Re: ReIssue: RE: When CE doesn't pass
I read in !emc-pstc that Scott Douglas dougl...@naradnetworks.com wrote (in 5.0.2.1.2.20021122131840.00a58...@pop.business.earthlink.net ) about 'ReIssue: RE: When CE doesn't pass' on Fri, 22 Nov 2002: An alternative to this is have your company order all the Products from their various sources and drop ship directly to your customers. If the product does not enter your doors, you are not liable for it. That's moving towards treating the collection of equipment from different suppliers as an 'installation' as defined in the Directive. You still need Product D (a golden sample) or a simulator for compliance testing. I would opt for the simulator if possible. If it's an installation, it doesn't have to be tested as a whole. But Article 4 must still be observed (actual interference must not occur). Finely skirting the issue, I know. But if you don't bring the thing in you door then you need not worry about it. It's not 'finely skirting'; it's understanding how the Directive applies in such circumstances. And you CAN bring it into your premises, provided you do NOTHING to it. You must INVOICE all the individual items of equipment separately. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: ReIssue: RE: When CE doesn't pass
Brian, Is there any way to replace the offending Product D with another vendor? If so, do it. If not, can you configure the system without Product D? If so, do it. If not, buy one Product D for your use in configuring complete systems. Then have your customer buy your system less Product D from you and have your customer also buy Product D from the original manufacturer. An alternative to this is have your company order all the Products from their various sources and drop ship directly to your customers. If the product does not enter your doors, you are not liable for it. You still need Product D (a golden sample) or a simulator for compliance testing. I would opt for the simulator if possible. Finely skirting the issue, I know. But if you don't bring the thing in you door then you need not worry about it. Also, DO NOT OPEN the offending product, EVER, unless you want to own it complete (that means all compliances of whatever type). By this I mean on a production basis. You can do anything you want to a simulator or support equipment. I expect I'll be hearing about this from others on the list. Just my 2 cents worth. Regards, Scott Douglas At 12:28 PM 11/22/02 -0500, brian_ku...@leco.com wrote: snip with turning them in won't help us ship product. Is there any train of thought, loophole, or documentation trail that will allow us to market and sell this turn-key system? How do we become liable for a CE labeled product that someone else's makes? I know we don't want to sell a non-compliant system, but what are we to do? Some suggest fixing the product yourself. If it can't be done externally, as soon as we open up the unit don't we become responsible for it including safety? I don't think we want to do that. Thanks to all again, Brian Kunde LECO --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: When CE doesn't pass
For large systems which cannot logistically either fit into chambers or would cost a small fortune to ship to a lab I believe you can have a notified body do modified EMC on site. I know TUV Rheinland in Newtown CT has a very nice Mobile EMC lab where they will come to your facility and do testing and issue you a TCF certificate. Of course this cannot be done if your system can be tested in a chamber.. Certainly it cost more to have this on site testing done but in the long run it saves a ton of money in shipping alone!!.Go to TUV.com for more details.. -Original Message- From: Leslie Bai [mailto:leslie_...@yahoo.com] Sent: Friday, November 22, 2002 5:05 PM To: EMC-PSTC Subject: RE: When CE doesn't pass It was about five years ago, I did an EMC job to meet the CE mark requirement for a Semiconductor equipment manufacturer by the approach of TCF (Technical Construction File). The whole system was real giant and there was no way to bring the system to the lab fitting in the chamber. Many sub-systems were OEM parts and most of them had been CE marked. However, during the site testing at customer's premises, a walky-talky made the system shut-down. It was quite straight-forward to find the cause of the failure and that was the CE marked UPS system. When we looked at the detail information of the CE Marked UPS system, it was truely CE marked, however the test report shows that this UPS system is a Class B device and that manufacturer declared CE compliance at Class B. Nobody was wrong, but the Semiconductor system must meet Class A environment. The advice to the semicondutor equipment manufacturer was to either fix the UPS immunity problem or change another UPS system. So CE marked - what does that mean? It is a manufacturer's self declaration. As a result of this when you shop around for CE marked sub-systems or OEM parts, make sure that CE mark is what you want. Regards, Leslie _ Do you Yahoo!? Yahoo! Mail http://rd.yahoo.com/mail/mailsig/*http://mailplus.yahoo.com Plus - Powerful. Affordable. Sign up http://rd.yahoo.com/mail/mailsig/*http://mailplus.yahoo.com now --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: ReIssue: When CE doesn't pass
You would certainly violate any warranties such as service and manufacturing. Bob Heller 3M Product Safety, 76-1-01 St. Paul, MN 55107-1208 Tel: 651- 778-6336 = lisa_cef...@mksinst.co mTo: Chris K. Poore chr...@percept.com Sent by: cc: EMC-PSTC emc-p...@majordomo.ieee.org owner-emc-pstc@majordo owner-emc-p...@majordomo.ieee.org mo.ieee.org Subject: RE: ReIssue: When CE doesn't pass 11/25/2002 07:06 AM Please respond to Lisa_Cefalo I would be a bit concerned with altering another's product. Two things could happen, you could violate some other aspect of CE, so you would need to re-test everything, or, you could violate something in the design itself, and how would you explain a field problem? The liability would rest on you either way. Passing CE is such a relative term, as we all know, and depends on many things including standards tested to, and pass/fail criteria. What to do? A nasty dilemma. My suggestion would be, if you want to make the investment, would be to find out the source of the problem and perhaps approach the OEM with a proposal for your purchasing a special unit that has hardened RF immunity (or emissions, whichever is the problem) That way, your not accusing them of lying, just stating that your requirements in the environment used are a bit more stringent. Worth a try. Good luck Lisa Lisa A. Cefalo, CRE Manager, Reliability and Design Services MKS Instruments 6 Shattuck Road Andover, MA 01810 (978)-975-2350 X 5669 lisa_cef...@mksinst.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: ReIssue: When CE doesn't pass
I would be a bit concerned with altering another's product. Two things could happen, you could violate some other aspect of CE, so you would need to re-test everything, or, you could violate something in the design itself, and how would you explain a field problem? The liability would rest on you either way. Passing CE is such a relative term, as we all know, and depends on many things including standards tested to, and pass/fail criteria. What to do? A nasty dilemma. My suggestion would be, if you want to make the investment, would be to find out the source of the problem and perhaps approach the OEM with a proposal for your purchasing a special unit that has hardened RF immunity (or emissions, whichever is the problem) That way, your not accusing them of lying, just stating that your requirements in the environment used are a bit more stringent. Worth a try. Good luck Lisa Lisa A. Cefalo, CRE Manager, Reliability and Design Services MKS Instruments 6 Shattuck Road Andover, MA 01810 (978)-975-2350 X 5669 lisa_cef...@mksinst.com Chris K. Poore chr...@percept.com To: EMC-PSTC emc-p...@majordomo.ieee.org Sent by: cc: owner-emc-pstc@majordoSubject: RE: ReIssue: When CE doesn't pass mo.ieee.org 11/22/2002 03:31 PM Please respond to Chris K. Poore Brian, Fix it. I said this before, and you expressed some concern about safety. I wouldn't be afraid about attempting to make changes to see what it might take to fix the product - you won't know until you try. I personally HATE having to fix an OEM's problems. Each change would have to evaluated and documented as to how this affects safety. A ferrite clamped on an internal cable will most likely not affect safety provided it is secured in place. A line filter could be a problem, but even that can be justified by a few simple tests and some documentation. In one case, I found that the conducted emissions on an OEM component were reduced by REMOVING the line filter. All other tests were also positive. In this case, the OEM was more than happy to cut cost from their product by removing the filter. (I still wonder if someone out there who was using the same OEM was suddenly baffled as to why they were suddenly failing EMC when they had once passed? SORRY!) it passes when we test it If you are an OEM and you say this to me... aaa I won't go there. Chris --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription
Re: When CE doesn't pass
Such is lifeI have seen way too much of this with monitors in particular from outside the US. If you are the manufacturer whose name is one the equipment you are selling and you have a failing component you are on the hook. What I have done under such circumstances is to obtain data for the specific component and send them the data and pictures from an accredited lab. If that doesn't work and you want results notify the agency responsible for the enforcement of the mark. Manufacturers have to be responsible for compliance for their product, not getting by on the coattails of others. Warren Birmingham Epsilon-Mu Consultants On Thursday, Nov 21, 2002, at 11:40 US/Pacific, brian_ku...@leco.com wrote: Has this ever happened to you? We manufacture analysis instrumentation equipment. The part we make is usually part of a complex system made up of other CE marked equipment from many different suppliers. Sometimes when we have a system tested for CE (emissions and immunity), one of the other companies pieces of equipment will cause the system to fail. I have seen some test labs identify the failing piece of equipment, write it up in the report and say it is not our problem because our equipment passes AND it is not contributing to the failure. But, what if we are selling the system including the CE Marked products that failed when we had it tested? It doesn't always do us much good to go to the manufacturer of the failing equipment because they will usually say that it passes when they tests it. If we were a PC manufacturer and had trouble with a printer or a monitor we could just find another one, but the equipment in our systems are more unique. There may only be 1 or 2 manufacturers of such a device and we don't have much of a choice. So here is my question. Can we sell a system that includes a CE marked peripheral that we have no design control over, that fails when WE have it tested? Please advise and Thank you in advance. Brian Kunde LECO Corp. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: When CE doesn't pass
One thing to watch for when applying ferrites is the weight. I had a client who put a ferrite on an AC power wire inside an ITE product tabletop enclosure. The ferrite caused the connector to come unplugged and resulted in exposed AC power wires freely moving about in the unit. Clearly, an EMC fix causing a safety issue. Tie wrap and shrink wrap can sometimes be used to solve the movement problem. Craig Burow Senior Compliance Manager Percept Technology Labs, Inc. Product Test and Compliance Experts 4735 Walnut Street #E Boulder CO 80301 303-444-7480 ext 102 phone 303-444-1565 fax cra...@percept.com http://www.percept.com/ -Original Message- From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of Gary McInturff Sent: Friday, November 22, 2002 1:24 PM To: brian_ku...@leco.com; emc-p...@majordomo.ieee.org Subject: RE: ReIssue: RE: When CE doesn't pass -Original Message- From: brian_ku...@leco.com [mailto:brian_ku...@leco.com] Sent: Friday, November 22, 2002 9:29 AM To: emc-p...@majordomo.ieee.org Subject: ReIssue: RE: When CE doesn't pass Thanks to everyone who responded to my earlier email. After reading the replies, I wanted to rephrase and clarify our situation to see if it matters. We design, manufacture, and market stand-a-lone Product A. But some of our customers want a complete turn-key system. So we purchase and re-sell Products B, C, and D. Each are individually marketed by their manufacturer and has the CE marking. We sell and setup this turn-key system for our customers. This might be seen as CE+CE+CE+CE should equal CE. Our company always wants to do what's right, so we test this turn-key system for CE. During the EMC testing, Product D causes the system to fail. Additional investigation finds that Product D fails all by itself, independent of the rest of the system. When the manufacturer of Product D is contacted, they reply with, it passes when we test it. Another problem is that we do not have enough buying power to force them to look into the problem and threatening them with turning them in won't help us ship product. Is there any train of thought, loophole, or documentation trail that will allow us to market and sell this turn-key system? How do we become liable for a CE labeled product that someone else's makes? I know we don't want to sell a non-compliant system, but what are we to do? Some suggest fixing the product yourself. If it can't be done externally, as soon as we open up the unit don't we become responsible for it including safety? I don't think we want to do that. Thanks to all again, Brian Kunde LECO tc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: When CE doesn't pass
It was about five years ago, I did an EMC job to meet the CE mark requirement for a Semiconductor equipment manufacturer by the approach of TCF (Technical Construction File). The whole system was real giant and there was no way to bring the system to the lab fitting in the chamber. Many sub-systems were OEM parts and most of them had been CE marked. However, during the site testing at customer's premises, a walky-talky made the system shut-down. It was quite straight-forward to find the cause of the failure and that was the CE marked UPS system. When we looked at the detail information of the CE Marked UPS system, it was truely CE marked, however the test report shows that this UPS system is a Class B device and that manufacturer declared CE compliance at Class B. Nobody was wrong, but the Semiconductor system must meet Class A environment. The advice to the semicondutor equipment manufacturer was to either fix the UPS immunity problem or change another UPS system. So CE marked - what does that mean? It is a manufacturer's self declaration. As a result of this when you shop around for CE marked sub-systems or OEM parts, make sure that CE mark is what you want. Regards, Leslie - Do you Yahoo!? Yahoo! Mail Plus - Powerful. Affordable. Sign up now
Re: ReIssue: RE: When CE doesn't pass
I read in !emc-pstc that brian_ku...@leco.com wrote (in tfscc...@leco.com) about 'ReIssue: RE: When CE doesn't pass' on Fri, 22 Nov 2002: Thanks to everyone who responded to my earlier email. After reading the replies, I wanted to rephrase and clarify our situation to see if it matters. We design, manufacture, and market stand-a-lone Product A. But some of our customers want a complete turn-key system. So we purchase and re-sell Products B, C, and D. Each are individually marketed by their manufacturer and has the CE marking. We sell and setup this turn-key system for our customers. This might be seen as CE+CE+CE+CE should equal CE. Our company always wants to do what's right, so we test this turn-key system for CE. During the EMC testing, Product D causes the system to fail. Additional investigation finds that Product D fails all by itself, independent of the rest of the system. When the manufacturer of Product D is contacted, they reply with, it passes when we test it. Another problem is that we do not have enough buying power to force them to look into the problem and threatening them with turning them in won't help us ship product. Is there any train of thought, loophole, or documentation trail that will allow us to market and sell this turn-key system? Yes. See below. How do we become liable for a CE labeled product that someone else's makes? I know we don't want to sell a non-compliant system, but what are we to do? See below. Some suggest fixing the product yourself. If it can't be done externally, as soon as we open up the unit don't we become responsible for it including safety? Yes, you do. I don't think we want to do that. I don't blame you. The crunch question is whether you are selling a 'system' or an 'installation' ***as defined by the Directive***. If these 'turnkey' systems are really produced for individual customers' requirements, and are not routinely-produced items, then they are 'installations'. To establish this, you do not quote **or invoice** an inclusive price for the whole shebang (which would make it a 'single article of commerce') but individual prices for the constituent products, especially those you are re-selling. Assuming that you don't act as the importer of these third-party products into the European Economic Area, you then have minimal responsibility for the EMC or safety performance of the third-party products, **provided** that you have valid DoCs for them. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: ReIssue: When CE doesn't pass
Brian, Fix it. I said this before, and you expressed some concern about safety. I wouldn't be afraid about attempting to make changes to see what it might take to fix the product - you won't know until you try. I personally HATE having to fix an OEM's problems. Each change would have to evaluated and documented as to how this affects safety. A ferrite clamped on an internal cable will most likely not affect safety provided it is secured in place. A line filter could be a problem, but even that can be justified by a few simple tests and some documentation. In one case, I found that the conducted emissions on an OEM component were reduced by REMOVING the line filter. All other tests were also positive. In this case, the OEM was more than happy to cut cost from their product by removing the filter. (I still wonder if someone out there who was using the same OEM was suddenly baffled as to why they were suddenly failing EMC when they had once passed? SORRY!) it passes when we test it If you are an OEM and you say this to me... aaa I won't go there. Chris --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: ReIssue: RE: When CE doesn't pass
Brian, I don't think it matters, if you are selling the equipment to your customers you bear the obligations EMC and everything else. It certainly gives you the right to eliminate a failing vendor from your qualified vendor list, but you can't just pass the problem on the client and say its not your fault. Even if the EU didn't care, I suspect your customer is not going to go after your suppliers if he runs into a problem. You're the one he paid money to in order to meet some need of theirs, and I expect they will insist that you deliver what you said you would. Gary -Original Message- From: brian_ku...@leco.com [mailto:brian_ku...@leco.com] Sent: Friday, November 22, 2002 9:29 AM To: emc-p...@majordomo.ieee.org Subject: ReIssue: RE: When CE doesn't pass Thanks to everyone who responded to my earlier email. After reading the replies, I wanted to rephrase and clarify our situation to see if it matters. We design, manufacture, and market stand-a-lone Product A. But some of our customers want a complete turn-key system. So we purchase and re-sell Products B, C, and D. Each are individually marketed by their manufacturer and has the CE marking. We sell and setup this turn-key system for our customers. This might be seen as CE+CE+CE+CE should equal CE. Our company always wants to do what's right, so we test this turn-key system for CE. During the EMC testing, Product D causes the system to fail. Additional investigation finds that Product D fails all by itself, independent of the rest of the system. When the manufacturer of Product D is contacted, they reply with, it passes when we test it. Another problem is that we do not have enough buying power to force them to look into the problem and threatening them with turning them in won't help us ship product. Is there any train of thought, loophole, or documentation trail that will allow us to market and sell this turn-key system? How do we become liable for a CE labeled product that someone else's makes? I know we don't want to sell a non-compliant system, but what are we to do? Some suggest fixing the product yourself. If it can't be done externally, as soon as we open up the unit don't we become responsible for it including safety? I don't think we want to do that. Thanks to all again, Brian Kunde LECO Reply Separator Subject:RE: When CE doesn't pass Author: neil.bar...@e2vtechnologies.com List-Post: emc-pstc@listserv.ieee.org Date: 11/22/02 4:25 AM No, you can't. If you are placing the system on the market as a single commercial unit then you must issue a Declaration of Conformity for the system. However, if you place the system on the market without the peripheral then you could claim conformity for that system as a unit. If you also sold the peripheral, acting purely as a distributor for the manufacturer of the peripheral, then the legal responsibility for that peripheral would lie with the other manufacturer. However, do you really want your system to be associated with a non-compliant product? Personally, I would inform the manufacturer of the peripheral of the problem and look elsewhere for an alternative unless he took action to make it compliant. To relate this to another thread that is running at present, this is a prime example of CE + CE does NOT make CE! Best regards, Neil R. Barker Compliance Engineering Manager E2V Technologies Waterhouse Lane Chelmsford Essex CM1 2QU U.K. Tel: +44 (01245) 453616 Fax: +44 (01245) 453410 E-mail: neil.bar...@e2vtechnologies.com -Original Message- From: brian_ku...@leco.com [mailto:brian_ku...@leco.com] Sent: 21 November 2002 19:41 To: emc-p...@majordomo.ieee.org Subject: When CE doesn't pass Has this ever happened to you? We manufacture analysis instrumentation equipment. The part we make is usually part of a complex system made up of other CE marked equipment from many different suppliers. Sometimes when we have a system tested for CE (emissions and immunity), one of the other companies pieces of equipment will cause the system to fail.I have seen some test labs identify the failing piece of equipment, write it up in the report and say it is not our problem because our equipment passes AND it is not contributing to the failure. But, what if we are selling the system including the CE Marked products that failed when we had it tested? It doesn't always do us much good to go to the manufacturer of the failing equipment because they will usually say that it passes when they tests it. If we were a PC manufacturer and had trouble with a printer or a monitor we could just find another one, but the equipment in our systems are more unique. There may only be 1 or 2 manufacturers of such a device and we don't have much of a choice. So here is my question. Can we sell a system that includes a CE marked peripheral that we
ReIssue: RE: When CE doesn't pass
A tricky situation, you have my sympathy. There are principals involved, and I can imagine that feelings about being let down by a supplier are also part of the picture. Sometimes the solution to such situations comes not from the confrontation but by the back door. What if your EMC lab were to spend half a day or a day investigating the rogue units? If they can come up with a fix the details might be used in a bargaining situation along the lines of Here's what you have to do. We're going to check out alternate suppliers. You can keep us as a customer if you fix the units you ship by XYZ date. If not we reserve the right to cancel contracts on the grounds of non-compliance, and, publish that information to the relevant authorities. That might encourage them to be more responsive, what do you think? Best Regards Ted Rook, Console Engineering, ext 4659 Please note our new location and phone numbers: Crest Audio Inc, 16-00 Pollitt Drive Fair Lawn, NJ 07410 USA 201 475 4600 telephone receptionist, 8.30 - 5 pm EST. 201 475 4659 direct line w/voice mail, 24 hrs. 201 475 4677 fax, 24 hrs. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: ReIssue: RE: When CE doesn't pass
I assume that you already did this, but your email didn't explicitly say so. Did you ask D's manufacturer HOW they test it? You may be surprised. I have knocked myself out trying to get a product to pass testing with an operating Ethernet port; only to find out that our OEM manufacturer tested the port with a one meter dummy cable and no traffic. However, at least they were good enough to show me their complete test report so that I could at least replicate what they did. Chris Maxwell | Design Engineer - Optical Division email chris.maxw...@nettest.com | dir +1 315 266 5128 | fax +1 315 797 8024 NetTest | 6 Rhoads Drive, Utica, NY 13502 | USA web www.nettest.com | tel +1 315 797 4449 | -Original Message- From: brian_ku...@leco.com [SMTP:brian_ku...@leco.com] Sent: Friday, November 22, 2002 12:29 PM To: emc-p...@majordomo.ieee.org Subject: ReIssue: RE: When CE doesn't pass Thanks to everyone who responded to my earlier email. After reading the replies, I wanted to rephrase and clarify our situation to see if it matters. We design, manufacture, and market stand-a-lone Product A. But some of our customers want a complete turn-key system. So we purchase and re-sell Products B, C, and D. Each are individually marketed by their manufacturer and has the CE marking. We sell and setup this turn-key system for our customers. This might be seen as CE+CE+CE+CE should equal CE. Our company always wants to do what's right, so we test this turn-key system for CE. During the EMC testing, Product D causes the system to fail. Additional investigation finds that Product D fails all by itself, independent of the rest of the system. When the manufacturer of Product D is contacted, they reply with, it passes when we test it. Another problem is that we do not have enough buying power to force them to look into the problem and threatening them with turning them in won't help us ship product. Is there any train of thought, loophole, or documentation trail that will allow us to market and sell this turn-key system? How do we become liable for a CE labeled product that someone else's makes? I know we don't want to sell a non-compliant system, but what are we to do? Some suggest fixing the product yourself. If it can't be done externally, as soon as we open up the unit don't we become responsible for it including safety? I don't think we want to do that. Thanks to all again, Brian Kunde LECO Reply Separator Subject:RE: When CE doesn't pass Author: neil.bar...@e2vtechnologies.com Date: 11/22/02 4:25 AM No, you can't. If you are placing the system on the market as a single commercial unit then you must issue a Declaration of Conformity for the system. However, if you place the system on the market without the peripheral then you could claim conformity for that system as a unit. If you also sold the peripheral, acting purely as a distributor for the manufacturer of the peripheral, then the legal responsibility for that peripheral would lie with the other manufacturer. However, do you really want your system to be associated with a non-compliant product? Personally, I would inform the manufacturer of the peripheral of the problem and look elsewhere for an alternative unless he took action to make it compliant. To relate this to another thread that is running at present, this is a prime example of CE + CE does NOT make CE! Best regards, Neil R. Barker Compliance Engineering Manager E2V Technologies Waterhouse Lane Chelmsford Essex CM1 2QU U.K. Tel: +44 (01245) 453616 Fax: +44 (01245) 453410 E-mail: neil.bar...@e2vtechnologies.com -Original Message- From: brian_ku...@leco.com [mailto:brian_ku...@leco.com] Sent: 21 November 2002 19:41 To: emc-p...@majordomo.ieee.org Subject: When CE doesn't pass Has this ever happened to you? We manufacture analysis instrumentation equipment. The part we make is usually part of a complex system made up of other CE marked equipment from many different suppliers. Sometimes when we have a system tested for CE (emissions and immunity), one of the other companies pieces of equipment will cause the system to fail.I have seen some test labs identify the failing piece of equipment, write it up in the report and say it is not our problem because our equipment passes AND it is not contributing to the failure. But, what if we are selling the system including the CE Marked products that failed when we had it tested? It doesn't always do us much good to go to the manufacturer of the failing equipment because they will usually say that it passes when they tests it. If we were a PC manufacturer and had trouble with a printer or a monitor we could just find another one, but the equipment in our systems are more
ReIssue: RE: When CE doesn't pass
Thanks to everyone who responded to my earlier email. After reading the replies, I wanted to rephrase and clarify our situation to see if it matters. We design, manufacture, and market stand-a-lone Product A. But some of our customers want a complete turn-key system. So we purchase and re-sell Products B, C, and D. Each are individually marketed by their manufacturer and has the CE marking. We sell and setup this turn-key system for our customers. This might be seen as CE+CE+CE+CE should equal CE. Our company always wants to do what's right, so we test this turn-key system for CE. During the EMC testing, Product D causes the system to fail. Additional investigation finds that Product D fails all by itself, independent of the rest of the system. When the manufacturer of Product D is contacted, they reply with, it passes when we test it. Another problem is that we do not have enough buying power to force them to look into the problem and threatening them with turning them in won't help us ship product. Is there any train of thought, loophole, or documentation trail that will allow us to market and sell this turn-key system? How do we become liable for a CE labeled product that someone else's makes? I know we don't want to sell a non-compliant system, but what are we to do? Some suggest fixing the product yourself. If it can't be done externally, as soon as we open up the unit don't we become responsible for it including safety? I don't think we want to do that. Thanks to all again, Brian Kunde LECO Reply Separator Subject:RE: When CE doesn't pass Author: neil.bar...@e2vtechnologies.com List-Post: emc-pstc@listserv.ieee.org Date: 11/22/02 4:25 AM No, you can't. If you are placing the system on the market as a single commercial unit then you must issue a Declaration of Conformity for the system. However, if you place the system on the market without the peripheral then you could claim conformity for that system as a unit. If you also sold the peripheral, acting purely as a distributor for the manufacturer of the peripheral, then the legal responsibility for that peripheral would lie with the other manufacturer. However, do you really want your system to be associated with a non-compliant product? Personally, I would inform the manufacturer of the peripheral of the problem and look elsewhere for an alternative unless he took action to make it compliant. To relate this to another thread that is running at present, this is a prime example of CE + CE does NOT make CE! Best regards, Neil R. Barker Compliance Engineering Manager E2V Technologies Waterhouse Lane Chelmsford Essex CM1 2QU U.K. Tel: +44 (01245) 453616 Fax: +44 (01245) 453410 E-mail: neil.bar...@e2vtechnologies.com -Original Message- From: brian_ku...@leco.com [mailto:brian_ku...@leco.com] Sent: 21 November 2002 19:41 To: emc-p...@majordomo.ieee.org Subject: When CE doesn't pass Has this ever happened to you? We manufacture analysis instrumentation equipment. The part we make is usually part of a complex system made up of other CE marked equipment from many different suppliers. Sometimes when we have a system tested for CE (emissions and immunity), one of the other companies pieces of equipment will cause the system to fail.I have seen some test labs identify the failing piece of equipment, write it up in the report and say it is not our problem because our equipment passes AND it is not contributing to the failure. But, what if we are selling the system including the CE Marked products that failed when we had it tested? It doesn't always do us much good to go to the manufacturer of the failing equipment because they will usually say that it passes when they tests it. If we were a PC manufacturer and had trouble with a printer or a monitor we could just find another one, but the equipment in our systems are more unique. There may only be 1 or 2 manufacturers of such a device and we don't have much of a choice. So here is my question. Can we sell a system that includes a CE marked peripheral that we have no design control over, that fails when WE have it tested? Please advise and Thank you in advance. Brian Kunde LECO Corp. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived
Re: When CE doesn't pass
Brian Kunde wrote: Sometimes when we have a system tested for CE (emissions and immunity), one of the other companies pieces of equipment will cause the system to fail. Yes, indeed. Luckily, I worked for a computer manufacturer and we could find other vendors. Still, I have found it advisable to add wording to purchase specifications, something like: Product shall be compliant with insert standard here. Product shall not, when attached to an otherwise compliant equipment, result in non-compliance. However, one cannot rely on this sort of thing. Some foresight has to be exercised in designing I/O and power connections so that they do not rely for compliance on expected suppression in another piece of equipment. I have seen engineers who relied on EMC suppression in a printer to reduce emissions associated with a driver; changing to a different printer had them scrambling to deal with problems they'd left untreated. Anyway, the question you ask contains its own answer: Can you sell non-compliant products? No. If you tested it, you certainly knew that you were placing a non-compliant system on the market, and the authorities would look very closely at those who made the decision to do so. Cheers, Cortland --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: When CE doesn't pass
Has this ever happened to you? ALL the time... My opinion: The system must pass if the equipment in the system tested is what you are intending to ship. If the failing component is part of the system you ship, then you should get it fixed. That's why the labs stock all those free ferrites - so you can fix someone elses problems. If the component that fails is NOT part of the system you ship, then the best approach is to replace that component with one that does. That's why I always keep a stock of peripherals that I know are class B compliant. I want a clean emissions report. A possible fix for this, one I have used in the past, is to specify EMC and safety requirements in the contract with your OEM supplier. That way, if there are failures to their product, they are contractually obligated to fix it. Works well if you are a high-volume client. Chris Poore --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: When CE doesn't pass
As I have previously babbled, a Declaration of Conformity (by itself) has no meaning. Get the CB and/or agency test report and note test conditions. If a CE-marked unit has no Certificate from TUV, VDE, etc; then try to find another supplier. The standard(s) listed on the certificate will theoretically provide the basic test conditions. If your supplier's Compliance Engineer cannot define specific test conditions, find another... Customers that fail my units during EMC or safety testing typically are not performing the test correctly or the end-use installation violates Conditions of Acceptability. I never speak for my employer. Brian -Original Message- From: brian_ku...@leco.com [mailto:brian_ku...@leco.com] Sent: Thursday, November 21, 2002 11:41 AM To: emc-p...@majordomo.ieee.org Subject: When CE doesn't pass Has this ever happened to you? We manufacture analysis instrumentation equipment. The part we make is usually part of a complex system made up of other CE marked equipment from many different suppliers. Sometimes when we have a system tested for CE (emissions and immunity), one of the other companies pieces of equipment will cause the system to fail. I have seen some test labs identify the failing piece of equipment, write it up in the report and say it is not our problem because our equipment passes AND it is not contributing to the failure. But, what if we are selling the system including the CE Marked products that failed when we had it tested? It doesn't always do us much good to go to the manufacturer of the failing equipment because they will usually say that it passes when they tests it. If we were a PC manufacturer and had trouble with a printer or a monitor we could just find another one, but the equipment in our systems are more unique. There may only be 1 or 2 manufacturers of such a device and we don't have much of a choice. So here is my question. Can we sell a system that includes a CE marked peripheral that we have no design control over, that fails when WE have it tested?
When CE doesn't pass
Has this ever happened to you? We manufacture analysis instrumentation equipment. The part we make is usually part of a complex system made up of other CE marked equipment from many different suppliers. Sometimes when we have a system tested for CE (emissions and immunity), one of the other companies pieces of equipment will cause the system to fail. I have seen some test labs identify the failing piece of equipment, write it up in the report and say it is not our problem because our equipment passes AND it is not contributing to the failure. But, what if we are selling the system including the CE Marked products that failed when we had it tested? It doesn't always do us much good to go to the manufacturer of the failing equipment because they will usually say that it passes when they tests it. If we were a PC manufacturer and had trouble with a printer or a monitor we could just find another one, but the equipment in our systems are more unique. There may only be 1 or 2 manufacturers of such a device and we don't have much of a choice. So here is my question. Can we sell a system that includes a CE marked peripheral that we have no design control over, that fails when WE have it tested? Please advise and Thank you in advance. Brian Kunde LECO Corp. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
