It depends. If it costs money probably they will refrain or at least be 
reluctant and prefer
a warning in chinglish on page 97 note 21. 

Regards,

Ing. Gert Gremmen
Approvals manager
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+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
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From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Thursday 2 February 2017 23:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DoC when exempted from RED 2014/53/EU

Yes, manufacturers would be well advised to take precautions not to kill 
potential customers. Can we rely on them to do that?

With best wishes DESIGN IT IN! OOO - Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Pete Perkins [mailto:peperkin...@cs.com] 
Sent: Thursday, February 2, 2017 10:36 PM
To: 'John Woodgate' <jmw1...@btinternet.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU

John, et al,  

               My point, which I believe that I made below, is that even for 
board kits which leave everything out in the open there are techniques to 
minimize the exposure problems since not all of the users are experienced or 
fully qualified to know the risks and keep themselves out of harm's way.  
               The manufacturer has the responsibility to provide a device that 
is easy to use in a 'safe' manner (the definition of which I have expanded to 
include EMC issues altho not technically safety per se).  
               It's not good enuf to hide behind 'we met all of the 
requirements' - which were mostly none.  

:>)     br,      Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

p.perk...@ieee.org

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Thursday, February 2, 2017 9:44 AM
To: 'Pete Perkins' <peperkin...@cs.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU

I'm not quite sure of your point. The thread is about evaluation kits, which 
are very often just populated PC boards with I/O and power connectors. 
Everything is accessible, so if the board uses voltages that hurt (which is 
uncommon but not unknown), you don't touch. Equally, there are no fire 
enclosures.

With best wishes DESIGN IT IN! OOO - Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Pete Perkins [mailto:peperkin...@cs.com] 
Sent: Thursday, February 2, 2017 5:21 PM
To: 'John Woodgate' <jmw1...@btinternet.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU

John, et al,  

               It's nice to look for exemption loopholes but ... I would be 
careful in encouraging too much loosening based upon the skill of the users.  
       In today's environment many engineers and technicians are primarily 
software folks who are working with hardware to implement systems and these 
folks do not have the same training or appreciation of electrical hazards in 
equipment.  
       This comment applies equally to problems arising from EMC interference 
in applications; we know that there are a myriad of issues arising from the 
advent of multiple cell towers in operation.  Dropped call issues are usually 
dealt with by modifying software not repositioning antennas or other hardware 
fixes which are above the technicians pay grade.  
               I include radios generally in this comment because of the 
widespread use of digital radio equipment and the IoT explosion underway.     

:>)     br,      Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

p.perk...@ieee.org

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Thursday, February 2, 2017 4:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DoC when exempted from RED 2014/53/EU

'Being safe' with quite a loose interpretation thereof, because the users can 
be confidently taken to know what not to touch. Similarly for other hazards.

With best wishes DESIGN IT IN! OOO - Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: Thursday, February 2, 2017 11:14 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DoC when exempted from RED 2014/53/EU

Amund 

Hmmm, as I understand it, the exemption you refer to originates in the New 
Legislative Framework realignment with reference to provisions in Decision No 
768/2008/EC 

Article 4
Conformity assessment procedures
4.   For custom-made products and small series production, the technical and 
administrative conditions relating to conformity assessment procedures shall be 
alleviated.

These exemptions are discussed in the guide to the LVD and draft guide to the 
RED, but not in the RoHS2 FAQ.

The rules on what is and what is not a "custom-built evaluation kit" are 
reasonably tight, but the product meets the requirements, it should be exempt 
from all CE marking, though it is of course not exempt from "being safe"

regards
Charlie


________________________________________
From: Amund Westin <am...@westin-emission.no>
Sent: 02 February 2017 07:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] DoC when exempted from RED 2014/53/EU 
 
Radio equipment not covered by RED 2014/53/EU as Custom-built evaluation kits 
destined for professionals (Annex I), should they have a Declaration of 
Conformity?
They are exempted from RED, but I would assume ROHS apply. In such a case, 
should a DoC only cover ROHS listing?

I can not find any discussion about such situation in the Blue Guide.

Best regards
Amund
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