> We have a product for non-residential use that is powered by a line 
> frequency a.c. power pack. With a 230 V a.c. power pack, the product has 
> been tested by a NATA accredited laboratory and meets EN55022: 1995 Class 
> A.  
> 
> If we source a UL approved 115 V a.c. power pack, is it necessary to have 
> the product re-tested for EMI with the new power pack for sale in the USA?

The FCC's position on this matter is very clear.  The FCC considers 
the total unit, including the power supply, to be the Equipment Under 
Test.
 
The FCC rules state that compliance with CISPR 22 is an acceptable 
means to show compliance with the FCC.  However, when testing to the 
CISPR 22 limits, the FCC test procedure, ANSI C63.4-1992, must be 
used. The testing must also be performed at the US line voltage, 
conducted emissions must be performed from 150 kHz to 30 MHz using 
both the QP and average limits (as per CISPR 22), and, if the unit 
uses or prduces a frequency above 108 MHz, radiated emissions testing 
must be performed up to the frequency specified by the FCC rules and using 
the FCC limit only for emissions above 1 GHz.

It sounds like you will definitely need to retest the conducted 
emissions of the new power supply with your unit and you should 
probably rescan the radiated emissions to insure that the new power 
supply does not cause any unforseen problems. If you decide to 
perform all of tests again, you may decide to test to the FCC limits 
at 115 V.

Finally, as of August 19, 1996, the FCC is implementing a program to 
separately approve power supplies and motherboards for Class B PC's. 
This program is currently in transition for power supplies until 
August 19, 1997 when it becomes mandatory.  I know this product is a 
Class A device, but it may now be possible to purchase an FCC Class B 
approved power supply. Under this same rule change, the 
manufacturer/integrator is allowed to change the power supply, 
motherboard, I/O card, etc. in an approved FCC unit with an approved 
component (i.e., power supply) and not retest the unit.  Please be 
aware that it has been an old practice of some power supply 
manuafacturers to advertize and place a sticker on their units (with 
the FCC logo) that states the units are FCC compliant.  This is not 
necessarily the same as FCC approved.

====================================================
Ray Hammonds                            Tel: 301-417-0220
Chief EMC Engineer                              Fax: 301-417-9069
Washington Laboratories
7560 Lindbergh Drive
Gaithersburg, MD  20879.
USA

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