Most definitely.... The system integrator is ALWAYS responsible for the final outcome (whether it is internal cards or external printers as in the original case). If the system is found to fail, then the integrator must make it pass. The only difference is really a liability issue. Before, if you CE marked a product without testing it, even though it was made up of individually CE marked pieces, a manufacturer was subject to sanctions (fines, imprisonment, 'infamy'). Considering the new guidelines, you may still have to fix any problems which exist, but the sanctions will not be there. Also remember that a CE marked part must have been tested in a system similar to the new system for the CE mark to be valid. (Prior tests must be "relevant".)
The bottom line is that a system integrator is well advised to perform the tests to avoid delays and market loss, but if he is inclined, he can make a case for not testing a system of previously CE marked products. Bob Martin, PE, NCE EMC Department Manager ITS-Boxborough (508)263-2662 (508)266-1870 fax [email protected] ______________ The views expressed are my own and not necessarily those of my employer. ------------------------ ---------- From: Tony Fredriksson To: Robert F. Martin ITS/QS-Box; [email protected]; jlovell%[email protected] Subject: RE: CE Mark product standards for purchased equipment List-Post: [email protected] Date: Tuesday, March 11, 1997 11:36AM Hi, This is very intriguing. Let me throw out a scenario for comment. Let's say that I have a PC with CE marking and I integrate a video card and 15" monitor, also with CE Marking, and all declared to Class B levels. Now suppose I import the system to Germany and don't test to verify the combination since these "new guidelines" say that it is OK to do so based on the fact that all of the items bear the CE Marking. The authorities obtain a sample, test it, and find that video emissions are over the Class B limits at multiple frequencies (this happens all the time by the way). Let's also say that it is the particular monitor/video card combination that is the problem. Each manufacturer can demonstrate Class B compliance on some other combination of their respective products with some other CE marked support device. Each vendor has supporting documentation from a legitimate test lab to support their declarations. How will the authorities decide who is at fault? The EMC directive says that the manufacturer or his authorized rep within the Community shall affix the CE Marking and certify conformity. In this case, the monitor vendor can point a finger at the system and video card vendor, the system vendor can point a finger at the monitor and video card vendors, and the video card vendor can implicate the system and monitor vendors. Won't the authorities ultimately go after the system vendor for integrating the stuff and placing it on the market without testing to verify comliance with the applicable directives? If this is the case, the new guidelines would not appear to have any practical application. All comments on this scenario would be helpful! Regards, [email protected] ---------- From: rfm To: [email protected]; jlovell%[email protected] Subject: RE: CE Mark product standards for purchased equipment List-Post: [email protected] Date: Tuesday, March 11, 1997 7:42AM The 'new' guidelines on interpreting the EMC directive allow for the integration of multiple CE marked products without having to retest the full system. The caveat in that however is that the CE marking must be "relevant". That is, the original CE mark must have been applied based on tests which are equivalent to the environment that you are planning for the system. The fact that you say the printers "were not designed for these severe spikes..." indicates that they were NOT marked based on relevant standards. You must therefore fully test them in accordance with the appropriate standards as part of your system. Bob Martin, PE, NCE EMC Department Manager ITS-Boxborough (508)263-2662 (508)266-1870 fax [email protected] ______________ The views expressed are my own and not necessarily those of my employer. ------------------------ ---------- From: jlovell%[email protected] To: [email protected] Subject: CE Mark product standards for purchased equipment List-Post: [email protected] Date: Monday, March 10, 1997 2:07PM Hi, We are producing a product for use in marine navigation. It is an intentional transmitter, so we are getting it type-approved by a notified body, the DRA in the UK. DRA has told us ETS300339 is the relevant product standard. ETS300339 calls for most of the usual emissions and immunity tests such as EN55022 and IEC1000-4-x, but it also calls for testing to ISO7637, an automotive spike and surge immunity standard. The system will ship with a choice of printers that are DC-powered at 12 to 24 volts and that are purchased CE-marked from a reputable printer manufacturer. My question is: do these off-the-shelf printers have to comply with ISO7637 because they are part of this larger system, or can they stand alone with their current CE marking? The printers were not designed for these severe spikes and surges and will likely fail. ------------------------------------------ John Lovell Director of Quality Trimble Navigation Ltd. +408-481-2012 Voice +408-481-8194 FAX [email protected] ------------------------------------------
