In reply to your second question, I would agree with Richard Woods that, as far as I am aware, there is no requirement for the person signing the DoC to be resident in Europe. I believe the DoC must be held in Europe, however, and so either the manufacturer's European office or distributor/Importer should have the original. The DoC must be held for 10 years after the last product is placed on the market.
Secondly, there is no requirement to present any data to the European community with respect to EMC testing. The latest version of the guidelines to the EMC Directive state that there is "...no requirement for a technical file to demonstrate the steps taken to show compliance with the Directive." (Section 8.1 of the Guidelines) when using the self certification route (as opposed to either the technical construction file or type-examination routes). In the same section, however, the Guidelines suggest that you should retain documentation to support your claim of compliance. Thus, the manufacturer only has to assure him/herself that the unit will comply with the relevant standards before applying the CE mark and signing a Declaration of Conformity. In answer to your first question the manufacturer can do as little or as much testing as they like using whatever facilities they like. If a product is taken for sample testing by an enforcement body in Europe it will test at an accredited OATS/EMC facility against the letter of the applicable standards. As for EN55022 allowing the use of a SAC for performing tests, section 11.3.5 of the 1994 version states that tests sites not having the physical characteristics of an OATS (as defined in 11.3.3 and 11.3.4) are suitable if they meet the site attenuation characteristics when measured in accordance with annex A of the standard. Regards, Mark "...opinions expressed are opinions etc etc etc....." >From: [email protected] >To: [email protected] >Subject: alternate test sites >Date: Friday, July 11, 1997 10:55AM > > >Greetings, > >These 2 questions may seem rather naive, but I never really had to >address >them. Any help by those who have direct experience would be greatly >appreciated. > >1. I heard the statement "The EU does not accept emissions data from a >semi-anechoic chamber (SAC)" Since I deal mostly with ITE, I looked in >EN55022-1987, para. 10.3.3 and see no mention of the use of anything but >an >OATS. The question is "Does all testing to EN55022 have to be performed >at >an OATS or can I use a SAC which has a "good" normalized site >attenuation >(<+/- 4 dB)?" It would seem to me that if you are self certifying, you >would want to be confident the equipment passes with enough margin that >it >would pass anywhere. If you felt confident using a current probe and a >scope, then go ahead and self-certify. > >2. My second question deals with the famous person who signs test >reports >and is the responsible person (i.e. jail time) should the data be found >to >be bogus. Again, assume we are self certifying ITE equipment. I was >told >that the responsible person must be a resident of the EU. A company in >the >States could not self certify and place the CE mark on equipment with >"only" the head of quality signature, assuming the head of quality lives >in >Anytown USA. I also heard that less than reputable companies in the >States >find "some European guy" who will sign anything and can vanish if the >need >arises. > >Some of this sounds like urban legend to me, but I appreciate any >comments >you may have. > >Thanks in advance... > >Jim Nadolny >AMP Inc. >jim [email protected]
