In response to the second question as well: The following exerpts are taken from the Procedures For Assessment of the Conformity of Products Intended to be Placed on the Market (from a guide on the EMC Directive):
"Paragraph 5.1: This article describes the procedure whereby the manufacturer or his authorized representative established within the Community ensures and declares that the products concerned conform to the harmonized standards applicable to them. The manufacturer (or his authorized representative established within the Community) affixes the CE marking and draws up a written declaration of conformity. The manufacturer or his authorized representative established within the Community keeps this conformity declaration at the disposal of the competent authorities for inspection purposes for a period of ten years after the equipment was placed on the market. Where neither the manufacturer nor his authorized representative is established within the Community, the obligation to keep the conformity declaration available is the responsibility of the person who places the product on the Community market, this means the importer as defined in paragraph 2.5 of this document.... Paragraph 2.3 Manufacturer: This is the person who accepts responsibility for the design and manufacture of a product covered by the Directive with a view to placing it on the Community market on his own behalf.... Paragraph 2.4 Authorized Representative: This is the person who is expressly appointed by the manufacturer and acts on his behalf in respect of certain obligations laid down in the Directive. The extent to which the authorized representative may enter into commitments binding on the manufacturer is determin accordance with the mandate conferred on hime by the latter. Comments: If a manufacturer appoints an authorized representative, the latter must be established within the Community. Articles 10(1) and 10(2) of the EMC Directive define the obligations incumbent on the authorized representative established within the Community with regard to the conformity assessment procedures, CE markings, EC declaration of conformity and the arrangements for holding this EC declaration of conformity, together with the technical file, at the disposal of the competent authorities. Paragraph 2.5 Importer This is the person who places on the Community market a product covered by the Directive and imported from a third country. Under the terms of the Directive (Article 10(1), third paragraph, and Article 10(2), third paragraph), the importer must keep the manufacturer's declaration of conformity and the technical file at the disposal of the authorities, where neither the manufacturer nor his authorized representative is established within the Community." C. Johnson, CSA Note: These opinions were overheard when whispered by the invisible playmate of JE's invisible friend only >>> Mark Briggs <[email protected]> 07/11/97 10:04pm >>> 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]
