Hello, again.
The new DRAFT guidelines prepared by the European Commission on
application of the EMC Directive explain integration of individually
CE marked subsystems in section 6.3.2, titled "Systems assembled from
only CE marked apparatus". This section is quite clear in stating
that such systems often do not have to be re-tested for compliance.
Of course, there are exceptions for some types of specialized systems,
especially industrial type equipment where, I suppose, the EMC
performance of the final system cannot be easily predicted.
Page 10 of the FCC's OET Bulletin No. 62, titled "Understanding the
FCC Regulations for Computers and Other Digital Devices", has a
paragraph that states that a system can be assembled and sold without
FCC authorization if only FCC authorized subsystems are used and any
special instructions for compliance, such as the use of shielded
cables, are followed.
The intent of the above paragraphs is (believe it or not) to lessen
the burden on system integrators for compulsory re-testing. However,
in the end, the system integrator is held responsible for compliance
of the final system. Good judgment and "due diligence" must always
prevail. If in doubt, re-test.
______________________________________________________________________
Jim Hulbert Tel: 203-924-3621
Senior Engineer - EMC Fax: 203-924-3352
Pitney Bowes email: [email protected]
P.O. Box 3000
35 Waterview Drive
Shelton, CT 06484-8000 U.S.A.
______________________________ Forward Header __________________________________
Subject: Re: CE Marked Subassemblies & Components
Author: Jim Hulbert at zippypo
List-Post: [email protected]
Date: 6/12/97 5:00 PM
I agree that your keyboard subassemblies in and of themselves need not
be CE marked or FCC certified if they not sold to the end user. It
sounds from your description that they are sold to a system integrator
who in turn sells the final system to the end user. The system
integrator is responsible for the compliance of the whole system, which
will include your keyboard.
The system integrator, however, would expect that the subassembly you
supply for use in his system would be designed with EMC in mind and
would not cause his system to fail EMC testing. I don't see how you
as a supplier can guarantee that without doing some testing of your
own.
It is perfectly acceptable for a system integrator to use different
suppliers' subsystems (i.e. PC chassis, monitor, keyboard, mouse,
printer, etc...) that are individually CE marked and declare system
compliance with the EMC Directive, provided that any conditions of the
CE marking for the subsystems (i.e. use of shielded cables, etc...) are
strictly followed. However, it is wise for the system integrator to
make sure CE marked subsystems have in fact been properly tested for
compliance. I would request, as a minimum, a copy of the test report.
If the manufacturer can't or won't supply test data, I would either
test myself or find another vendor for that subsystem. The same goes
for systems assembled from individually FCC certified subsystems.
When a product is CE marked, I don't believe it is ever necessary to
list the representative systems the product was tested in on the
Declaration of Conformity. The DoC should list the Directives that
are met and the standards that were applied. If there is a wide
variety of possible system configurations, it may be wise to follow
the TCF route to compliance. In that case the DoC should name the
competent body that assessed the TCF.
One final note, CE marking (or FCC certification) is generally only
appropriate for equipment or subsystems that have an intrinsic
function for an end user, such as a PC or a CRT monitor. It is
generally not appropriate for individual components that in and of
themselves have no intrinsic function. If you assemble a product from
"uncertifiable" components, obviously you are obligated to do complete
compliance testing on the final product yourself because you place
your product on the market.
*All views are my own and not those of my employer*
______________________________________________________________________
Jim Hulbert Tel: 203-924-3621
Senior Engineer - EMC Fax: 203-924-3352
Pitney Bowes email: [email protected]
P.O. Box 3000
35 Waterview Drive
Shelton, CT 06484-8000 U.S.A.
______________________________ Reply Separator _________________________________
Subject: CE Marked Subassemblies & Components
Author: [email protected] at SMTPGWY
List-Post: [email protected]
Date: 6/11/97 9:46 PM
We manufacture application specific subassemblies (keyboards) that are used
on special computer systems, workstations etc. We typically do not place
these goods on the market, as they are designed specifically for a
particular system, and have no intrinsic functions of their own. Sometimes
our customers who are the system integrators will ask for the CE Mark or FCC
certification. We explain that this is really putting the cart before the
horse as the "system" is what must be tested and CE Marked or FCC certified.
I have noticed that desktop computer subassemblies are often CE Marked, even
when the same manufactuerer logo is on the whole system. I would assume that
these subassemblies (i.e. keyboards) can be used with several systems, and
are consequently tested with a few "representative" systems and then marked.
Do the "representative" systems need to be noted on the Declaration of
Conformity? If I test my subassembly with System A and B, can System C claim
they are compliant because they have a similar product and are using my CE
Marked subassembly?
There seems to be the potential for marketing games to be played by
suppliers of components and subassemblies by promoting the CE mark to the
end user (or potential customer), with the promise of "use all CE Marked
parts and your end product will be compliant". If nothing else, it looks
like there may be a lot of redundancy in testing of products.
Darrell Locke
Advanced Input Devices
