I just saw this E-Mail and I have to say I find NO FAULT with this approach. The rules DO allow for limited testing based on sound engineering judgement. However I understand that if limited testing is performed, then you need to get a competent body to agree with you & bingo - you are legal!
So why don't you chat with a few competent bodies and have them sign up to your approach. Chas Grasso >---------- >From: Paul Rampelbergh[SMTP:[email protected]] >Sent: Saturday, February 22, 1997 11:14 AM >To: Eric Lifsey >Cc: Brian Kunde; [email protected] >Subject: Re: Penalty for Non-Compliance > >Hello, > >I put products on the market without performing ALL the required > EMC tests and stick the CE label on it. > > Surprised I tell you that so openly? > >Now this doesn't mean that I do nothing to make the product conform. > >The product is checked by simple measurements means (I don't like > to discus the subject anymore due to the fact that some people spoils, > on purpose, all efforts I made previously to have joined efforts, > opinions, recommendations in a discussions group in this mail list). > >On the other hand, in the design I use as low as possible clock frequency's, > the communication busses are filtered, printed circuit boards layout > has special attention, the line input uses commercial reliable filters, > everything is put in a commercial available specific EMC well designed > metal box, etc.. > >ALL possible precautions are taken and considered to avoid problems > including possible injuries to people, etc.. but NO I do not all > compliance tests to the specified rules. > > I CAN NOT AFFORD IT. > >For INFORMATION: > I was in charge of the flight simulator department of SABENA > airlines (30 years, 40 people: maintenance engineers, 3 commercial > and 2 military simulators and if the project had not collapsed, the > flight simulator of the HERMES European space shuttle for astronaut > training). > Budget and cost of test equipment in front of a flight simulator > with visual and motion system prices (>$15,000,000 each) was > of no concern. > I'm retired now. Things are different. > Now I design and produce small equipment's for handicapped people, > not for profit. > That's it. > Who put the blame on me? I'm a stupid CE sticker man. > >The above expressed is not only my personnal opignion but also that of > my compagny. Regards. > > >Eric Lifsey wrote: >> >> IMO the penalties are far from being an acceptable risk; and they >> vary from country to country, so enforcement is not even. It is >> often the final integrator or customer that ends-up enforcing >> compliance. Sometimes customs gets involved too. >> >> A source within the US delegation to the EU told me (circa mid-1995) >> that a US manufacturer of non-compliant machinery had a shipment >> refused by customs of France, while three other EU countries >> permitted entry of the same product at the same time. There was no >> mention of fines - but having a shipment refused entry/delivery had >> to smart some. >> >> I know of other cases that do not bear repeating here, but suffice it >> to say, enforcement is indeed taking place; although from what I see >> it seems that the enforcement is the result of user or competitor >> compliants instead of random action by the authorities. >> >> Naturally, we're all experts on European Law, right? >> (Wrong. Blatant sarcasm intended.) >> >> Regards, >> Eric Lifsey >> >> >>____________________________________________________________________________ >>___ >> Subject: Penalty for Non-Compliance >> From: "Brian Kunde" <[email protected]> at Internet >> Date: 2/21/97 11:07 AM >> >> I hear a very disturbing subject being openly discussed among several >> of my European contacts. Distributors in Europe are saying that the >> CE marking is a joke. That many companies (European Companies are >> mentioned most often) are simply applying the CE marking to their >> products without testing. Some say that many companies were initially >> forced to do this because of the time and cost of testing and >> redesign, but since there is very little checking going on the risk is >> "Cost Effective". >> >> IS THIS TRUE? >> >> Has anyone heard of specific situations where a company or person has >> been fined or jailed for fraudulently placing the CE marking on >> non-compliant equipment? What is the penalty for non-compliance? What >> is the penalty for fraud? Is anyone checking? Is anyone getting in >> trouble? >> >> I have been asked to obtain strong evidence to counter this opinion. >> More or less to "put the fear of God" into distributors and reassure >> our marketing and sales force that delaying product to market for the >> CE mark is the right thing to do. >> >> Can you help? Please post or email me anything you can. >> >> Thanks, >> >> Brian Kunde >> --------------------------------------------------------------- > >-- >Paul Rampelbergh >Wezembeek-Oppem (Belgium) >------------------------- > >
