I was not aware that Canada had adopted CISPR 22. Can anyone confirm
this, as well as answer Dave's question regarding having to meet
conducted emissions limits starting at 150 KHz? What about a phase-in
period?
Thanks in advance.
______________________________________________________________________
Jim Hulbert Tel: 203-924-3621
Senior Engineer - EMC Fax: 203-924-3352
Pitney Bowes email: hulbe...@pb.com
P.O. Box 3000
35 Waterview Drive
Shelton, CT 06484-8000 U.S.A.
______________________________ Reply Separator _________________________________
Subject: Re: Declarations of Conformity and Markings
Author: <fryd...@norand.com > at SMTPGWY
List-Post: emc-pstc@listserv.ieee.org
Date: 2/13/98 10:43 AM
To: All and
Benoit Nadeau
Several questions are highlighted within the message, most are simple with one
underlying point. What are we as EMC and Safety Approval people to do as more
and more markings are required?
Until a "Global" approval marking system is adopted, each of us have devised a
labeling solution. The development of our individual "system" reflects the
diversity of the our particular equipment we market globally. No one here
apparently has responded because it is a difficult predicament. I myself was
reluctant to respond, as a minor contributor, hoping someone with more
experience would lend some assistance.
Matrox has some concerns that we all must deal with. I will keep my
responses listed "here" above the original message. We at Intermec/Norand do
not have telecom equipment to approve, we install previously approved modems
for each country installation. We do use UHF and spread spectrum transmitters,
each of which require licensing and Country approvals.
(1) FCC approval via DoC does not require a signature. Just a statement as
listed.
(2) Canada ICES-003 for us in the USA is not difficult. As long as the
product complies to CISPR 22 -1993 the ICES statement can be added. At a
recent seminar Brian Kasper of Industry Canada suggested a shortened version
of the ICES statement is allowed. Our interpretation follows;
Canada: ICES-003, Class (*) *= A or B as appropriate
**Question; Since Canada has adopted CISPR 22, must all products meet the
conducted emissions requirements from 150 kHz to 30 MHz or does Canada accept
conducted emissions to the FCC band, 450 kHZ to 30 MHz?
(3) The signatured copy from our perspective must be held by a European
representative. The declarations we send with each product do not have the
signature but have the statement "Signature copy on file". If there is a
National Requirement for the signature, I believe by having one available by
your EU representative will suffice.
(4) New Zealand response from Andrew Dyke <andrew.d...@moc.govt.nz> New
Zealand Regulatory Ministry. Our EMC regime is in a transition mode at
present, with the labeling scheme set out in DP10 (C-tick marking) not taking
effect until 1 January 1999. Currently the process is, test the product to the
appropriate CISPR standard, have the supplier complete a declaration of
conformity (there is a form on our website)[use the Austel.com site for links]
and send the declaration to me for registering. A declaration fee of
NZ$170.65 is payable either by international bank cheque with the declaration,
or we can send an invoice. The declaration may be faxed.
(5) I have no expertise on Japan requirements. We currently have our products
tested and certified by a lab in Japan. Obviously since our products comply
to CISPR 22 Class B, Japan has little difficulty accepting them. The MRA with
Japan should reduce some of the market roadblocks.
(6) Korea has required "In Country" testing of our products. Hopefully with
the Asian Pacific Economic Cooperation MRA that Korea will recognize testing
by accredited laboratories. Until the MRA includes Korea, do as you must do.
(7) Apparently you have an path for marketing, good luck.
Government protection for electrical safety and communications world wide has
all "Global Marketers" scrambling to keep abreast of current requirements.
The EMC-PSTC group here is a valuable asset, lets keep helping each other when
we can. Until the governments worldwide adopt the "One Test, One Marking"
approval process, we all will be checking daily for new developments for
regulatory requirements...
Dave Fry, Sr. EMC Specialist
Intermec Technologies Corporation
Norand Mobile Systems Division
EMC Test Laboratory
(formally the Norand EMC Test Laboratory, Norand Corp.)
(319)846-2415 Fax (319)846-2475 Internet: fryd...@norand.com
______________________________ Reply Separator
_________________________________
Subject: Declarations of Conformity and Markings
Author: Benoit Nadeau <bnad...@matrox.com> at smtpgate
Date: 1/23/98 2:36 PM
Bonjour de Montr e'al,
Matrox is building computer graphics and communications boards. In our
efforts to meet every market place demands, we are presently looking at
the issuing of Declarations of Conformities and markings of our products.
This effort lead to questions for which I have to find answers. I already
have some ideas of the response but I would like to discuss for matters
with our group. Anyone have similar problems could gain or shared its way
of doing things.
1) FCC (USA)
-Class B DOC Procedure
In that case it is quite clear that at least the new FCC logo, trade
name and model should appear on the product. The question is the DOC must
be supplied with every product either on a sheet or in the manual
(preferably). This DOC must have the name of the responsible and a phone
number but does it have to be actually signed (bear a signature) ? I look
in Part 2 and Part 15 of the FCC Regulation and seen no specific demand
for a signature.
2) Industry Canada (Canada)
Before 1995, the Canadian Government did accept the FCC statement for
product entering Canada. But since then, they require a separate
statement. There is a suggested text in the regulation but I've seen
shorter version of this like : <italic>Complies with Canadian ICES-003
Class {*}</italic>. But most of the product I see around do not have this
statement on the product. How do foreign company treat the Canadian
market access ?
3) CE mark (European Countries)
The CE mark clearly has to be on the product. On the other hand the DOC
is not required to be supplied with every product but has to be in every
selling points within the European Market. In the CE Directive, there is
no requirement for this declaration to be signed but it seems that
National regulations requires this signature. Do you have any reference
to this requirement ?
4) C-TICK Mark (Australia/New-Zealand)
The Down-Under market has also is own set of requirements where their
special logo (C-TICK) must be on the product. However in that case, the
importer or local representative must be identified by a special code
next to the mark. Also, the original DOC and Compliance Reports must also
be hold by this representative. No need to supply this declaration with
every product.
5) VCCI (Japan)
For VCCI aligned its technical requirements to those of Europe last year
(10 meters measurements, CISPR22 type, Class A and B). For Class B the
equipment must bear the VCCI logo. For Class A, it is more complicated, a
very long Japanese text has to be on the product (or a tag attached to
the product). How do other Class A PC Card manufacturers deals with this
?
6) Korea
The Pacific countries are joining into the dance and Korea has, for
what I know, the more stringent regulation. Not only they require the
product to be tested by a Korean recognized test lab, but they require a
test by year by product. They also have a special BIG logo that has be on
the product.
7) Ta i:wan and Russia
These two last players are beginning to make wave. Luckily Ta i:wan signed
an agreement with A2LA (our EMC lab Accreditor) which will possibly ease
certification for this market. They do not seem to ask for a special logo
and the control is done with the borders incoming papers. For Russia, I
only have partial informations,
As one can see it is becoming quite complicated ( we even thought of
wrapping our board with the numerous declarations and notes to we have to
supply). I can not imagine when Singapore, Hong-Kong/China, Central and
South-American countries and, why not, African countries will start to
join the party.
Have a nice day anyway....
--------------------------------------------------------------------------
Benoit Nadeau, ing. M.ing. (P.eng., M.eng)
Gerant du Groupe Conformite (Conformity Group Manager)
Matrox <<http://www.matrox.com/>
--------------------------------------------------------------------------
1055, boul. St-Regis
Dorval (Quebec) Canada
H9P 2T4
Tel : (514) 969-6000 (x2475)
FAX : (514) 969-6275
Internet : bnad...@matrox.com, <<mailto:bnad...@matrox.com>
