While it seems simple enough, the product is more than just a component. It can be considered an apparatus by EU standards because it has an intrinsic function. If the pump was restricted to a specific application, and would not work without it, you might get away without testing it. Because that is not the case, and they seem to have general purpose uses, then CE marking is appropriate if you sell into the EU. If you only sell to people (in the US) who incorporate the pumps into products which THEY sell in Europe, then any requirement for testing/marking is contractual, not regulatory.
As for the problems experienced with previous testing, you should, in fact operate the motor with a battery. If the power supply was the source of the problems you had, they should go away. With regard to testing the new vendor, you are obligated to demonstrate compliance of the new motor. If you did not already follow the TCF route, it may be appropriate for you to consider it for these pumps. In that way, you may be able to do abbreviated tests when designs (or vendors) change. (TCFs do, however, generally have higher initial cost) Likewise, you may be able to do reduced tests if you add new products. Bob Martin ITS- Northeast [email protected] The opinions expressed are my own and not necessarily those of my employer. ---------- From: Russell, Ray To: 'IEEE PSTC' Subject: EMC Directive and Small DC motors List-Post: [email protected] Date: Tuesday, April 07, 1998 1:50PM Greetings, We manufacturer a small line of vacuum pumps that use very small (1/16 hp) 12, 6 and 4 VDC motors. Just a DC motor and a pump. We have had some EMC testing performed to the EN 55014 and EN 55104 standards where there was some high conducted emissions that required a .1 uf capacitor across the positive and negative terminals. But I believe this is more of an issue of the power supply source, and lead lengths than the motor. These items are considered components because they need a power supply to operate. However, they could use battery power, but I assume that there would not be an emission problem in this mode. We now have another source for motors, and I have been asked to retest. I am very reluctant to spend thousands of dollars on testing, when I personally do not understand the benefit or risk. Of course the test house highly recommends additional testing. So I come seeking some advice or alternatives. Here are some of my thoughts: Since this is a component, could we just assign a declaration of incorporation? Are there any reasonable limits to what should be tested, as far as power/frequency/application in the directives? Is there a justifiable reason to test this product? Thank you for your consideration, any thoughts would be appreciated. Ray Russell [email protected]
