>From the EMC directive's point of view I htink you are dealing with a
"System", and therefore have to CE-mark the equipment according to the EMC
directive. See more about the definintions of "system" and "installation" in
the Guidelines to the EMC directive
(http://europa.eu.int/comm/dg03/publicat/guides/emcgen.pdf), see point 6.4
about systems and point 6.5 about installations.
On the other hand it seems to me that you too are dealing with an equipment
built for the company's internal use. This is still valid as long as the
different manufacturing facilities are within the same company.
About such equipment John Barnes/Lexmark International about a week ago
wrote quite good:
"About a week ago one of the participants on this mailing
list asked whether equipment built in-house, for a company's internal use,
had to be safety and electromagnetic compatibility (EMC) tested.
I just started reading Tim Williams' book "EMC for Product
Designers" (second edition) this morning, and on page 15 came across the
following statement under Scope, requirements, and exceptions for EMC
Directive 89/336/EEC:
Taken into service
"Taking into service" means the first use of a product
in the EU by its final user.
If the product is used without being placed on the
market, if for example the
manufacturer is also the end user, then the protective
requirements of the Directive still
apply.
This means that sanctions are still available in
each member state to prevent
the product from being used if it does not comply with
the essential requirements or if it
causes an actual or potential interference problem.
On the other hand, it should not need
to go through the conformity assessment procedures to
demonstrate compliance (article 10,
which describes these procedures, makes no mention of
taking into service).
Thus an item of special test gear built up by a lab
technician for use within the campany's
design department must still be designed and installed
so as not to cause or suffer
from interference, but should not need to follow the
procedure for aplying the CE
mark.
John Barnes Advisory Engineer
Lexmark International"
Venlig hilsen / Best regards
Niels Hougaard
EMC Engineer, B.Sc.E.E.
BARCO Communication Systems - Denmark
Emdrupvej 26
DK - 2100 Copenhagen
Denmark
Telephone + 45 39 17 00 00
Direct + 45 39 17 08 15
Fax + 45 39 17 00 10
E-mail [email protected]
Web www.barco.com
-----Original Message-----
From: [email protected] [mailto:[email protected]]
Sent: Tuesday, August 24, 1999 5:56 AM
To: [email protected]
Subject: Fixed Installation
I have questions concerning a manufacturing system. The system comprises of
about a dozen pieces of integrated equipment that take up about 12 x 6 x 6
meters and it has a total continuous current draw of 250 kilowatts (408,
3-phase). The equipment will not be sold and only used internally within
the same company that is the manufacturer. It is the first of a very
limited number of systems (roughly 5). My first impression is that this
system can be considered a "fixed installation" under the EMC Directive and
therefore is exempt from the EMC Directive (at least that's my
interpretation of section 6.5 of the Guidelines on the EMC Directive).
However, after a year or so, the system may be torn down, shipped to a
different manufacturing facility within the same company and reassembled.
First of all, am I correct in considering this a fixed installation? And
does it remain a fixed installation even if it is moved?
Does it fall under the EMC Directive? Does it require a TCF?
Or should I only be concerned with emission levels "in situ"?
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