Moshe,
Here is another thread from 1 ½ years ago.
Jim Knighten
NCR
--------------------------------------------------------------
Dear Richard
The Self-Declaration Route to Conformity under the EU's EMC Directive
requires the manufacturer to create and sign a Declaration of Conformity
which states that the product meets the Protection Requirements of the EMC
Directive, and which also lists the harmonised EMC standards that he has
applied.
Now, there is NO LEGAL REQUIREMENT TO ACTUALLY HAVE PERFORMED ANY EMC
TESTING to the listed standards, but there is a legal requirement to be able
to show "due diligence" (as this is experessed in the UK's EMC Regulations
which implement the Directive)in meeting the Directive.
At a recent meeting of the UK's EMC Test Lab's Association it proved
impossible to get a consensus on self-declaration (sometimes called
self-certification) other than that it means the manufacturer is really
saying: "if you test my products to these standards they will pass it".
But even this is not quite right, as it is possible to "apply" a standard
without actually passing all its tests. The EMC Enforcement in the UK make
the point quite clearly: they say (based on UK Case Law) that it is possible
to meet the standards and fail the Directive, or to fail the standards and
meet the Directive.
Obviously, a responsible manufacturer who wants to reduce the business risks
of having his product barred from the entire EU will take whatever steps are
needed, which will usually involve EMC testing and record-keeping, but which
EMC phenonema to test for, how much testing to do, who to have do the
testing and whether they should be accredited, and what reports to
keep......... are all entirely up to the manufacturer, who has to make a
business risk versus cost decision.
Most managers can see the costs but have no inkling of the business risks,
and so some are living more dangerously than they know. Some EU countries
require automatic mandatory product recalls for goods found to be
non-EMC-compliant!
On the other hand there are alot of companies who are spending more on
testing than they need to for the level of risk they want, and they could be
at a competitive disadvantage compared to companies who understand the EMC
Directive better.
Refer to the EU's 1997 EMC Guidelines, and/or to UK Trading Standards EMC
Specialists for confirmation of this, which knowledgeable test lab managers
will confirm if you press them hard enough.
Don't forget the EU also require manufacturers to be able to show that they
are using due diligence in ensuring that products in serial production
continue to comply, this usually requires some sort of sampling plan, unless
the design is so good that its EMC performance cannot possibly vary
(unlikely).
Also, please take care not to mix FCC and EU EMC requirements, they have a
different legal basis.
Hope this helps!
Keith Armstrong
Partner, Cherry Clough Consultants
Phone +44 (0)1457 871 605
Fax: +44 (0)1457 820 145
WOODS, RICHARD wrote:
>
> > A couple of months ago, there was a discussion in this
forum about how to
> > test for EU conducted emssions and immunity on a 24 Vac
CCTV camera. The
> > consensus was that the the manufacturer was required to
perform the tests
> > before he could issue a Declaration of Conformity. This
problem has come
> > back to haunt me. I have been asked to cite the
sections of the standards
> > that support this position. My citations are listed
below. Your comments
> > would be appreciated.
> >
> > CONDUCTED EMISSIONS TESTING
> >
> > Based upon the following citations, it is clear that the
FCC rules for
> > digital devices requires that an EUT operating from the
AC mains via an AC
> > adapter or similar power source be tested for conducted
emissions.
> >
> > Part 15.107(f) of the FCC rules states,
> >
> > Measurements to demonstrate compliance with the
conducted limits are
> > not required for devices which only employ battery power
for operation and
> > which do not operate from the AC power lines or contain
provisions for
> > operation while connected to the AC power lines. Devices
that include, or
> > make provision for, the use of battery chargers which
permit operating
> > while charging, AC adapters or battery eliminators or
that connect to the
> > AC power lines indirectly, obtaining their power through
another device
> > which is connected to the AC power mains, shall be
tested to demonstrate
> > compliance with the conducted limits.
> >
> > Part 15.31(a)(6) of the FCC rules states,
> >
> > NOTE: Digital devices tested to show compliance
with the provisions
> > of 15.107(e) and 15.109(g) must be tested following the
ANSI C63.4
> > procedure . . .
> >
> > ANSI C63.4-1992 Section 7 states,
> >
> > If the EUT normally receives power from another
device that connects
> > to the public untility ac powerlines, measurements shall
be made on that
> > device with the EUT in operation to ensure that the
device continues to
> > comply with the appropriate limits while providing the
EUT with power. If
> > the EUT is operated only from internal or dedicated
batteries, with no
> > provision for connection to the public utility ac
powerlines (600 Vac or
> > less) to operate the EUT (such as an adapter), ac
powerline conducted
> > measurements are not required.
> >
> > Based upon the following two citations, it is unclear if
or how non-mains
> > power ports are to be tested for CE compliance.
> >
> > EN55022 contains no guidance on the test setup of an EUT
that is not mains
> > operated except that Clause 2 makes a normative
reference to CISPR 16-2:
> > 1987 (methods of measurement).
> >
> > CISPR 16-2 contains no guidance on the test setup of an
EUT that is not
> > mains operated.
> >
> >
> > CONDUCTED IMMUNITY TESTING
> >
> > Based upon the following two citations, it is clear that
fast transient
> > testing is required on AC power ports.
> >
> > EN 50082-1:1992 specifies in Table 4 that the "AC power
ports" shall be
> > subjected to the fast transients tests specified by IEC
801-4:1988.
> >
> > IEC 801-4:1998 specifies in clause 7.2.1 that "The EUT
shall be arranged
> > and connected according to its normal installation
requirements." Clause
> > 7.2.2 specifies that test equipment be coupled directly
to the power
> > supply lines of the EUT. There are no restrictions that
the power ports
> > must be directly connected to the AC mains.
> >
> > Richard Woods
> > Sensormatic Electronics
> > wo...@sensormatic.com <mailto:wo...@sensormatic.com>
> > Views expressed by the author do not necessarily
represent those of
> > Sensormatic.
> >
> >
> >
________________________________________________________
Dr. Jim Knighten e-mail: jim.knigh...@sandiegoca.ncr.com
<mailto:jim.knigh...@sandiego.ncr.com>
Senior Consulting Engineer
NCR
17095 Via del Campo
San Diego, CA 92127 http://www.ncr.com <http://www.ncr.com>
Tel: 858-485-2537
Fax: 858-485-3788
***** Notice the Area Code change from 619 *****
-----Original Message-----
From: mvald...@netvision.net.il [SMTP:mvald...@netvision.net.il]
Sent: Tuesday, July 20, 1999 9:07 PM
To: emc-p...@ieee.org
Subject: CE enforcement
Hello everyone,
I need some "horror stories" on enforcement in Europe (to help
convince some managers we
really have to comply).
Anything new in this area?
thanks in advance,
Moshe
--------------------------------------------
Name: moshe valdman
E-mail: mvald...@netvision.net.il
Phone: 972-54-881334
Telefax: 972-3-5496369
Date: 20/7/99
Time: 21:06:55
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