To whom it may concern, 

Sorry, rather lengthy.  I tried to cut it down. 

I've finally realized I don't think I fully understand 
European approvals and I'll discuss why with two examples. 
The first example will go from the *system level* down 
to the *sub-system level*.  The second example will go 
from the *system level* up to a *super-system level*. 

In other words, I don't think I fully understand how 
the stateside concept of "component approval" versus 
"listed" gets translated over into the CE mark, or 
VCCI, or BCIQ for that matter ...  I believe this was 
touched on a while back but I can't find it. 

System Configuration - 

 Let's say we have product.  It's *model number* is System 1. 
 System 1 is composed of two sub-systems. 
 Sub-systems have in turn the *model numbers* Sub-system A 
 and Sub-system B. 
 System 1 has a mains input of 115/230vac to a 
 power distribution unit (PDU).  
 The PDU inputs the 115/230vac to a power supply. 
 The power supply outputs 48vdc to sub-systems A and B. 
 System 1 is NOT a telco product. 

 -------------------- 

First - System to sub-system: 

 System 1 has been successfully tested to the appropriate 
 emissions, safety, and immunity requirements.  It is 
 declared that System 1 complies to have the CE mark applied.  
 System 1 is marketed.  It is shipped overseas to our friends 
 in Europe.  No problems. 

 Now, marketing comes along and wants to sell Sub-systems 
 A and B of System 1 on their own.  In other words, the 
 Sub-systems A and B will NOT necessarily be in  configurations 
 that will use anything from the original configuration of 
 System 1.  And they will be advertised and sold as 
 Sub-system A and Sub-system B. 
 
 Question:  Is any retest of the sub-systems by themselves required? 
            If so, why so? 
            If not, why not? 

 -------------------- 

Second - System to Super-system: 

 Marketing decides to incorporate two or more System 1's into a 
 configuration using a product, let's call that Product A, from 
 another company that itself has been through all required emissions, 
 safety, and immunity requirements and is itself CE marked. And has 
 also been marketed and sold in Europe with no problems. 

 *** Marketing also decides to advertise and sell this 
 super-system under a new *model number* Super-system 2.  
 There is a high amount of confidence that this entire system 
 Super-system 2 will never be shipped as one piece.  The Bill 
 of Lading that would come through Customs though would show 
 Super-system 2 with parts System 1 and Product A. 

 Question:  Is any retest of Super-system 2 required? 
            If so, why so? 
            If not, why not? 

 -------------------- 



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