In a message dated 29/09/00 15:43:06 GMT Daylight Time, [email protected]
writes:
<< I'm just getting started in the world of EMI and would like to ask a few
questions. I'm not sure if I should be going the TCF route or the Standards
Route. The company that I work for manufactures products which have many
variants.
1) Is it EC law that a manufacturer must perform EMI testing before
applying the CE mark?
No. In the UK, the Electromagnetic Compatibility Regulations don't require
testing if you follow the Standards Route. But you must make the Declaration
of Compliance before you use the CE mark and be able to provide evidence of
compliance to the regulatory authorities when challenged. This can be test
results, or detailed analysis, or statements etc. Again, 'testing' per se is
not a particular requirement. For instance, a simple resistive convection
heater could be stated to Comply because there are no non-linear elements to
produce or be affected by EMI. No need to test. Having said that, testing
is the only absolutely certain way of proving compliance. And don't forget
that the Regulations are Criminal Law!
2) If a manufacturer follows the Standards Route, does EC law require each
variant to be tested?
No. There is nio statutory need to test. But you need to provide firm
evidence, when asked, that the variant is not significantly different in EMC
terms to the original subject of the Compliance Declaration. A detailed
technical statement would suffice, but must be accurate and traceable.
Again, we are taking Criminal Law here!
3) If, when testing, the limit is exceeded, can the CE mark still be
applied?
No. The CE mark means that ALL relevant Directives have been complied with.
If EMC limits are exceeded when using the Standards Route then it doesn't
comply with the EMC Directive. If the product can't be produced without
exceeding the limits, then the TCF route to compliance should be used.
4) Are the services of a Competent Body required in order to put together a
TCF or can the manufacturer do that on his own?
A TCF is only valid when qualified by a Competent Body. A manufacturer can
build his own TCF, or an external Test House/Competent Body can build it, but
at the end of the day the Competent Body signs/takes responsibility for it.
Think of a TCF as a new EMC standard which relates ONLY to that particular
product. A simple rule is 'if it complies with the Standards then use the
Standards Route, if it doesn't then use the TCF route.
Hope is useful.
Chris Dupres
Surrey, UK.
>>
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