In short: The update guide as referred to by Canio says:
6.4.2 Customer buys several apparatuses in one box that are ce-marked, do
not ce mark the system, but include installation instructions.
6.4.2.1 You assemble several ce-marked apparatuses, and you are not sure !
Criterion: the foreseen EMC environment may not fit the
individual
component's.
if they do: ce+ce=ce (for EMC only, not for LVD !!!!!!!!!)
Conclusion : verify the standards and conditions your used apparatuses
comply with
Do not combine Class A and Class B ITE. Some standards have up to 5
environmental
classes. Sub apparatuses may use an ISM frequency not allowed for the ITE
characteristics of the combination you make etc. etc.
The difference is very subtle.
Regards,
Gert Gremmen, (Ing)
ce-test, qualified testing
===============================================
Web presence http://www.cetest.nl
CE-shop http://www.cetest.nl/ce_shop.htm
/-/ Compliance testing is our core business /-/
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>>-----Original Message-----
>>From: [email protected] [mailto:[email protected]]On Behalf
>>Of [email protected]
>>Sent: Monday, March 27, 2000 5:51 PM
>>To: Canio Dichirico; [email protected]
>>Subject: Re: Is the "modular approach to EMC" the same as CE + CE = CE?
>>
>>
>>
>>
>>Here is my understanding of the approach to systems compliance
>>for CE marking.
>>If all parts of the system are CE marked you are not (legally) required to
>>re-test the system for compliance to the EMC Directive, provided
>>you give clear
>>instructions for assembly/installation/operation/maintenance in
>>the instructions
>>for use ("installation guidelines"). The Declaration of
>>Conformity , as well as
>>the instructions for use, must refer to the system as a whole. My
>>understanding
>>of the "modular approach" is that if all parts are CE-marked you are not
>>required to put the CE mark on the system as a whole. This is the
>>legal aspect.
>>On the other end, I fully agree that CE + CE = CE is far from
>>sure until you
>>have tested the whole system for compliance ! There is a clear
>>statement on this
>>in the "Guide to the Application of Directive 89/336/EEC" published by the
>>European Commission (1997). In sec. 6.4.2.1 (System assembled from only CE
>>marked apparatus) there is a paragraph titled "Additional comment":
>>"... combining two or more CE-marked subassemblies may not
>>automatically produce
>>a system which meets the requirements of the relevant standard."
>>I fully agree with this statement, since the
>>wirings/packaging/grounding/shielding aspects of any assembly process can
>>determine the EMC behavior of the complete system.
>>So my conclusion is: the safest way is to test the system as a
>>whole, because in
>>any case (whether you choose to follow the modular approach or not) the
>>Declaration of Conformity refers to the whole system and manufacturer is
>>responsible for compliance.
>>
>>Hope this helps.
>>
>>Best Regards,
>>
>>Paolo Roncone
>>Compuprint - Italy
>>
>>
>>
>>
>>
>>
>>"Canio Dichirico" <[email protected]> on 27/03/2000 14.30.50
>>
>>Please respond to "Canio Dichirico" <[email protected]>
>>
>>
>>
>> To: "IEEE EMC List" <[email protected]>
>>
>> cc: (bcc: Paolo Roncone/IT/BULL)
>>
>>
>>
>> Subject: Is the "modular approach to EMC" the same as CE +
>> CE = CE?
>>
>>
>>
>>
>>
>>
>>
>>
<<attachment: Gert Gremmen.vcf>>
