Some food for thought . . . 
 
It can depends what you mean by 'system'. Here's two examples:
1) A system can be a single product (like a PC) that can contain
'components' that are CE compliant (power supply, modem card, motherboard). 
2) Or a system can consist of several products - a workstation, a disk
server,
a printer.
 
In example '1' CE + CE does not necessarily equal CE. When put together the
'system' may radiate. The individual items may have been tested in a certain
configuration which the integrator may not be mimicking. There was an
instance in the UK where a PC manufacturer was fined by Cardiff Trading
Standards (who routinely patrol for EMC Directive - amongst others -
violations). THe
manufacturer of that PC used the CE + CE = CE approach. But when the unit
was actually tested, it failed miserably. 
 
For example '2', you may be able to get away with CE + CE = CE. With this
type of 'system', the 'modules' themselves were
most likely tested in a configuration that the system 'manufacturer'
(integrator) would most likely be assembling. Typically this is what happens
with home PC 'systems'. Those that assemble such a 'system' at home, for
home use don't have to demonstrate compliance.  But then again, the home
user is not bundling the package for resale. In that case I, as a
manufacturer would evaluate the system because it is ultimately my
responsbility in ensuring that MY end product (the bundled 'system' with a
model number that I generated) meets the requirements.
 
 
John Juhasz 
Fiber Options
Bohemia, NY
 

-----Original Message-----
From: Canio Dichirico [mailto:cdich...@eso.org]
Sent: Monday, March 27, 2000 7:31 AM
To: IEEE EMC List
Subject: Is the "modular approach to EMC" the same as CE + CE = CE?


Hi All!
 
The designer/manufacturer of a (prototype) system has recently exposed to me
the following argument. If the system is built out of subsystems that are
CE-marked, the complete system may be considered compliant with the EMC
Directive 89/336/EEC. The designer stated that this is possible on the basis
of the "modular approach to EMC".
 
In order to understand this argument I read the paper "Update on the
European Union's EMC Directive", appeared on the European Edition of
Compliance Engineering - 1999 Annual Reference Guide. In this paper one may
read that "For systems and installations ... either a system or a modular
approach may be used to demonstrate compliance. The TCF [Technical
Construction File] route is thus not required for verifying a system and/or
installation if all subunits and subsystems comply with the EMC requirements
(modular approach), presuming that the referenced standards are relevant for
intended environments and that installation guidelines are followed."
 
Does what I read on Compliance Engineering confirm what declared by the
(prototype) system designer?
 
Which are the "installation guidelines" that the paper quoted above is
referring to? Which are the differences, if any, between the "modular
approach" and the "equation" CE + CE = CE? I remember reading in this forum
(plenty of times) that CE + CE does not necessarily equal CE. 
 
Any replies or comments are welcome.
 
Thank you all in advance!
 
 
Canio Dichirico
European Southern Observatory
Technical Division - Electronic Systems Department
Karl-Schwarzschild-Str. 2
D-85748 Garching bei München
 
Tel. +49-89-3200 6500
Fax +49-89-320 23 62
email: cdich...@eso.org <mailto:cdich...@eso.org> 
website: www.eso.org <http://www.eso.org> 

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