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?
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: [email protected] website: www.eso.org
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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 |
