If the product you are selling is a component or sub assembly that will be
installed as part of a finished product, then yes you can do what you
purpose. Make sure you document what needs to be done and why.  Most DOCs
have a section labeled "Supplementary Information:". I would place a note in
that section stating that there are conditions for compliance.

If your product is the final product or a consumer product than no. How is
your customer going to install a cap across the AC line in your product?
External assemblies such as shielded I/O cables and such are allowed as long
as they are well documented.  I have seen special line cords with filters
built into the plug, but it had to be made captive to the unit (or part of
the unit) per the VDE (this was many years ago). I don't see how this can be
done though there are many more clever than I. I will be curious to see
others reply.

Brian Kunde
LECO Corp.

-----Original Message-----
From: [email protected] [mailto:[email protected]]On Behalf
Of Russell, Ray
Sent: Friday, March 24, 2000 10:14 AM
To: 'IEEE PSTC'
Subject: EMC - Declaration of Incorporation?



Greetings,

We sell an air compressor with a DC motor. This motor requires a capacitor
across the DC supply lines to meet the EMC requirements. Of course
management does not want to supply the capacitor, they want to describe it
in the documentation, and add a note on the Declaration of Conformity that a
capacitor is required. Is this acceptable for European customers?

In that scenario, I would like to issue a Declaration of Incorporation, but
after reviewing the directives, I can only find a reference to the
Declaration of Incorporation in the Machinery Directive. Can this be used
for the other directives?

Thank you once again for your assistance,


Ray Russell
Regulatory Compliance Engineer


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