Very well put, I would have to say. 

Steve Yow

-----Original Message-----
From: geor...@lexmark.com [mailto:geor...@lexmark.com]
Sent: Wednesday, August 22, 2001 8:40 AM
To: emc-p...@ieee.org
Subject: Euro Agency Marks vs. CE Marking

Earlier exchange.....................

> In Europe, there are no longer any 'national approvals' like the old
> SEMKO etc. There is ONLY the Low Voltage Directive, and the European
> Standards (ENs) that have been 'notified' in the Official Journal as
> providing evidence of compliance."
>
>
< Not so, the SEMKO "S" mark along with NEMKO, DEMKO and FIMKO and many
< others (TUV?) is alive and well.  These marks not only demonstrate
< compliance with the LVD and EMCD (if applicable) but also that some
< form of manufacturing quality contol is exercised which is audited by
< the mark's owner.  Critical components will be checked and hi pot
< testing must be performed.

For the European Union, only the CE marking is required, indicating
conformity to all applicable Directives, for ITE this would be the EMC
and LV Directives.  It is correct that this marking is not "issued" by
any test agency, and does not, in itself, stipulate required production
tests.

It is true that all of the former local country approval agencies are
still alive, and attempt to "sell" the importance of their marks to
their country residents as the only "true" sign of safety.  They often
point out, and rightly so, that the CB Scheme does not actually require
the equivalent of a type test to the applicable standard, allowing a
manufacturer to submit a Technical Construction File (TCF) or self-
declaration of conformity, and with little production oversight
required. Due to this and local preferences, many manufacturers still
obtain one of more of these redundant, but traditional, marks.

In some respects, these many test houses contributed to their own demise.
How many "type tests" from multiple agencies does it take to affirm
meeting EN60950?  How many agency inspectors does it take to inspect the
same factory?  When all is said and done, only one type test and one
routine factory follow-up inspection is required to ensure the safety
quality of a product.

The CB Scheme is the common sense approach, but still has a few flaws.
The CB Scheme should include a requirement for one, and only one, agency
factory certification and follow-up inspections.  This would remove the
continuing redundancy of multiple agencies inspecting the same factory
for the same safety related processes.

My opinion...........

George Alspaugh



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