Craig, here is my opinion. Your equipment does fall into the scope of the
two standards. The exemptions are not listed in the scope. Compliance is
mandatory for devices listed in the scope, but some devices are exempt from
testing as noted elsewhere in the standards. Therefore, if your equipment is
covered by the scope, you must list the standards on your DOC even if you
are exempted from testing. 

Richard Woods

----------
From:  Craig Hensley [SMTP:[email protected]]
Sent:  Wednesday, January 03, 2001 12:50 PM
To:  [email protected]
Cc:  Craig Hensley
Subject:  EN61000-3-2 / EN61000-3-3 (Again)


This is probably a gross over-simplification, but I want to make sure I
understand the applicability of the new EN61000-3-2 (harmonic) and
EN61000-3-3 (flicker) standards.

In reviewing the standards as well as previous communications within this
group I have arrived at the following conclusions.

EN61000-3-2 - Applies only to products with input power higher than 75W.
Per paragraph 7.4 of the standard, "no limits apply for equipment with an
active input power up to and including 75W".

EN61000-3-3 - Per paragraph 6.1 of the standard, "Tests shall not be made on
equipment which is unlikely to produce significant voltage fluctuations or
flicker".  

Per an earlier e-mail from Gert Gremmen "unlikely" means that the equipment
has no variations in power supply current, or variations that cause voltage
fluctuations below the most stringent level in the standard.  In general: -
Equipment with a power consumption below 100 VA max is unlikely to create
flicker problems, and, - Most equipment under 500VA will not create flicker
problems.

You could actually do a simple check the 230V mains side to see if the
product causes dips or fluctuations.  If there are no dips there is no need
to measure.

If a product does not fall under the applicability of EN61000-3-2 or
EN61000-3-3 per the above explanations, what is the consensus regarding
referencing these standards on the DoC?  Based on some earlier e-mails, it
appears that a few of you are going to add these to the DoC.  This should
take away questions that may arise with DoC's that do not contain these
standards.  Based on this approach, couldn't you also reference other
non-applicable harmonized standards?  

Recently I have been asked to sign a document from one of our distributors
that states all product provided after 01/01/01 will comply with EN61000-3-2
and EN61000-3-3.  However, my products fall outside the scope of these
standards (per above explanations), so what I am wondering is can I say I
comply because I have evaluated the standards and found they are not
applicable.  I face the same dilemma on the DoC's.  Is it reasonable to
claim compliance via non-applicability?

I apologize for the conversational tone of this e-mail, but I am interested
in any other views and opinions.  

Best Regards for 2001,
Craig Hensley
Iomega Corp.
Roy, UT




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