I assume that you already did this, but your email didn't explicitly say so. Did you ask "D's" manufacturer HOW they test it? You may be surprised. I have knocked myself out trying to get a product to pass testing with an operating Ethernet port; only to find out that our OEM manufacturer tested the port with a one meter dummy cable and no traffic. However, at least they were good enough to show me their complete test report so that I could at least replicate what they did.
Chris Maxwell | Design Engineer - Optical Division email [email protected] | dir +1 315 266 5128 | fax +1 315 797 8024 NetTest | 6 Rhoads Drive, Utica, NY 13502 | USA web www.nettest.com | tel +1 315 797 4449 | > -----Original Message----- > From: [email protected] [SMTP:[email protected]] > Sent: Friday, November 22, 2002 12:29 PM > To: [email protected] > Subject: ReIssue: RE: When CE doesn't pass > > > Thanks to everyone who responded to my earlier email. After reading the > replies, I wanted to rephrase and clarify our situation to see if it matters. > > We design, manufacture, and market stand-a-lone Product A. But some of our > customers want a complete turn-key system. So we purchase and re-sell > Products > B, C, and D. Each are individually marketed by their manufacturer and has the > CE > marking. We sell and setup this turn-key system for our customers. This > might > be seen as CE+CE+CE+CE should equal CE. > > Our company always wants to do what's right, so we test this turn-key system > for > CE. During the EMC testing, Product D causes the system to fail. Additional > investigation finds that Product D fails all by itself, independent of the > rest > of the system. When the manufacturer of Product D is contacted, they reply > with, "it passes when we test it". Another problem is that we do not have > enough buying power to force them to look into the problem and threatening > them > with turning them in won't help us ship product. > > Is there any train of thought, loophole, or documentation trail that will > allow > us to market and sell this turn-key system? How do we become liable for a CE > labeled product that someone else's makes? I know we don't want to sell a > non-compliant system, but what are we to do? > > Some suggest fixing the product yourself. If it can't be done externally, as > soon as we open up the unit don't we become responsible for it including > safety? I don't think we want to do that. > > Thanks to all again, > Brian Kunde > LECO > > > > > > > ____________________Reply Separator____________________ > Subject: RE: When CE doesn't pass > Author: [email protected] > Date: 11/22/02 4:25 AM > > No, you can't. If you are placing the system on the market as a single > commercial unit then you must issue a Declaration of Conformity for the > system. However, if you place the system on the market without the > peripheral then you could claim conformity for that system as a unit. If you > also sold the peripheral, acting purely as a distributor for the > manufacturer of the peripheral, then the legal responsibility for that > peripheral would lie with the other manufacturer. However, do you really > want your system to be associated with a non-compliant product? Personally, > I would inform the manufacturer of the peripheral of the problem and look > elsewhere for an alternative unless he took action to make it compliant. > To relate this to another thread that is running at present, this is a prime > example of CE + CE does NOT make CE! > > Best regards, > > Neil R. Barker > Compliance Engineering Manager > E2V Technologies > Waterhouse Lane > Chelmsford > Essex > CM1 2QU > U.K. > > Tel: +44 (01245) 453616 > Fax: +44 (01245) 453410 > E-mail: [email protected] > > > > -----Original Message----- > > From: [email protected] [mailto:[email protected]]> > > Sent: 21 November 2002 19:41 > > To: [email protected] > > Subject: When CE doesn't pass > > > > > Has this ever happened to you? > > > We manufacture analysis instrumentation equipment. The part > we make is > > > usually > > part of a complex system made up of other CE marked equipment > from many > > different suppliers. Sometimes when we have a system tested > for CE > > (emissions > > and immunity), one of the other companies pieces of equipment > will cause > > the > > "system" to fail. > > I have seen some test labs identify the failing > > piece of > equipment, write it up > > in the report and say it is not our problem because our > equipment passes > > AND it > > is not contributing to the failure. But, what if we are > selling the > > "system" > > including the CE Marked products that failed when we had it tested? > > > It doesn't always do us much good to go to the manufacturer > of the > > > failing > > equipment because they will usually say that it passes when > they tests > > it. If > > we were a PC manufacturer and had trouble with a printer or a > monitor we > > could > > just find another one, but the equipment in our systems are > more unique. > > There > > may only be 1 or 2 manufacturers of such a device and we > don't have much > > of a > > choice. > > > So here is my question. Can we sell a "system" that includes > a CE > > > marked > > peripheral that we have no design control over, that fails > when WE have it > > tested? > > > Please advise and Thank you in advance. > > Brian Kunde > > LECO Corp. > > > > > > > > ------------------------------------------- > > This message is from the IEEE EMC Society Product Safety > > Technical Committee emc-pstc discussion list. > > > Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ > > > To cancel your subscription, send mail to: > > [email protected] > > with the single line: > > unsubscribe emc-pstc > > > For help, send mail to the list administrators: > > Ron Pickard: [email protected] > > Dave Heald: [email protected] > > > For policy questions, send mail to: > > Richard Nute: [email protected] > > Jim Bacher: [email protected] > > > All emc-pstc postings are archived and searchable on the web at: > > http://ieeepstc.mindcruiser.com/ > > Click on "browse" and then "emc-pstc mailing list" > > > > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ > > To cancel your subscription, send mail to: > [email protected] > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Ron Pickard: [email protected] > Dave Heald: [email protected] > > For policy questions, send mail to: > Richard Nute: [email protected] > Jim Bacher: [email protected] > > All emc-pstc postings are archived and searchable on the web at: > http://ieeepstc.mindcruiser.com/ > Click on "browse" and then "emc-pstc mailing list" ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
