Gary, I didn't want to suggest that you can get Korean EMC certification with an EMC report from a local US lab. I was trying to say that to get a IEC60950 CB report with the Korean deviations does not require the EMC report to be from a Korean lab. I would venture a guess that those folks in Korea that are reviewing a CB report for safety have no interest in the EMC report other than is it there.
The only issue I have successfully argued is when requested for complete schematics and BOMs for power supplies. Typically they request everything and the power supply manufacturers I have dealt with are very reluctant to provide that info. Since the power supply CB contains the info on critical components and the schematics of barrier sections of the power supply I have been able to get them to accept that info only. When I have sent over a product for MIC certification I typically send a doc package that includes the safety reports, our EMC reports and the ETSI and Part 68 telco reports. I do not know how much testing they actually do but I do typically get my certification in 3 weeks. Dave Clement Motorola Inc. Test Lab Services Homologation Engineering 20 Cabot Blvd. Mansfield, MA 02048 P:508-851-8259 F:508-851-8512 C:508-725-9689 mailto:[email protected] http://www.motorola.com/globalcompliance/ -----Original Message----- From: Gary McInturff [mailto:[email protected]] Sent: Thursday, August 08, 2002 6:17 PM To: Clement Dave-LDC009; EMC-PSTC (E-mail) Subject: RE: Korea Deviation to IEC60950 CB report. Dave, You've got my attention on item 4, but still confused. Agreed there is no requirement for a Korean lab in the CB report, but as you also point out it has nothing to do with meeting the Korean national requirements. So it seems we agree that this can't be the full path to conformance from a Korean perspective. The issue now seems to be whether or not a non-Korean lab can provide data satisfactory to the Koreans. With every regulation and test house that I come into contact with the word has always come back the same. Korea wants a Korean lab, and about the only exception I can think of is KTL in Ottawa and I made them show me the documents that allow them to do so. They have had for a while the ability to do the radiated portion, but they did not until very recently have the same ability for the immunity requirements. The net effect was that the equipment still needed to be shipped to Korea. My prime vendor for this would love to be able to provide that service but after much checking into the regulations on his part, including direct query with the Korean the best he could offer was to do the project management for it, ship the product, pay the fees, and act as an intermediary. As you can imagine he and I occasionally may have discussions about interpretations of the regulations etc, but I have a very high regard for his ability to either provide sound factual information or in this case, research it and respond. (Don't tell him this part he'll just raise my rates :) ) The same data came from other vendors as well. Now this is for ITE, buy the way, I do believe that for telecom stuff Korea has signed the MRA's both government to government and industry specific. Obviously it is pretty hard to argue with success so if you are telling me that you can go to your local EMC NIST approved lab with ITE equipment, get the test done locally and submit only the test report I am all ears. We aren't able to send folks to the various governmental symposiums so I do rely on knowledgeable vendors, but would be happy to hear the information is wrong. I suspect my main vendor would love to hear it as well. Taiwan requires test reports, but that data can come from US Labs. Are you sure you are not confusing the two. Gary -----Original Message----- From: Clement Dave-LDC009 [mailto:[email protected]] Sent: Thursday, August 08, 2002 1:26 PM To: EMC-PSTC (E-mail) Subject: RE: Korea Deviation to IEC60950 CB report. Seems strange that the IECEE allowed an EMC requirement to be added as a national deviation to a Safety Standard, but they did, and it's even more bizarre that Japan has the same deviation and has no national mandatory EMC requirement. But anyway; There is no requirement that to meet the requirements for the Korean deviation in a CB report that the EMC report must come from a Korean lab. Also, having a CB safety report that shows the EMC deviation as passing has nothing to do with meeting the Korean national requirements for EMC. So in actuality there is a 4th option. 4- Have an EMC report from any recognized lab - Pass I routinely obtain CB reports from UL, CSA or TUV that meet this requirement with a CISPR test report from our OATS. Dave Clement Motorola Inc. Test Lab Services Homologation Engineering 20 Cabot Blvd. Mansfield, MA 02048 P:508-851-8259 F:508-851-8512 C:508-725-9689 mailto:[email protected] http://www.motorola.com/globalcompliance/ -----Original Message----- From: Gary McInturff [mailto:[email protected]] Sent: Thursday, August 08, 2002 12:52 PM To: EMC-PSTC (E-mail) Subject: Korea Deviation to IEC60950 CB report. Korea - Differences to IEC60950, Third Edition (1999) 7 Addition: EMC. The apparatus shall complies with the relevant CISPR requirements As I understand it there are three options for this deviation. 1 - Have a Korean Test Report - Pass 2 - Don't have a report - Fail 3- Write a letter to the CB author stating you meet the requirements - pass Seems to be a particularly interesting case of circular reasoning going on here. Korea requires test data from a Korean approved lab to be submitted to them for EMC approval. Basic property of approval is that one meets the EMC requirements as demonstrated by a test report from a Korean authorized laboratory and also meets the Safety requirements as documented in a CB report. Most often these documents are obtained from different companies, but all nicely bound in one documentation bundle by the manufacturer when they submit for Korean acceptance. Assume one has Korea as a market then this section in the CB report makes no sense. For the first option Korea already requires that one verifies emissions with a test report from a Korean approved laboratory and presumably they read it or at least check it off their bureaucracy forms when it arrives. The equipment still can' t be imported until they see a CB report they accept. If they have the emissions report and the CB report in front of them then the first condition of this requiring the safety evaluator to confirm that they also have a copy of this report is non-sensical. In fact I suspect that as proof they have done their job the safety evaluator would include as an appendix a copy of the emissions report. So know the Korean officials have two copies of the same report. For option 2, Either one doesn't have Korea as a market and is not interested in meeting any of their deviations so the clause isn't needed, or they are interested, have the report, and send it to CB author. So now we are back to circular reasoning item 1. Option 3 may be my favorite. They authorize only a few labs to submit data. The only reason to require a Korean certified lab test is that they don't trust manufactures when they simply tell them the requirements are met. On Its own that is not an unreasonable request, independent verification of test results is always better than just trusting the manufacturer. But now in the CB report, that as I noted before either provides a copy of the emissions report as an annex or amendment to the CB report because of circular reasoning item 1 or Circular reasoning item 2 comes into play, and defaults to item 1. But if either of those two useless clauses isn't enough now there is a third option. Just write a letter that says trust us. It will be included in the CB report as an appendix or an annex. Of course this letter doesn't make any sense either because they require along with the CB report, a test report from a previously Korean approved lab. This requirement is because they ! obviously don't trust a manufacturer to just say they meet the requirements. And back to useless option 1. What am I missing here? Seems like its time to break out the old Fecalencephalometer ( a large painful instrument intended to measure just how far your head is up your rear end! ------------------------------------------- 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"
