I agree with the common sense approach. Say you make heavy duty reinforced shoes, which you sell to both the Army and the public. For the military market no CE directive applies. For the civilian market they fall under the Personal Protective Equipment Directive and need to be marked accordingly.
Do you just CE mark those Shoes intended for civilian sale and leave the Military ones blank ? Or to save the pain of controlling two stock numbers and having segregated warehouse and production lines, CE mark all the products you make ? The same reasoning could be applied to a manufacture of ruggerdised PCs which could have dual use in both the Civilian and Military sectors. It is easier in the long run to design the product for both markets. On the other hand most military electronics need to meet far higher EMC performance criteria than any EU EMC standard requires. When your 20 foot long pointy missile gets hit by a high power radar array, performance criteria B, momentary loss of function but self recovers, is not quite good enough. Same thing for emissions, you do not want your nice new missiles box of electronic tricks radiating so much that it screws up all other systems in the vicinity and tells anyone with a simple hand radio that there is an missile. Basically with military equipment, it is the case of what standards does the customer require you to meet. Andrew Carson - Senior Compliance Engineer, Xyratex, UK Phone: +44 (0)23 9249 6855 Fax: +44 (0)23 9249 6014 -----Original Message----- From: Chris Maxwell [mailto:[email protected]] Sent: 01 November 2002 14:45 To: [email protected] Subject: RE: CE marking/testing of military equipment Again, I think common sense should rule on this one. I'm no military expert; but I did work in military communications for four years (yawn). I have seen a little bit of how DoD standards work. Say you are making a missle to launch from a ship. Go ahead, look through all of the civilian directives and standards that apply to CE marking. What are the chances that you will find a standard for ship-based missles?? Has the IEC ever convened a technical commitee or working group to develop a safety standard for ship-based missles? How about your average NRTL...Go ahead, give them a call. Your end of the conversation would go something like: "Hi, TUV? I've got this 20 foot long missle that carries two tons of explosives. It also has about six tons of solid rocket fuel, and a pointy nose ...... No, I'm not threatening you because of my last invoice. I want a price quote for a safety test"...... Do you think that you would get a quote? (I don't have a problem with TUV...I just used their acronym because it is recognizable.) Most military equipment is, by nature, unique and one of a kind. You just can't expect an engineer to safety test a toaster today and a ship-based missle tomorrow. If there is no CE marking directive or standard that deals with your piece of equipment on a technical basis; then how could you expect a CE mark on your equipment to show any level of consumer protection? If the equipment is specialized (especially military); then you need to deal with safety from the ground up. You are probably better off dealing with the basics of safety starting with risk based analysis. You may also find some defense department standards that apply. You can't rely on CE marking standards; unless you can find one that deals with the specific aspects of your product. If there was no directive or standard to apply; then putting on a CE mark would simply be for "show" and give a false sense of security. 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: John Allen [mailto:[email protected]] > Sent: Thursday, October 31, 2002 10:18 PM > To: [email protected] > Cc: Nick Williams > Subject: Re: CE marking/testing of military equipment > > > > Hi Folks > Sorry the first message today was incomplete - here is the full version: > > I fully support Nick's observations. > > In respect of the "comments" made by Gert, I would like to point out that > the UK appears to be not the only Member country that has taken advantage of > Article 223 , and those countries are "Full members" - not "half-members" - > so those comments are unjustiable! > > Even more to the point, it should be remembered (as I pointed out in my > earlier message) that many newer directives include specific exclusions for > equipment for military and state security applications - so everyone else > now appears to accept and agree that the UK stance and legislation on the > EMC Directive is entirely justifiable! > > Regards > > John Allen > Technical Consultant > Electromagnetics, Safety and Reliability Group > ERA Technology Ltd > Cleeve Rd > Leatherhead > Surrey KT22 7SA > Tel: +44 (0) 1372-367025 (Direct) > +44 (0) 1372-367000 (Switchboard) > Fax: +44 (0) 1372-367102 (Fax) > (but sent from my home email address!) > > > ----- Original Message ----- > From: "Nick Williams" <[email protected]> > To: <[email protected]> > Sent: Thursday, October 31, 2002 4:30 PM > Subject: RE: CE marking/testing of military equipment > > > > > > The UK's position is consistent with the provisions of, inter alia, > > article 223 of the Treaty of Rome and is therefore entirely legal.> > > > > I shall not dignify the remaining comments by replying to them. They > > are unworthy of a forum such as this. > > > > Regards > > > > Nick. > > > > > > At 07:23 +0100 31/10/02, Gert Gremmen wrote: > > >Hi Patrick, > > > > > >This text is British law,en the Uk is only a half member of the EC. > > >This law is is not backed up by the EMC directive European Text. > > >It is therefore contradictory to the EC membership requirements > > >and theoretically illegal. > > >But who will complain, as it is not creating trade barriers, > > >and is limited to pure military equipment. > > >As always, the British stand out in Europe, gaining from the profits, > > >and not accepting the obligations. > > >As Margaret Thatcher already said: Why else did God create the Channel ? > > > > > > > > >Regards, > > > > > >Gert Gremmen > > >ce-test, qualified testing > > >Rotterdam, The Netherlands > > > > > >http://www.ce-test.nl > > > > > >-----Original Message----- > > >From: [email protected] > > >[mailto:[email protected]]On Behalf Of [email protected] > > >Sent: woensdag 30 oktober 2002 23:50 > > >To: EMC-PSTC > > >Subject: Re: CE marking/testing of military equipment > > > > > > > > > > > >Hi Gert: > > > > > >I made the comment about the UK based on the following information: > > >http://www.emctla.org/Tech%20Notes/technical_guidance_note_33.htm > > > > > >2) I found the standard referred to at: > > >http://www.hmso.gov.uk/si/si1992/Uksi_19922372_en_1.htm > > >See section 20. > > > > > >PS: I love the Brits - who else would title the government standards > group > > >'Her > > >Majesty's Stationery Office'! > > > > > > > > >On Wed, 30 Oct 2002 20:48:18 +0100, "Gert Gremmen" <[email protected]> > > >wrote: > > >>There is no ground to beieve that military equiment is to be excluded > > >>in any country in Europe. This is definitely not the case in the > > >>Netherlands. > > >> > > >>Regards, > > >> > > >>Gert Gremmen > > >>ce-test, qualified testing > > >>Rotterdam, The Netherlands > > >> > > >>http://www.ce-test.nl > > >> > > >> > > >>-----Original Message----- > > >>From: [email protected] > > >>[mailto:[email protected]]On Behalf Of [email protected] > > >>Sent: woensdag 30 oktober 2002 18:49 > > >>To: EMC-PSTC > > >>Subject: CE marking/testing of military equipment > > >> > > >> > > >> > > >>I have a customer asking for CISPR 22 test results on a commercial power > > >>supply > > >>intended for use in military equipment in Europe. > > >> > > >>I've heard the UK excludes military equipment from CE marking. Do other > > >>countries also exclude military equipment from the EMC Directive? > > >> > > >>If CISPR standards are not used for European military equipment, would > > >>MIL-STD-461 be used? > > >>---- > > >>Patrick Lawler > > >>[email protected] > > >> > > >>------------------------------------------- > > >>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" > > > > > >---- > > >Patrick Lawler > > >[email protected] > > > > 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> 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: 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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. 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