>>>>>For EMC purposes, the directives are very clear:  you do not need to 
meet
the EMCD if your product is solely automotive, only the AEMCD.  However for
safety purposes the LVD still seems to apply, suggesting you need to have
the CE Mark. However using the CE Mark requires using all applicable
directives, therefore necessitating compliance with the EMCD, which our
theoretical product does not comply with.<<<<<<

The CE Marking on an electrical product does not mean "My product complies 
with the EMC Directive".  Your Declaration of Conformity indicates which 
Directives you meet, and you decide which Directives are applicable based on 
the type of product and the scope of the Directives.  I have not read any 
statement in any Directive that says, "If you declare compliance to the LVD, 
then you must declare compliance to the EMC Directive.".  

This is my understanding:  Since the AEMCD is the applicable Directive for 
EMC of automotive products, the EMC Directive is not applicable, regardless 
of what other Directives apply.



Greg Galluccio
www.productapprovals.com

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