I would be VERY wary of any lab-orginated certificates of the type Lothar describes, for several reasons: a) The directives clearly put the DoC responsibility on the manufacturer or the EC importer (as appropriate), and the test lab is almost certainly not one of those in the vast majority of cases. b) All the CE Marking directives (not just the EMC) require technical files containing a good deal of supporting information on the manner in which the equipment is designed and manufactured - not just how it was tested for certification purposes. A test lab would almost certainly not have such data, but even if it did obtain the data from the actual manufacturer, it would most certainly not be a position to apply the required design and manufacturing controls necessary for ensuring on-going compliance. Not even routine 3-monthly factory inspections such as performed by the North American NRTL's can totally ensure that because it is very-much a "day-to-day", "hands-on" task. Like a number of the contributors to this forum I know this because I have "been there, done that" on quite a few occasions (and am in a position to help anyone who needs assistance to get their own house in order). John Allen, Technical Consultant EMC and Safety Engineering ERA Technology Ltd. Cleeve Road Leatherhead KT22 7SA, UK Tel: +44-1372-367025 (Direct) +44-1372-367000 (Switchboard) Fax: +44-1372-367102
From: Lothar Schmidt [mailto:lothar.schm...@cetecomusa.com] Sent: 05 August 2003 01:44 To: emc-p...@majordomo.ieee.org Subject: RE: Declaration of Conformity by 3rd Party Yes the DoC is issued by the party placing the product on the market. There are some labs trying to sell certificates which looks like a DoC, but this is not the the right way defined in the EMC directive of the EU. Regards Lothar Schmidt BQB & Technical Manager EMC/Radio/SAR CETECOM Inc. 411 Dixon Landing Road Milpitas, CA 95035 ' +1 408 586 6214 7 +1 408 586 6299 From: Locke, Darrell [mailto:dlo...@advanced-input.com] Sent: Monday, August 04, 2003 1:42 PM To: emc-p...@majordomo.ieee.org Subject: Declaration of Conformity by 3rd Party I have a question on the Declaration of Conformity for CE Marking. It is my understanding that it is created by the party placing the product on the market in the EU. Has anyone ever heard of a DOC by a third party such as a test lab? What about when one manufacturer CE marks a subassembly that another manufacturer places on the market? I would think the DOC is still issued by the party placing the product on the market. Darrell Locke Advanced Input Devices >>> Download free spam killer at http://eliminatespam.com <http://eliminatespam.com> _____________________________________________________________________ This e-mail has been scanned for viruses by MCI's Internet Managed Scanning Services - powered by MessageLabs. For further information visit http://www.mci.com ************************************************************************* Copyright ERA Technology Ltd. 2003. (www.era.co.uk). All rights reserved. The information supplied in this Commercial Communication should be treated in confidence. No liability whatsoever is accepted for any loss or damage suffered as a result of accessing this message or any attachments. _____________________________________________________________________ This e-mail has been scanned for viruses by MCI's Internet Managed Scanning Services - powered by MessageLabs. For further information visit http://www.mci.com
