Hi 
Wrt to Bill's comment on the weakness of the DoC, I would personally say that
the DoC in question is non-compliant with the EMCD since it does not declare
compliance with a relevant full set of harmonised standards for bothimmunity
and emissions or reference a relevant Competent Body-approved TCF, and
therefore it does not demonstrate compliance with the requirements of Articles
3 & 4 (and related requirements) of the Directive.
 
Therefore, the weakness is probably not with the concept of the DoC as stated
in the Directive, but with the manner in which compliance with the Directive
in general and the DoC requirements in particular is,  or is not, enforced,
(i.e. very rarely in many EU countries!).
 
Nevertheless it would be interesting to be given the actual wording of that
DoC so that we could comment in detail, since  - in my experience - around 50%
of DoC's are incorrect in some form, especially when prepared by someone who
does not know both the relevant Directive(s) and the related interpretive
documents.
(In fact I wonder if it even referenced the EMCD, as I have seen some that
called up only relevant standards and not the relevant overarching Directives).
 
Regards
John Allen, 
Technical Consultant
EMC and Safety Engineering
ERA Technology Ltd.
Cleeve Road
Leatherhead 
Surrey KT22 7SA
UK
Tel: +44-1372-367025 (Direct)
+44-1372-367000 (Switchboard)
Fax: +44-1372-367102


From: Bill Stumpf [mailto:[email protected]]
Sent: 03 October 2003 17:04
To: '[email protected]'; [email protected]
Subject: RE: Missing Emissions data from D of C?


Derek,
This points out one of the weaknesses of the self-declaration (DOC). The
responsible party can self declare for whatever standards they feel suite
their needs. For instance, just because a product is CE marked, it doesn't
mean that it has been tested or passed to all the relevant standards. It may
just be safety. The only way to tell for sure is to look at the actual DOC,
which lists the standards the product has been tested to. In the case you
brought up, The product should have been tested for emissions to EN 55014 at
the very least. We would also recommend EN 55022, since the potential for
interference goes well beyond  the 300MHz called out in EN 55014.
 
William M Stumpf 
DLS Electronics 
166 South Carter St. 
Genoa City WI 53128 
ph: 262-279-0210 
fx: 262-279-3630 
email: [email protected] 

 ----Original Message-----
From: [email protected] [mailto:[email protected]]
Sent: Thursday, October 02, 2003 1:02 PM
To: [email protected]
Subject: Missing Emissions data from D of C?



Hi all, 
 
while reviewing a clients competitors D of C, I was surprised to see that only
Immunity and Low voltage were address, there were no emissions requirements
called out.
 
The product is a professional arcade game. Is this product exempt? Any
thoughts why this could be allowed?
 
Cheers,
 
Derek N. Walton
Owner, L F Research EMI Design and Test Facility
Poplar Grove,
IL 61065


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