I took a second look at the EMCD guidelines, chapter 6 and have changed my opinion.
In the EMCD guidelines, if the DRAMS are sold to the end user, applicability of the EMCD comes down to whether the DRAM modules perform a "direct function" to the end user. The examples given in chapter 6 of the EMCD guideline (required reading for all involved with CE-Mark/EMCD compliance btw) put components such as memory modules into a gray area, or do they? In my previous response, I rationalized that (ref. Ch6 of the EMCD guidelines) the SDRAM does not perform a direct function to the end user, now I'm not so sure. Note that although the SDRAM type memory module is not specifically used as an example, the hard disk drive is.....and the hard disk is considered to perform a direct function and is subject to the provisions of the EMCD. Does this change anyone else's opinion as to whether the EMCD applies? Certainly the function provided by a hard disk drive and compact flash memory card is very similar. Is an SDRAM module so different that it does not require testing? SimpleTech apparently feels CE-Marking is prudent: http://www.newegg.com/app/Showimage.asp?image=20-150-310-02.jpg In regards to one contributor's question as to how an SDRAM module would be tested, essentially the modules are installed and tested into a host PC, complete with monitor keyboard etc. There are detailed procedures in both EN 55022/CISPR 22 and in FCC Part 15. Although I'm not in the ITE arena, I am aware that there are some differences in the specific procedures for the EMCD versus FCC Part 15. FCC 15 explicitly allows PC manufacturers to sell a PC assembled from FCC compliant components without testing the assembled PC, though special marking is required. I don't believe there is an "official" parallel to the FCC procedure for CE-Marking, though a small PC assembler could legally CE-mark without testing and build his compliance file with compliance documentation for the PC components. Douglas G. Frazee Regulatory Compliance Manager Lucent Technologies PSAX Division (301) 809-4415 (301) 352-4680 FAX [email protected] -----Original Message----- From: Doug Massey [mailto:[email protected]] Sent: Monday, November 10, 2003 9:26 AM To: [email protected] Subject: RE: opinions, please I have to throw my opinion in on this one, couldn't resist - Let's not beat around the bush - NO, the CE mark does not apply. Most certainly, it is exempt from the LVD. As to EMC, this device has no clock to radiate by itself. It is subject to the EMCD when and only when incorporated into an end product. Of course, you are offering it for sale stand-alone, for incorporation into an end product. Said end product, assumed to be CE Marked itself, should have been tested in a full, representative configuration, so it is assumed that all available memory expansion slots were populated, and hopefully, being exercised during the testing. Your memory device should be significantly like the memory device installed in the end product during testing. All emissions and immunity characteristics of said product should be dependent on other design features, NOT on the particular memory module installed. No, this rationale does not follow any textbook definition of component or system - I guess, by necessity, any definition would be vague. It just makes common sense to me. If this seems a bit cavalier, ask this question: Should the individual IC's on the memory module be CE Marked? Is it a good idea to test your device for immunity? Yes, if you have protections designed in, but then the testing is purely a design verification test, not for the purpose of CE Marking, but rather, to insure that your design functions as intended. And as to the modem card mentioned in a previous reply to this thread, I think it is marked to indicate compliance to the RTTE Directive, which considers the modem card a system - ie, when added to a product, the RTTE Directive still applies only to the modem, and not to the complete system. In other words, the RTTED is explicitly applicable to the modem card, and there is no questions as to component vs system in the RTTE. Doug Massey Product Safety Engineer Advanced Compliance Solutions Ph. (770) 831-8048 FAX (770) 831-8598 Visit our web home at http://www.acstestlab.com From: [email protected] [mailto:[email protected]] On Behalf Of Gordon,Ian Sent: Monday, November 10, 2003 4:11 AM To: '[email protected]'; [email protected] Subject: RE: opinions, please Dave at al How will you test it as a free standing unit? Won't you need to build it into a pc and then test it? I know CE + CE doesn't give CE but if you did that with a representative pc and assuming the system continues to be compliant are you not showing "due diligence"? I still wouldn't have thought a CE mark was appropriate though. Ian Gordon _____________________________________________________________________ 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 This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. 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