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. 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] Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc 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] Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
