Interesting question..........here's my opinion.

I assume you are concerned only with the EMC Directive.  The EMCD guidelines
document http://europa.eu.int/comm/ente
prise/electr_equipment/emc/guides/index.htm 
has detailed information on application of the EMCD to components.  Memory
modules are not specifically used as an example and seem to fall somewhat in a
gray area.  Certainly if the modules were being sold only as an OEM product,
CE marking is not required.  If the are being directly sold to the end user,
then I believe the flowchart decision as to whether the EMCD applies or not
depends on whether the component performs a "direct function".  Here, I would
rationalize that PC plug-in products such as modems, sound cards, video cards
etc. perform "direct functions"; the DRAM module does not, it is strictly a
component that is required for the PC to operate.  Thus application of the EMC
Directive is not mandatory even if marketed directly to the end user.  

However, if your firm feels that CE-marking provides product benefits such as
enhanced marketability, you will be able to optionally test, declare
compliance and CE-Mark to the EMCD using EN55022/55024.

Douglas G. Frazee
Regulatory Compliance Manager
Lucent Technologies
PSAX Division
[email protected]

 -----Original Message-----
From:   [email protected] [mailto:[email protected]] 
Sent:   Friday, November 07, 2003 12:37 PM
To:     [email protected]
Subject:        opinions, please


I have a question: Is a Memory Module (DIMM) considered a component or an
apparatus? 

I'm trying to decide whether the CE MARK is applicable to this type of product.

   Dave Cuthbert
   Micron Technology



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