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 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

