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          http://www.emc2004.org/


I read in !emc-pstc that John Kretsch <[email protected]> wrote (in
<001301c45a57$1eea6970$f5f3fea9@astibo>) about 'Optical Passives for
European Market' on Thu, 24 Jun 2004:

>Yes, the LVD and EMCD are most likely not appropriate here. Chris is
>right about what a WDM is and how it is constructed. 100% passive.

Passivity per se is not a sufficient consideration.
>
>I thought that ANY product, from ANY industry, has to be CE-marked for
>sale in the EU. Period. So how can something NOT be CE-marked? I didn't
>think this could even be an option.

Indeed, it is perfectly possible for something that is obviously
'benign' in respect of safety and EMC, and any other applicable
Directive, not to be CE-marked. I have tried to explain that products
that strictly don't need to be CE-marked, nevertheless are expected to
be so marked by people who don't fully understand either the product or
the regulations, or both.

>
>I wouldn't think that we would have to go the TCF route for something
>like this. That would be way too painful and expensive. Especially for
>something like this.

I don't think anyone has said that. It is necessary  to distinguish
between a 'Technical File', as in 'Technical File Route', and the
'technical file' that the LVD requires, and which is really required, to
demonstrate 'due diligence', for the EMC Directive. In your case, the
'technical file' only needs to state, in my opinion, that the product is
'benign' with respect to the LVD and EMCD.

With regard to the laser safety issue, you can cover that by a warning
in the user instructions.
--
Regards, John Woodgate, OOO - Own Opinions Only.
The good news is that nothing is compulsory.
The bad news is that everything is prohibited.
http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk



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