Jim, I attended a presentation on the topic at February's TCB Council meeting. After the presentation (and reading the directive), here is my understanding:
1) Your interpretation is correct. and 2) the Directive applies to products permanently affixed (need tools to install/uninstall) 3) the Directive applies to products permanently or temporarily to the electrical system (including via the lighter socket) 4) the Directive does not apply to products that can be used in a vehicle but that are not attached as above (so probably cell phones without DC adapters, other battery powered devices without DC adapters, etc?) Does this answer your question about being related to vehicle safety and which path to take? Unfortunately, no. I'm still working on that one. Anyone else care to join in? Best Regards, -Dave Heald David Heald EMC Engineer / Worldwide Regulatory Symbol Technologies tel: +1.631.738.5373 fax: +1.631.738.3915 Symbol. The Enterprise Mobility Company. (TM) >>> "Jim Eichner" <[email protected]> 05/18/05 07:54PM >>> I'd like to test my understanding of how the new Automotive EMC Directive is to be interpreted with regards to electronic-subassemblies (ESA's) that are unrelated to vehicle safety, what the relationship is to the EMC Directive, and how those questions differ between the old and new Automotive EMCD. Old (95/54/EC): You need the e-Mark and you need to meet the radiated emissions limits in the Directive. If the product is automotive only, then you do not also need to meet the EMCD. New (2004/104/EC): You need to meet radiated emissions limits, conducted transient emissions limits, and conducted transient immunity tests, as specified in the Directive. After that, you have 2 choices: a) e-Mark: A "technical service" is needed, and will issue the e-Mark with it's accompanying approval number after doing or witnessing the required testing. Products are marked with the e-Mark. If the product is only intended for the automotive market, you do not also need the EMC Directive. b) No e-Mark: If you meet the (non-automotive) EMC Directive and have a declaration saying so, and your equipment is not related to vehicle safety, you do not need the e-Mark. You need a letter >from a technical service stating that the product is not related to vehicle safety. You have to pass all the same tests in 2004/104/EC in addition to whatever the EMC Directive required you to do (and the tests are very different) but you can do that testing with or without agency involvement and you can self-declare compliance with those tests as part of your EMC Directive self-declaration. Expiry: As far as I can tell, ESA approvals done to the old AEMCD are valid until Jan. 1st, 2009, and you can obtain new approvals to the old AEMCD until July 1st, 2006. Questions: 1. Do you think I have this right or wrong? If wrong, how so? 2. The new rules seem to create a very strange set of circumstances. How can the authorities tell the difference between a) an ESA that is not safety-related and therefore is legitimately allowed to not have the e-Mark, and b) an ESA that is safety-related and is illegitimately missing the e-Mark? As always, thanks in advance for whatever guidance the forum can offer. Jim Eichner, P.Eng. Compliance Engineering Manager Xantrex Technology Inc. e-mail: [email protected] web: www.xantrex.com Any opinions expressed are those of my invisible friend. Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. 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