In the USA, FCC CE and RE limits for digital equipment were first derived as
described in CBEMA Report ESC5/77/29.  CE limits were based on measurements
of victim radio sensitivity below 30 MHz, and RE limits were based on EIA
specs for radio receiver sensitivity above 30 MHz.

In other words, just as Mr. Woodgate states.  I saw nothing about margins.
Instead, the measurement methods were chosen to provide suitable accuracy.
Thus, for instance, the 30 MHz break for CE/RE measurements.  30 MHz was
stated to be the lowest frequency at which reasonably accurate RE
measurements could be made at three meters.  Analysis predicted that the 48
dBuV CE limit was sufficient to protect against RE below 30 MHz.  The limits
were placed just as Mr. Woodgate states, to minimize EMI complaints under
typical but not all conditions.  The 450 kHz lower end of FCC measurements
encompassed the MW AM band plus the 455 kHz IF of AM band radios.  In
Europe, the lower frequency was 150 kHz because of 150 kHz - 300 kHz LW AM
band usage.

In this country we have LORAN navigation in use near the coasts, but it was
deemed economically unsound to mandate that all office equipment meet CE
limits to protect a few coastal radio victims.

> From: [email protected]
> Date: Tue, 2 Aug 2005 02:49:02 -0500
> To: [email protected]
> Subject: RE: Request for info on CE Mark penalties
> 
> Dave, I have been trying for some time now to find out just exactly how
> limits lines were derived. Can you point me to a study/report/data that can
> show me (or more importantly, others here at work) just how the limits were
> derived? No one seems to be able to.
> 
> Bob Heller
> 3M EMC Laboratory, 76-1-01
> St. Paul, MN 55107-1208
> Tel:  651- 778-6336
> Fax:  651-778-6252
> =========================
> 
> 
> 
> drcuthbert@micron
> .com             
> Sent by:                                                   To
> [email protected]         <[email protected]>
> <[email protected]>
> cc 
> 08/01/2005 11:53 
> AM                                                    Subject
> RE: Request for info on CE Mark
> penalties        
> 
> 
> 
> 
> 
> 
> 
> 
> 
> 
> John,
> 
> the consideration of penalties is a form of consequentialist ethics that
> focuses on "us". A higher form (in my opinion) is to focus on the
> consequences to "the other." In this case, the other is society. As you
> know, the EMC limits are not arbitrary; they are based on the interference
> potential to EM communications. So one can consider that shipping a product
> that exceeds the EMC limits could potentially harm society.
> 
> One can take this one step further and consider that a product that is
> under the EMC limits can still potentially harm society, but that it is not
> as harmful as a product that exceeds the EMC limits. In this case we can
> site rule based ethics by proclaiming that we meet the EMC rules and
> therefore we have done all that we are required to do. These two
> conflicting ethical positions could make for a long and interesting
> discussion.
> 
> Dave Cuthbert
> Micron Technology
> 
> 
> 
> From: [email protected] [mailto:[email protected]] On Behalf Of Tyra, John
> Sent: Friday, July 29, 2005 7:20 AM
> To: [email protected]
> Subject: Request for info on CE Mark penalties
> 
> 
> 
> Hello everyone,
> 
> 
> Does anyone have any good articles or website examples of the penalties for
> non- conformance for the CE Mark. I especially need examples for EMC
> violations to use to stress the seriousness  and impact to business for
> some non regulatory people here who need some convincing.
> 
> 
> Thanks in advance for your help
> 
> 
> 
> 
> 
> John Tyra
> Manager Product Safety
> 
> 
> Bose Corporation
> The Mountain, MS-450
> Framingham, MA 01701-9168
> 
> 
> Phone: 508-766-1502
> Fax:     508-766-1145
> 
> 
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