Hi Chuck, The EMC Directive applies to individually marketed installations, systems, apparati or components, not those coincidentally assembled by the end user. The scenario you've described below should be completely legal since both were likely marketed separately from possibly different manufacturers. Your scenario is no different, except by scale, than a home computer network or a large corporate computer network. And to answer your second question, the manufacturer cannot possibly and logically test every possible combination of peripherals that the laptop might connect to. The manufacturer can only exercise his due diligence by exercising all the laptop ports during EMC testing using a defined set of peripheral devices. Please note that the manufacturer is responsible only for compliance of its own products. If a system integrator markets a configured installation/system/appliance using components that are individually CE marked, then he is responsible for the compliance of that particular marketedinstallation/system/appliance. Comments?
Best regards, Ron Pickard RPQ Consulting 7372 West Luke Avenue Glendale, AZ 85303 +623.512-3451 tel, +623.848-9033 fax [email protected] www.rpqconsulting.com <http://www.rpqconsulting.com/> _____ From: [email protected] [mailto:[email protected]] On Behalf Of Grasso, Charles Sent: Sunday, January 13, 2008 4:28 PM To: John Woodgate; [email protected]; [email protected] Subject: RE: Definition of system integrator Thank you John and Monrad. I wonder though how this clinical definition applies in the PC marketplace? Who is the "manufacturer" when an external USB drive is purchased (by a consumer) and then attached to - say - a laptop BTW in this case we have two CE marked devices! How does the "manufacturer" of the laptop prove that his product complies with the EMC Directive with the plethora of peripherals available to the everyday consumer? Chas From: [email protected] on behalf of John Woodgate Sent: Sat 1/12/2008 1:49 AM To: [email protected] Subject: Re: Definition of system integrator In message <[email protected]>, dated Fri, 11 Jan 2008, Monrad Monsen <[email protected]> writes: >The same is true for Europe. The "Guide for the EMC Directive >2004/108/EC (22nd March 2007)" does not use the term "system >integrator", but the guide does describe the system integrator role and >states that for the purpose of the EMC Directive that entity that >combines/designs/puts together the system becomes the "manufacturer". >As manufacturer, the entity (system integrator) becomes responsible for >ensuring that the system complies with the requirements for an >apparatus as given in the EMC Directive. The guide states on page 19 >in section 1.2.2 the following: > - - - - - - >1.2.2 Combination of finished appliances (systems) >A combination of several finished appliances which is made commercially >available as a single functional unit intended for the end-user is >considered to be apparatus. Such a system, within the sense of the EMC >Directive, is combined, and/or designed and/or put together by the same >person (the "manufacturer") and is intended to be placed on the market >for distribution as a single functional unit for end-use and to be >installed and operated together to perform a specific task. All >provisions of the EMC Directive, as defined for apparatus, apply to the >combination as a whole. > >It should be noted that combining two or more CE finished appliances >does not automatically produce a "compliant" system e.g.: a combination >of CE marked Programmable Logic Controllers and motor drives may fail >to meet the protection requirements. > - - - - - - > >The guide has a footnote that points to the base EMC Directive >2004/108/EC paragraph 2(1)(b) which has the simple apparatus >definition: > = = = = = >(b) 'apparatus' means any finished appliance or combination thereof >made commercially available as a single functional unit, intended for >the end user and liable to generate electromagnetic disturbance, or the >performance of which is liable to be affected by such disturbance. > = = = = = > >Hope this helps. > Some unofficial 'interpretation' may assist. The words 'made commercially available as a single functional unit intended for the end-user' can be interpreted as 'invoiced at a single inclusive price'. 'Commercially available' may be interpreted that such a combination is not put together specially for a single customer, but is offered (e.g. in a catalogue or advertisement) to all-comers. The underlying concept is that the 'manufacturer' can assess and, if necessary, test the combination as a whole, while testing is often not economically realistic for a 'one-off' special combination. Such a special combination might be invoiced as separate items so as to emphasise its special nature. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk For very important information, please turn over. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
