The part you citate:
The correct application of all the relevant harmonised standards whose references have been published in the Official Journal of the European Union shall be equivalent to the carrying out of the electromagnetic compatibility assessment”. is just the part that requires mandatory testing, I do not know many harmonized standards that present the testing requirements as optional. But In general you are right, but I’d choose another route to present “proof of compliance” which is also a requirement. In addition, the citation above is just the part that is much discussion about. The famous british hairdryer case was about a manufacturer that replaced an emc assessment by correctly applying harmonised standards. In spite of that he was condemned, because the frequency range his device was creating interference was not subject to test in the standard . It proves that harmonized standards alone are not enough, as suggested in the directive. The citation was there in place after substantial lobbying of industry, to prevent them from thinking about their products. In my opinion the citation above is plainly NOT ENOUGH to show compliance. It’s just a first step. The manufacturer DOES need to assess beyond the harmonized standards, to perform due diligence. Regards, Ing. Gert Gremmen [email protected] <mailto:[email protected]> www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Van: [email protected] [mailto:[email protected]] Namens Charlie Blackham Verzonden: Thursday, May 05, 2011 9:07 PM Aan: 'Gartman, Richard'; [email protected] Onderwerp: RE: [PSES] Opinion regarding USB and EMC testing Richard > To demonstrate compliance with the EMC directive, products that have a > “path” to the AC grid must be tested for: They don’t have to be “tested” against anything at all. The Conformity procedure in Annex II of 2004/108/EC opens with: “The manufacturer shall perform an electromagnetic compatibility assessment of the apparatus, on the basis of the relevant phenomena, with a view to meeting the protection requirements set out in Annex I, point 1. The correct application of all the relevant harmonised standards whose references have been published in the Official Journal of the European Union shall be equivalent to the carrying out of the electromagnetic compatibility assessment”. You may choose to “correctly apply” harmonised standards to perform this assessment (there are other options), but again, you aren’t required to “test” What your assessment would entail would depend on your product or range of products – you might for example choose to only perform mains emissions and immunity tests on a subset of range of devices and write a justification as to how this would cover you range of products based on similarities of devices, the effects (known and unknown) of intermediary ITE equipment etc. Another option is that you might choose to use you FCC part 15 mains conducted emissions measurements to support you EU DoC, rather than repeat the test at 230V, for example. Regards Charlie From: Gartman, Richard [mailto:[email protected]] Sent: 05 May 2011 19:32 To: [email protected] Subject: [PSES] Opinion regarding USB and EMC testing Panel of experts .. To demonstrate compliance with the EMC directive, products that have a “path” to the AC grid must be tested for: Radiated Emissions < 1GHz – EN 55022 Radiated Emissions > 1GHz - EN 55022:2006+A1:2007 Conducted Emissions – EN 55022 Radiated Immunity – IEC 61000-4-3 EFT – IEC 61000-4-4 Surge – IEC 61000-4-5 Conducted Immunity – IEC 61000-4-6 Voltage dips & Interruptions – IEC 61000-4-11 Harmonics – IEC 61000-3-2 Flicker – IEC 61000-3-3 ESD - Electrostatic Discharge – IEC 61000-4-2 A product with a UBS connector has a path to the AC grid. The 5V on the connector may be provided by an AC adapter or a piece of ITE equipment, i.e. a computer. If the “device” can ONLY be powered by a USB connector from a computer, does the “computer isolation” on the path to the AC grid reduce the testing required to demonstrate compliance of the device? The “device” would only function when it is connected to a computer via the USB. Configuration example: Line voltage => AC adapter => Computer => USB connection => Device The USB connection would also be providing data between the computer and device I would be interested in hearing any opinions on this. Thank you for your views W. Richard Gartman, MS, CSP Product Stewardship Manager Texas Instruments, Education Technology 7800 Banner Drive, Dallas, Tx 75251 Office: 972-917-1636 Email: [email protected] <mailto:[email protected]> www.education.ti.com/us/productstewardship <http://education.ti.com/us/productstewardship> Car racing also prepares you for and expects you to live in the moment – perspective comes before and after the race. Preparation equals success. <http://education.ti.com/us/productstewardship> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]>
