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        From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace 
Lin
        Sent: Friday, May 02, 2008 5:12 AM
        To: emc-p...@ieee.org
        Subject: Re: FCC Immunity Requirements
        
        
        Ian,
         
        Years ago, I had an oppotunity to ask an FCC officer this question at 
the FCC
booth during an IEEE symposium.  The officer told me FCC cares if a product
produces high emission to the public.  It is not FCC's resposibility for a
product that doesn't work properly in a noisy environment.  For this reason,
FCC is not likely to post any immunity requirement on unintentional radiators.
 Please note Bob's and Ted's comments.
         
        Last March, I had an oppotunity to sit with an EU policy maker for a 
dinner. 
I expressed FCC's position about immunity requriement.  He agreed with it. 
However, it maybe not easy to withdraw the immunity requriements from the EMC
Directive.  For manufacturers, it is not a big deal to meet both emission and
immunity requriements (since EU requirements are self declaration).  However,
if other countries follow up and post in-country testing requriements, this
would be a big issue for manufactrurers.
         
        Sincerely,
        Grace
         

Grace:
 
I think that the general lack of immunity requirements in the USA originates
>from a traditional basis. The US has long controlled emitters (intentional &
unintentional), but has never assumed any "right of good reception." (Uhh,
let's not get into encrypted and cell phone emissions right now.)
 
OTOH, Europe has licensed receivers, and thus has an obligation to ensure a
certain quality of service to those licensed users. 
 
The argument was made that the US market would reject poorly performing
consumer equipment with lousy immunity, and that regulatory control was an
unnecessary intrusion on that market. That logic carried the day for a long
time, regardless of what you think of it's truth. However, the US market has
become just about as regulation-controlled as the European market, so I expect
that someday we will see immunity standards imposed on US consumer
electronics. (Since many products sold in the US market are already compliant
with EN, there is a de facto immunity requirement already in place. <g>)
 
Ed Price
ed.pr...@cubic.com <mailto:ed.pr...@cubic.com>      WB6WSN
NARTE Certified EMC Engineer & Technician
Electromagnetic Compatibility Lab
Cubic Defense Applications
San Diego, CA  USA
858-505-2780 (Voice)
858-505-1583 (FAX)
Military & Avionics EMC Is Our Specialty
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