Ron, I suppose the questions from my post you understood as my assertions. I've just asked based on what I should assume it is no 'apparatus'. My product is in my opinion finished (no more assembly by producer or user is planned) and will be marketed commercially.
I have in mind the open (without case) boards question just from the beginning of my interest in EMC (2 years before we joined EU in 2004) because since 1992 we have in our offer the microcontroller education system with some open boards connected when needed. After reading old Directive and its guide and later the new Directive and its guide I am still not sure if after 2004 we sell it legally or not and designing new (this time analogue) education system I'd like to be sure. Best regards Piotr Galka ----- Original Message ----- From: "Pickard, Ron" <[email protected]> To: "EMC-PSTC" <[email protected]> Cc: "Piotr Galka" <[email protected]> Sent: Wednesday, November 12, 2008 5:04 PM Subject: RE: Deviation of Performance Criteria - other question. Piotr, Please also consult the EU's EMC Directive guidance document for further clarification, which can be found at: http://ec.europa.eu/enterprise/electr_equipment/emc/guides/emcguide_may2 007.pdf As you have mentioned, your equipment is not a finished product and is not being put onto the market in the classic sense, but your students may likely be considered as being end users from the directive's perspective. Even if not being marketed commercially, it may still be considered to be placed on the market when being put into service as described in the Guide. However, if your device, as you describe it, may be considered as a sub-assembly being made available use by students (end user), then it is considered as an apparatus and the EMCD applies. However, if your device may be considered as being inherently benign (see Guide), the EMCD may not apply. But, even if your device must comply with the directive, an assessment (you have the freedom to define/describe that assessment) should demonstrate conformance with the essential requirements of the directive (Article 5, Annex I). IMHO, your previous arguments posted in this thread could form the basis of that assessment. Please note that the Guide provides flowcharts that might be helpful in your navigation of this applies/or not decision process for the EMCD. So, my advice to you would be to read the directive (Article 4.3 may be of interest) AND the Guide thoroughly to understand what applies to your device and what doesn't and your situation. Finally, it may be wise to consult with someone very familiar with the technical and legal aspects of the EMCD to provide you with a firm basis for you to proceed. I hope that you understood my reply as I tried to describe my opinions well enough in English for you. I also understand that this may have raised more questions for you, which may not be a bad thing. Education is good thing, don't you think? Personally, this forum has been a wonderful learning experience for me over the years, and I hope for others as well. Maybe this will spawn more comments from our more learned colleagues, thereby adding to a consensus on this subject. IHTH and please note that my contributions above are solely my opinions only. Best regards, Ron Pickard [email protected] From: [email protected] [mailto:[email protected]] On Behalf Of Piotr Galka Sent: Wednesday, November 12, 2008 4:54 AM To: EMC-PSTC; Sterner, David (NY80) Subject: Re: Deviation of Performance Criteria - other question. ----- Original Message ----- From: "Sterner, David (NY80)" <[email protected]> >Under EMC directive 2004/108/EC, "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. >As your classroom lab equipment does not seem to fit this definition, >some provisions of the directive are therefore non-applicable. Marking >is another issue. I'd really like to understand you, but I'm not good at English (really I hardly understand not electronic English). So please tell me what do you suggest ? My equipment: - is not finished appliance ? - is not commercially available ? - is not functional unit ? - pupil at school are not end users ? - it not generates electromagnetic disturbance and can't be affected by such disturbance ? and why do you think so ? I'd be very happy if I can be sure my equipment does not fit this definition but it looks I miss some point you see it. Best Regards Piotr Galka - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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