In message <690230e9cf51aa4ebf639fae9216d5b166e...@mer2-exchrec1.echostar.com>, dated Wed, 28 Oct 2009, "Grasso, Charles" <[email protected]> writes:
>What changes is if the four identical pieces are sold as a system and >now - as a system - need to comply with the EU standards. > >The EU - for quite a while - has had the opinion that CE+CE does NOT = >CE (necessarily). > >This is a very perplexing question! No, it isn't. The principles were established LONG ago: they just haven't penetrated, a situation not helped by Brussels not agreeing to spell things out in plain language. I'm going to bend the rules and re-post what I wrote before, in the hope that reading it again will make things clear. QUOTE In Europe, the position is, or ought to be, fairly clear. If these are custom racks, with products put in as the **customer** requires, and the individual products and racking are billed itemized (to prove the custom aspect), then the individual product DoCs and EMC assessment are valid for EMC, but you would be wise to look at temperature effects for safety. If the racks are batch or stream produced, not custom (although you could make, say, ten identical custom racks *for one customer, to his specification*, without that being a 'batch'), and are billed as a single item, then for EMC and safety they must be tested as a single item of commerce, even if the individual products have DoCs and assessments. ENDQUOTE The 'system' concept was in the previous EMC Directive, but is not very evident in the current one. But it is the key, and the statements below are based on the Guidelines to the former EMC Directive: If a manufacturer or assembler sells a number of individually-compliant products (identical or different) in a rack or in any other form, as a catalogue item (not custom) and for an inclusive price, that is a 'system' and must have its own DoC and safety and EMC assessments. After all, as a catalogue item, the cost of testing can be spread over a significant number of such 'systems'. If a manufacturer or an assembler puts together in a rack or other form a number of compliant products, as specified by a customer on a custom basis, and invoices them at individual prices (to demonstrate that it is a custom assembly), that is not a system and does not need its own DoC and assessments, because, at least for EMC, it is no different from the products being placed on a table or shelf. After all, the cost of testing such a custom assembly would be wholly out of proportion to any benefit gained. And the customer could, in any case, buy the products and rack or other mounting separately and put it all together himself, and then there is no question of any DoC and assessment. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK Help stamp out intolerance! - 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://www.ieeecommunities.org/emc-pstc 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]>
