Hi Gary, It looks like the "it depends..." scenario may be resolved by defining who the device is marketed and/or eventually available for sale to. The main difference seems to be whether or not the device is sold to the 'end user' for incorporation into an apparatus, or if it is sold to an OEM to be incorporated and then the more complete apparatus resold to an end user.
Check the "Guide for the EMC Directive 2004/108/EC (8th February 2010)". Section 1.2.3 in particular deals with whether or not components or sub-assemblies are in-scope or excluded http://ec.europa.eu/enterprise/sectors/electrical/files/emc_guide__updated_20100208_v3_en.pdf The February 2010 "new EMC Directive Quickguide" on the obligations of manufacturers also has definitions that reinforce the above distinction. (1st page, Definition 2) http://ec.europa.eu/enterprise/sectors/electrical/files/quickguide/entr-2009-00920-00-00-tra-00_en.pdf Best Regards, -Dave Heald On Fri, Dec 9, 2011 at 12:01 PM, McInturff, Gary < [email protected]> wrote: > Knowing there are directives for EMC, Safety, and RoHS compliance I am a > bit uncertain what to do with a subassembly which is in itself incomplete > and not fully functional but requires entry into the EU so that it can > become part of a larger system – also requiring all the regulations.**** > > ** ** > > We build and generate DoC’s and apply the CE mark as appropriate for end > units and reference the EU directives that apply. I seem to have two > choices on the subassemblies**** > > Acknowledge that the end product will have all of the directives imposed > when this thing is installed and write a DoC that lists them. The rational > is that we know and understand the requirements they just can’t be verified > on a subassembly. **** > > So I might indicate this is a nonfunctional assembly but list the EMC, > Safety, and RoHS etc directives that I considered**** > > ** ** > > Or I might indicate it’s a non-functional assembly and list only those > directives that it can comply with at this level. Rather than EMC, safety > and RoHS, I simply state the RoHS directive for example. **** > > ** ** > > Either of which being the basis for my applying the CE mark.**** > > ** ** > > The CE marking requirements guides don’t seem to address this – or I have > just completely misread them.**** > > ** ** > > Thanks**** > - > ---------------------------------------------------------------- > > 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.ieee-pses.org/emc-pstc.html > > Attachments are not permitted but the IEEE PSES Online Communities site at > http://product-compliance.oc.ieee.org/ can be used for graphics (in > well-used formats), large files, etc. > > 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://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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]>
