In message
<d250d01e39356a4e9cc3b4b459d6655094dc1...@ms-cda-01.advanced-input.com>,
dated Tue, 2 Apr 2013, "McInturff, Gary" <[email protected]>
writes:
Does one just state there are no requirements at this level on the DoC,
do they reference the appropriate directives for safety and EMC for the
final product.
If it's not usable on its own, it may well be something that should not
have a CE mark and a DoC. From 1.2 of the 'EMC Guide' 2010:
1.2 Defining the scope of apparatus
The EMC Directive defines "apparatus" as any finished appliance, or
combination thereof made commercially available (i.e. placed on the
market) 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 a disturbance.
1.2.1 Finished appliances
A finished appliance is any device or unit that delivers a function and
has its own enclosure.
A finished appliance is considered as apparatus in the sense of the EMC
Directive, if it is intended for the end-user and thus has to fulfil all
the applicable provisions of the Directive.
When the finished appliance is intended exclusively for an industrial
assembly operation for incorporation into other apparatus, it is not
apparatus in the sense of the EMC Directive and consequently the EMC
Directive does not apply.
We custom design bits and pieces for end customers in EU, and we keep
dancing around this issue both for ITE and medical devices.
End customers are presumably manufacturers, not 'end-users' as defined
in the Directive? If not, 1.2.3 of the Guide is applicable:
1.2.3 Components/Sub-assemblies
In contrast to finished appliances, components /sub-assemblies do not,
in general, have a proper enclosure intended for their final use.
Components/sub-assemblies are often intended to be fitted into or added
to an apparatus in order to add an additional function.
1.2.3.1 Components/sub-assemblies within scope
Components or sub-assemblies on the market which are:
- for incorporation into an apparatus by the end-user;
- available to end-users;
are to be considered as apparatus with regard to the application of the
EMC Directive.
The instructions for use accompanying the component or sub-assembly
should include all relevant information, and should assume that
adjustments or connections can be performed by an end-user not aware of
the EMC implications.
Illustrative examples:
Plug-in cards for computers;
Programmable logic controllers;
Electric motors (except for induction motors, see section 1.1.4);
Computer disk drives;
It might have a digital clock but no way to measure emissions until
it's in the final enclosure. The end user would then do some final
declarations and issue DoC's.
So the 'end-user' in your terminology IS a manufacturer and NOT an
end-user in the meaning given in the Directive.
We make RoHS and WEEE statements but those are not currently part of
our DoC for EU
Just what does a DoC for a rock look like if I wanted to ship it?
If it's not suitable for throwing, it is benign and thus exempt.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
They took me to a specialist burns unit - and made me learn 'To a haggis'.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
-
----------------------------------------------------------------
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]>
