Hello Scott,

Here are my rambling thoughts....

For the EU, I think you need to comply with the EMC Directive because I recon 
your product satisfies the following Directive definition... 

 /‘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;/

Think about a wall-wart power supply, usless by itself, but it still subject to 
the EMCD.

You need to meet the Directive’s “Essential Requirements”....

1. Protection requirements

Equipment shall be so designed and manufactured, having regard to the state of 
the art, as to ensure that:

(a) the electromagnetic disturbance generated does not exceed the level above 
which radio and telecommunications equipment or other equipment cannot operate 
as intended;

(b) it has a level of immunity to the electromagnetic disturbance to be 
expected in its intended use which allows it to operate without unacceptable 
degradation of its intended use.

>From what little I know about your product, in the case of (a) disturbance, I 
>would write a technical rationale and justification as to how the product 
>cannot produce electromagnetic interference due to the nature of its design 
>and operating characteristics. Your product appears to include active gain 
>stages and therefore has the risk potential of parasitic oscillation. Some 
>brief measurements with a high impedance oscilloscope probe or near-field 
>probes and a spectrum analyser  /may/ be prudent and include the results in 
>your justification.

In the case of (b) immunity, assuming there is no harmonised standard for you 
product, I would define my acceptable performance degradation and the 
disturbance levels by drawing from standards for similar products or from 
standards for similar markets, e.g. consumer, industrial, vehicular etc., 
wherever you product is aimed at. You will probably have to test this, radiated 
immunity as a minimum, perhaps ESD and maybe conducted immunity if there is 
risk of EMI from the host product. Sounds to me like a very short day at the 
cheapest test lab you can find, provided it has documented test methods for the 
tests you have chosen, reasonable quality procedures and calibration. Take the 
lab’s raw logbook results, plenty of photographs, copies of calibration 
certificates and write them up yourself, or splash out on a test report if you 
wish.

To do nothing or to say it doesn’t matter if the product fails under 
electromagnetic disturbance wouldn’t be acceptable, that’s right against the 
spirit of the Directive which we (well, I) believe you need to meet. Consumers 
like me expect stuff to work while the vacuum cleaner's running, my daughter's 
on Facebook via the wireless router, I'm chatting to a friend on my mobile 
while the 4 DECT phones are ringing, the iron's thermostat is clicking on and 
off, the washing machine's running, and when I operate it after shuffling 
across the carpet in my nylon trousers (fussy bunch.... consumers).

Compile your product schematics and drawings (or a list thereof), your ratioale 
and justification for meeting the emissions requirements, your rationale for 
choosing your performance criteria and disturbance levels, write-ups of the 
testing you undertook, and hey-presto, you have your EMC Directive Technical 
Construction File, give it a document name or number.

Oh, and don't forget your EU Declaration of Conformity.

Just what I'd do, but follow at your own risk :-)

T
----- Original Message -----
From: Scott Douglas
Sent: 07/12/13 02:47 PM
To: [email protected]
Subject: [PSES] EMC Required?

Hi folks, Consider a simple circuit. IR diode, a transistor or two, some 
resistors and caps. Receives input from IR remote, converts to electrical and 
sends down a wire. No clock in the thing so you could call is passive. But does 
it need EMC testing for US or EU? The IR signal will be in the 35-50 kHz range 
so pulses down the wire will be the same. Does this make it fit within the 
realm of EMC required? The device is sold by itself without other products, but 
is always connected to something else in use. Something else could be a wide 
variety of anything. I think of it like a stand-alone audio speaker. Purely a 
passive device that is driven by signals that fall within the EMC required 
realm. So do you do EMC or not? Looking forward to your opinions on this. Scott 
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