Hi Brian, Your summary is exemplary. It points out exactly what I have also read in the Guide, that lead me to believe that a Developer Kit might by excluded from the EMC Directive. Particularly the End User definition.
Which brings me to the second part of the problem: entering Europe without any marking or DoC whatsoever. Do you know of an established method to declare the non-applicability of CE-marking related directives, so the customs officials do not deny entry each time one of these boards is shipped to Europe. Something that would resemble FCC Form 740 for example. To John Woodgate: Thanks for the lead on Farnell, I have asked them the question, I'll post their answer if I ever get one. John On Fri, Oct 25, 2013 at 10:25 AM, Kunde, Brian <[email protected]>wrote: > The Guide for the EMC Directive may be somewhat helpful. > > As it is sold, do you feel this type of product is really an "Apparatus"? > It has no function as sold. Don't you have to incorporate it with other > Components to make it work? Isn't it really a Component or sub-assembly > incorporated with other Components or sub-assemblies to create a Prototype > Apparatus not intended to be marketed? > > Can you classify it as a "Component" or "Sub-Assembly" which is NOT > Intended for Incorporation into an Apparatus??? > Referring to the Guide for the EMC Directive 2004/108/EC (8th February > 2010), look at the Flow Charts starting on page 10; then go to Flow-Chart 2 > on page 16. > A "Component or Sub-Assembly NOT Intended for Incorporation into an > Apparatus" would be "Excluded from the EMC Directive". > > An Apparatus must also be intended for the "End User". Though in this > case, the End User would be an Engineer with knowledge of Electronics which > would most likely include at least some knowledge of EMC. On page 17 of the > guide where it describes what an End User is, see the text that says, > "Generally an end-user is deemed to have no qualifications in the field of > electromagnetic compatibility." Products not intended for the End User is > Excluded from the EMC Directive. > > In the scope of the EMC Directive, it says, "When compliant with the > provisions of the EMC Directive, equipment > may be placed on the market and/ or put into service in the Community > territory, freely moved and operated as designed and intended in the > expected electromagnetic environment." So what is the "expected > electromagnetic environment" for a product like this? It is intended to be > used Temporarily in an engineering lab or Research and Development lab. > What is the "Expected" EMC Environment of such an area where prototype > electronic devices without any EMC testing is commonly operated for long > periods of time? Though I cannot find any text that specifically excludes > prototype electronic devices operating in an R&D environment, it is kind of > a no brainer. > > Hope this is somewhat helpful. > > Brian > > > -----Original Message----- > From: John Woodgate [mailto:[email protected]] > Sent: Friday, October 25, 2013 6:22 AM > To: [email protected] > Subject: Re: [PSES] EMC requirements for developer/evaluation boards > > In message > <caey+zhmv+erfxd--dvutjklyva7wbr1dtjdkjxfqyj6m5lg...@mail.gmail.com>, > dated Fri, 25 Oct 2013, EMC Guy <[email protected]> writes: > > >. My literature research did not come up with anything helpful, > >especially for Europe > > As I explained, you will not find anything explicit about this issue. > Wherever you are, you can ask Farnell, but the answers will be > Europe-oriented. > -- > OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk If > dictionaries were correct, we would only need one, because they would all > give the same information. > 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://www.ieee-pses.org/list.html (including how to > unsubscribe) > 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]> > ________________________________ > > LECO Corporation Notice: This communication may contain confidential > information intended for the named recipient(s) only. 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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://www.ieee-pses.org/list.html (including how to > unsubscribe) > 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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]>
