Scott,

I can’t say exactly why they did that, but we do see customers obtaining E-mark 
for marketing purposes, even if the product isn’t immunity related equipment.

As for testing, EN 50498 was created from 2004/104/EC, for those non-immunity 
related products. The testing is identical as for E-marking(for 12 or 24 VDC 
powered devices at least), with the exception of EN 50498 not requiring 
radiated susceptibility.

Thanks,

David


From: Scott Xe [mailto:[email protected]]
Sent: Friday, August 19, 2016 11:38 PM
To: Schaefer, David <[email protected]>; [email protected]
Subject: Re: Automotive EMC

Hi David,

Appreciate your clear guidance!

UN ECE R10.05 is only for products that are defined as immunity-related 
systems.  Recently I received a UN ECE R10.05 compliant report (no Conformity 
of Production) on a portable DVD player issued in Spain from the supplier.  
Since this is also working in household environment, I also received an EMC 
compliant report but without the use of applicable standard EN 50498.  The unit 
is affixed a CE mark but no E-mark.  Although it is NOT completely compliant 
with requirements, the product is deemed to comply with requirements 
technically.  Any thought why to test to E-mark, not normal EMC?

Thanks and regards,

Scott



From: "Schaefer, David" <[email protected]<mailto:[email protected]>>
Date: Saturday, 20 August 2016 at 1:47 AM
To: Raymond Li <[email protected]<mailto:[email protected]>>, 
"[email protected]<mailto:[email protected]>" 
<[email protected]<mailto:[email protected]>>
Subject: RE: Automotive EMC

Scott,

UN ECE R10 has been in force for a long time now. For the EU, it replaced 
2004/104/EC for automotive EMC a few years ago. Products that are defined as 
immunity-related systems require compliance to ECE R10, which includes testing, 
certification, and Conformity of Production. It is not a self declaration like 
CE. Also, UN ECE R10 is an E-mark(capital E), which replaced e-mark(lower case 
e).

EN 50498 can be used for aftermarket products that have no immunity related 
functions. Those are defined in ECE R10.05 as below:



2.12. "Immunity related functions" are:

(a) Functions related to the direct control of the vehicle:

(i) By degradation or change in: e.g. engine, gear, brake, suspension, active 
steering, speed limitation devices;

(ii) By affecting drivers position: e.g. seat or steering wheel positioning;

(iii) By affecting driver's visibility: e.g. dipped beam, windscreen wiper.

(b) Functions related to driver, passenger and other road user protection:

(i) E.g. airbag and safety restraint systems.

(c) Functions which, when disturbed, cause confusion to the driver or other 
road users:

(i) Optical disturbances: incorrect operation of e.g. direction indicators, 
stop lamps, end outline marker lamps, rear position lamp, light bars for 
emergency system, wrong information from warning indicators, lamps or displays 
related to functions in subparagraphs (a) or (b) which might be observed in the 
direct view of the driver;

(ii) Acoustical disturbances: incorrect operation of e.g. anti-theft alarm, 
horn.

(d) Functions related to vehicle data bus functionality:

(i) By blocking data transmission on vehicle data bus-systems, which are used 
to transmit data, required to ensure the correct functioning of other immunity 
related functions.

(e) Functions which when disturbed affect vehicle statutory data: e.g. 
tachograph, odometer.

(f) Function related to charging mode when coupled to the power grid:

(i) For vehicle test: by leading to unexpected vehicle motion;
(ii) For ESA test: by leading to an incorrect charging condition (e.g. 
over-current, over-voltage).



A CD or DVD player likely would fall under EN 50498, unless it will be 
connected to the vehicle bus. If it only connected for DC power, CE mark would 
be appropriate.

If you have more questions, please let me know.

Thanks,

David Schaefer
EMC Chief Technical Advisor
TÜV SÜD America Inc
Office: 651 638 0251
Cell: 612 578 6038
Fax: 651 638 0285




From: Scott Xe [mailto:[email protected]]
Sent: Friday, August 19, 2016 11:48 AM
To: [email protected]<mailto:[email protected]>
Subject: [PSES] Automotive EMC

I have learnt that automotive EMC is now legislated for by UNECE Regulation 10. 
 When will it enter into force?

With CD players, DVD players, can they comply with UNECE Regulation 10 or EMC 
under EN 50498 according ESA previously used in Automotive EMC?

In terms of marking, e-mark is required if compliance selects UNECE Reg 10 
while CE Mark is required if selects EMC.  Is it the same as Automotive?

With UNECE Reg 10 option, does it require conformity of production too?

Thanks,

Scott


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