Products that work only on 120 V obviously won't be CE marked, even if they 
meet the EMC Directive, because CE requires conformity to all applicable 
Directives and that includes the Low Voltage Directive.
 
With best wishes DESIGN IT IN! OOO – Own Opinions Only
 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and 
Associates Rayleigh England
 
Sylvae in aeternum manent.
 
From: Adam Dixon [mailto:[email protected]] 
Sent: Saturday, October 1, 2016 2:39 PM
To: [email protected]
Subject: Re: [PSES] [RFI] Part 15 isn't enough..
 
Reply to John's question about CE marking on products in US:  

Results from an early Saturday morning visit to local (Atlanta, GA) WalMart to 
look at product labels are:
Televisions:  no CE marking (FCC + UL was common to all six models from five 
manufacturers, majority of which would be considered reputable.)
Laptops:  CE marking (could only see markings on one unit the way they are 
displayed, as well as markings are typically covered by removeable battery 
pack).  Laptops @ home have CE marking.
LCD monitors:  LG monitor @ home w/CE marking
 
Power tools w/ or w/o lithium batteries:  no CE marking, first time seeing ANCE 
marking on one battery powered drill which also had NOM and CSA markings but no 
UL marking.
Toaster ovens:  no CE marking
Microwaves:  no CE marking
Childrens' electronic toys:  don't know - got in trouble w/store security 
unboxing before I could confirm.


Just kidding about the last one....


Cheers,
Adam in Atlanta
 
 
On Sat, Oct 1, 2016 at 5:57 AM, ce-test, qualified testing bv - Gert Gremmen 
<[email protected] <mailto:[email protected]> > wrote:
John Allen wrote:
>That's probably why the products from some major multinationals (as mentioned 
>in the previously linked >website) could not be sold elsewhere in the major 
>World markets without suitable compliance and >verification, and yet can be 
>sold in the US.

I was wondering if that is really the case ?  Can our US collegues witness that 
product of reputable manufacturers are not wearing the CE marking in the US. ??




Regards,

Ing. Gert Gremmen
Approvals manager
------------------------------------------------------------------------------------


+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking
     according to EC-directives:
        - Electro Magnetic Compatibility 2004/108/EC
        - Electrical Safety 2006/95/EC
        - Medical Devices 93/42/EC
        - Radio & Telecommunication Terminal Equipment 99/5/EC
+ Improvement of Product Quality and Reliability testing
+ Education

Web:    www.cetest.nl <http://www.cetest.nl>  (English)
Phone :  +31 10 415 24 26 <tel:%2B31%2010%20415%2024%2026> 
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From: John Allen [mailto:[email protected] 
<mailto:[email protected]> ]
Sent: Friday 30 September 2016 15:31
To: [email protected] <mailto:[email protected]> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

Dieter

Yes, that's what the words state, and have done for years - but, with no clear 
requirements or guidelines as to the technical requirements (tests, limits, 
pass/fail conditions etc.) or the actual need to do verification, then 
many/most suppliers appear to me to ignore those words! I think the same was 
true in Europe during the period after the original EMC Directive (76/889/EEC) 
was published but before the CE marking requirement version (89/336/EC) came 
out and required "proof" of compliance in the form of test reports, tech files 
and the CE marking - after that, things gradually began to change!

The big problem in 1989, and for some years after, was the almost total lack of 
standards against which to do the tests and assessments on non-military 
products. However, some 25+ years later, the same cannot be said as there are 
many international, and even US trade-body, standards which could almost 
immediately be used as the basis for realistic sets of requirements to be 
formulated.

Many multi-national and US companies already do that as normal development 
practice, but in the current US legislative environment they can then "cost 
cut" for the US market by either not doing that testing on US-market specific 
products, or "cost reducing" their internationally-sold products for sale in 
that market. That's probably why the products from some major multinationals 
(as mentioned in the previously linked website) could not be sold elsewhere in 
the major World markets without suitable compliance and verification, and yet 
can be sold in the US.

John E Allen
W. London, UK

From: Paasche, Dieter [mailto:[email protected] 
<mailto:[email protected]> ]
Sent: 30 September 2016 13:59
To: [email protected] <mailto:[email protected]> 
Subject: Re: [PSES] [RFI] Part 15 isn't enough..

In general I believe that changing part 15 will be very difficult since it is a 
legal  (political) document and would need congress approval for changes. 
Different that than in the EU where you have directives and harmonized 
standards somehow separately.

 
Also the US is part of international committees and heavily participates on 
emissions and immunity standards. However implementation and enforcing is 
always difficult.
 
And finally, isn't FCC indirectly stating that immunity has to be met as well?  
FCC Part 15.5 (b)
§15.5   General conditions of operation.
     (a) Persons operating intentional or unintentional radiators shall not be 
deemed to have any vested or recognizable right to continued use of any given 
frequency by virtue of prior registration or certification of equipment, or, 
for power line carrier systems, on the basis of prior notification of use 
pursuant to §90.35(g) of this chapter.
     (b) Operation of an intentional, unintentional, or incidental radiator is 
subject to the conditions that no harmful interference is caused and that 
interference must be accepted that may be caused by the operation of an 
authorized radio station, by another intentional or unintentional radiator, by 
industrial, scientific and medical (ISM) equipment, or by an incidental 
radiator.
     (c) The operator of a radio frequency device shall be required to cease 
operating the device upon notification by a Commission representative that the 
device is causing harmful interference. Operation shall not resume until the 
condition causing the harmful interference has been corrected.
     (d) Intentional radiators that produce Class B emissions (damped wave) are 
prohibited.
 
Sincerely,
 
Dieter Paasche
 
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