Adam
W.r.t. worldwide sales, in some cases a company, and that includes many US ones, require the “agility” to quickly distribute and redirect products to many different markets, and that may mean minimising the numbers of varieties of those products – that’s quite common in market sectors like ITE and some AV products where the only difference between those going to the US, Japan and Europe will often be the power cord because of the use of auto-ranging PSUs, and that also means that it will have to meet (or at least claim to meet!) all the regional EMC emission and immunity regs. However domestic appliances and the like don’t generally sell so quickly and cost margins can be lower, and market preferences for the styles and features may differ more – that can often be the reason that such appliances tend to be market-specific and so the use of dedicated voltage PSUs and so on are more likely to be used. I think your ad hoc survey in Walmart generally illustrates the above points. Re the TV market, don’t forget that digital terrestrial and satellite TV is now predominant in many developed regions of the world and the transmission characteristics of those systems have been pretty much standardised worldwide – so the references to the analogue (OUR spelling!) NTSC & PAL systems are rather out of date! J. Also means that the relevant reception equipment is often designed to cope with many of the regional variations by firmware programming or plug-in modules and cards, and not by hardware changes – so such equipment is often multi-voltage/frequency and can be sold worldwide (subject to local technical import regs and approvals and so on), and so it will (should!) have to meet all the relevant EMC emissions and immunity requirements. General “conclusion” (well, sort of) from the above – if you want to get equipment that has reasonably low emissions AND good immunity, then buy the same models that are intended to be sold in lots of other countries; if not then buy the US-market specific models and “good luck” on the immunity side of things. John E Allen W. London, UK From: Adam Dixon [mailto:[email protected]] Sent: 01 October 2016 17:15 To: [email protected] Subject: Re: [PSES] [RFI] Part 15 isn't enough.. Well, it wasn't a totally wasted trip since I picked up treats for our dog. ;-) 120VAC is within the 50-1000VAC LVD range, though I am not familiar with 120VAC or the minimum 50VAC applications in the UK. I was thinking about product designs which apply to worldwide markets. So it ends up being more a case of designing and certifying for country- or region-specific or worldwide markets. Attributes such as power supply cost, efficiency and universal vs non-universal input voltage, as well as scope and cost of regulatory compliance for one country vs worldwide, etc. And for the television market, NTSC or PAL or both. http://ec.europa.eu/growth/sectors/electrical-engineering/lvd-directive_en Cheers, Adam On Sat, Oct 1, 2016 at 10:06 AM, John Woodgate <[email protected]> wrote: 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]> 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 (English) Phone : +31 10 415 24 26 <tel:%2B31%2010%20415%2024%2026> ------------------------------------------------------------------- This e-mail and any attachments thereto may contain information that is confidential and/or protected by intellectual property rights and are intended for the sole use of the recipient(s) named above. Any use of the information contained herein (including, but not limited to, total or partial reproduction, communication or distribution in any form) by persons other than the designated recipient(s) is prohibited. If you have received this e-mail in error, please notify the sender either by telephone or by e-mail and delete the material from any computer. Thank you for your co-operation. From: John Allen [mailto:[email protected]] Sent: Friday 30 September 2016 15:31 To: [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]] Sent: 30 September 2016 13:59 To: [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 ---------------------------------------------------------------- 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]> - ---------------------------------------------------------------- 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]> - ---------------------------------------------------------------- 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]> - ---------------------------------------------------------------- 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]> - ---------------------------------------------------------------- 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) <http://www.ieee-pses.org/list.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]> - ---------------------------------------------------------------- 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) <http://www.ieee-pses.org/list.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]> - ---------------------------------------------------------------- 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]>
