I suppose it could have a switch-mode 24 V DC to 10 mA current source converter, running at 0.5 MHz or so, but a fixed resistor would be a little less costly.

On 2025-12-17 16:38, Lauren Crane wrote:

Hi Doug,

What do you imagine such a driver circuit would contain that has any significant EM emissions?

Best Regards,

-Lauren Crane

*From:*Douglas Nix <[email protected]>
*Sent:* Tuesday, December 16, 2025 9:45 AM
*To:* [email protected]
*Subject:* Re: [PSES] EMC compliance for non-emitters?

        

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Hi Lauren,

I’d assume that the LED indicator has a driver circuit embedded in the block, and therefore it has some ability to emit EMI and might otherwise have been susceptible to EMI in the environment, but for the immunity techniques used on the driver board.

Doug Nix

Kitchener, Ontario, Canada

[email protected]

+1 (519) 729-5704



    On Dec 16, 2025, at 10:31, Lauren Crane
    <[email protected]> wrote:

    Dear Experts,

    I have a weird Customs challenge. I am trying to import to the US
    an LED indicator wrapped up in a small case etc… it is a part of a
    company’s switch line up. It is essentially a lighted (LED) single
    pole switch block for a pushbutton, rated to operate at 24 V AC/DC.

    The OEM has declared the following compliance :

      * Resistance to fast transients 2 kV IEC 61000-4-4
      * Resistance to electromagnetic fields 9.1 V/m (10 V/m) IEC
        61000-4-3
      * Resistance to electrostatic discharge 6 kV on contact (on
        metal parts) IEC 61000-4-2 8 kV in free air (in insulating
        parts) IEC 61000-4-2
      * Electromagnetic emission Class B IEC 55011

    This gives it the appearance as an item of EMC-interest, thus
    triggering (apparently) the import broker to flag it for the FDA
    import form 2877.

    My question is why would the switch OEM company do this? I can see
    why ESD and fast transients might be of interest to a switch, but
    why say it is compliant to an emission standard when the item in
    and of itself is not an emitter? I’m nearly certain it is
    compliant to the cited standard because it has no emissions of its
    own at all.

    Similarly one could declare these compliances for a length of
    insulated conductor, but it really makes no sense to do so.

    It does operate off of 24V AC and DC, but I doubt there are any
    active components doing power conversion internally.

    Thanks in advance for any insights you might have….

    Best Regards,

    -Lauren Crane


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