Re: [PSES] German Product Safety Act (ProdSG) - Label requirement

[John Woodgate]

In message 
, 
dated Tue, 28 Feb 2012, "Kim, Ben"  writes:



What if it conflicts with upcoming LVD Directive ?


Then it applies only in Germany to German-made products.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
If 'QWERTY' is an English keyboard, what language is 'WYSIWYG' for?

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Re: [PSES] German Product Safety Act (ProdSG) - Label requirement

[IBM Ken]

Are there requirements on the size of the label and if it must be
visible on the outside of the product?  Can it be behind an access
door?

On 2/28/12, John Woodgate  wrote:
> In message
> <72b8947772cf0948adaa9853631663fb6477498...@pbi-namsg-02.mgdpbi.global.pv
> t>, dated Tue, 28 Feb 2012, Jim Hulbert  writes:
>
>>Under the new German Product Safety Act (ProdSG), as of Dec 2011
>>consumer products are required to have a label with the name and
>>address of the manufacturer (or importer if the manufacturer is outside
>>the EU).  Simply providing that information with the operator guide is
>>not good enough anymore.  Does this new requirement apply only to
>>products that have the GS certification mark, or does it apply to all
>>consumer products?
>
> If it's an Act - i.e. a law, it must apply to all products.
> --
> OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
> John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
> If 'QWERTY' is an English keyboard, what language is 'WYSIWYG' for?
>
> -
> 
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Re: [PSES] German Product Safety Act (ProdSG) - Label requirement

[Kim, Ben]

What if it conflicts with upcoming LVD Directive ? The EU LVD/EMC directives 
are currently under revision as part of alignment with new NLF Directive, 
and placing those importer contact information in a document will be one of the 
allowed options once the proposal is passed by EU Council (highly likely). 

LVD Directive (2006/95)- Alignment package proposal: Article 8

" Importers shall indicate their name, registered trade name or registered 
trade mark and the address at which they can be contacted on the electrical 
equipment or, 
where that is not possible, on its packaging or in a document accompanying the 
electrical equipment"

Thanks, 
Ben Kim

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Tuesday, February 28, 2012 3:31 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: German Product Safety Act (ProdSG) - Label requirement

In message 
<72b8947772cf0948adaa9853631663fb6477498...@pbi-namsg-02.mgdpbi.global.pv
t>, dated Tue, 28 Feb 2012, Jim Hulbert  writes:

>Under the new German Product Safety Act (ProdSG), as of Dec 2011 
>consumer products are required to have a label with the name and 
>address of the manufacturer (or importer if the manufacturer is outside 
>the EU).  Simply providing that information with the operator guide is 
>not good enough anymore.  Does this new requirement apply only to 
>products that have the GS certification mark, or does it apply to all 
>consumer products?

If it's an Act - i.e. a law, it must apply to all products.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
If 'QWERTY' is an English keyboard, what language is 'WYSIWYG' for?

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Re: [PSES] German Product Safety Act (ProdSG) - Label requirement

[John Woodgate]

In message 
<72b8947772cf0948adaa9853631663fb6477498...@pbi-namsg-02.mgdpbi.global.pv

t>, dated Tue, 28 Feb 2012, Jim Hulbert  writes:

Under the new German Product Safety Act (ProdSG), as of Dec 2011 
consumer products are required to have a label with the name and 
address of the manufacturer (or importer if the manufacturer is outside 
the EU).  Simply providing that information with the operator guide is 
not good enough anymore.  Does this new requirement apply only to 
products that have the GS certification mark, or does it apply to all 
consumer products?


If it's an Act - i.e. a law, it must apply to all products.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
If 'QWERTY' is an English keyboard, what language is 'WYSIWYG' for?

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Re: [PSES] R&TTE compliance test reports

[Thomas Cokenias]

Hi Scott,

Not sure if this answers your question,   but you MUST use a Notified Body if 
you test to a standard that has not been harmonized as evidenced by being 
published in the Official Journal of the EU.

If you do  test to a standard that is indeed harmonized and published in the 
OJ, then you are not required to get a NB expert opinion, and as others have 
posted, you do not need to use an accredited test lab for your tests either, as 
long as you use test methods called out by the standards and your equipment and 
procedures can meet the measurement  uncertainty limits published therein.  
This means you can do tests at your location if you already have the equipment.

best regards

Tom Cokenias
T.N. Cokenias Consulting
P.O. Box 1086
El Granada CA 94018


On Feb 28, 2012, at 8:07 AM, Scott Xe wrote:

>> I notice that some compliance reports of R&TTE are reviewed by a notified 
>> body while some are issued by an accredited laboratory only.  Can someone 
>> advise if they have different purposes or requirements.
>> 
>> Thanks and regards,
>> 
>> Scott
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[PSES] AW: German Product Safety Act (ProdSG) - Label requirement

[Michael Loerzer]

Jim,

 

I send my answer tomorrow. 

 

 

 

Best regards

 

Dipl.-Ing. Michael Loerzer

Managing Director
Regulatory Affairs Specialist

 

Das neue Buch zum Thema "Product Compliance":
http://www.beuth.de/de/artikel/produktkonformitaet (Produktkonformität,
Prozesse, Risikomanagement, CE-Kennzeichnung, Fallbeispiele für
Geschäftsführung, Konstruktion, Normenabteilung, Vertrieb, Einkauf,
Produktion, QM)

 

_

Globalnorm GmbH

Alt-Moabit 94

10559 Berlin

 

Fon +49 30 3229027-51

Mobile +49 170 3229027

Fax +49 30 3229027-59

Mailmichael.loer...@globalnorm.de

 

  www.globalnorm.de

  www.globalnorm.ca

  www.product-compliance.com

 

_

Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin

Geschäftsführer: Dipl.-Ing. Michael Loerzer

Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448

 

Von: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Im Auftrag von Jim Hulbert
Gesendet: Dienstag, 28. Februar 2012 21:40
An: EMC-PSTC (emc-p...@ieee.org)
Betreff: German Product Safety Act (ProdSG) - Label requirement

 

Under the new German Product Safety Act (ProdSG), as of Dec 2011 consumer
products are required to have a label with the name and address of the
manufacturer (or importer if the manufacturer is outside the EU).  Simply
providing that information with the operator guide is not good enough
anymore.  Does this new requirement apply only to products that have the GS
certification mark, or does it apply to all consumer products?

 

Jim Hulbert

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[PSES] Japanese Consultant

[Michael Loerzer]

Hi,

 

for a regulatory compliance project we are looking  for a Japanese
Consultant (native speaker) which is familiar with Japanese ESH/HSE
requirements and regulatory machine safety requirements. You can contact me
offline.

 

Best regards

 

Dipl.-Ing. Michael Loerzer

Managing Director
Regulatory Affairs Specialist

 

 

_

Globalnorm GmbH

Alt-Moabit 94

10559 Berlin

 

Fon +49 30 3229027-51

Mobile +49 170 3229027

Fax +49 30 3229027-59

Mail 
michael.loer...@globalnorm.de

 

  www.globalnorm.de

  www.globalnorm.ca

  www.product-compliance.com

 

_

Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin

Geschäftsführer: Dipl.-Ing. Michael Loerzer

Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448

 


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Re: [PSES] R&TTE compliance test reports

[Nick Williams]

On 28 Feb 2012, at 17:11, Amund Westin wrote:

> My input on this issue:
>  
> · Notified Body = Appointed by authorities for testing / 
> certification according to an EU directive
> · Accredited laboratory = Fulfil ISO/IEC 17025 Laboratory 
> Accreditation (criteria for laboratories to demonstrate the technical 
> competence to carry out specific test methods)

Correct. 


>  
> I assume that a Notified body must also be an Accredited laboratory, but not 
> visa versa.

Not necessarily. The requirement for appointment as a Notified Body is to have 
the appropriate competence to make judgements about whether or not a product 
complies with a particular Directive's essential requirements (as well as 
certain other administrative requirements such as independence from the 
manufacturer of the products they are auditing, and appropriate indemnity 
insurance). There is no specific requirement for an NB to be accredited as a 
test lab, although they frequently are. 

Nick. 



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Re: [PSES] Consumer Equipment CS

[Don_Borowski]

Seems to me that it depends on the type of power supply in the equipment. 
Just about everything these days uses a switching power supply. Given 
that, the next question is whether it is harmonic/power factor corrected 
or not. 

If not, and the input to the power supply is simply a bridge rectifier 
into the energy storage capacitor (first hitting the conducted emissions 
components of course), then the power supply will be very tolerant of the 
waveform, just conducting on the peaks to charge the energy storage cap. 
These power supplies are perfectly happy running on DC as well, though 
they then may fail conducted emissions.

The ones with harmonic/power factor correction are probably more picky 
about their power. They are certainly tolerant of somewhat clipped AC 
waveforms one sees in places where there are lots of switching power 
supplies without harmonic/power factor correction. Seems to me they should 
be happy running on DC as well. But they may not be happy with waveforms 
with lots of edges on them, they type sometimes used to drive induction 
motors.

Cheers,

Don Borowski
EMC Compliance Engineer
Schweitzer Engineering Labs
Pullman, WA, USA



From:   "Ed Price" 
To: 
Date:   02/28/2012 09:13 AM
Subject:Consumer Equipment CS
Sent by:emc-p...@ieee.org



I have a personal question about the ruggedness of consumer entertainment 
equipment to powerline distortion, and I would like to hear any thoughts 
you might have about this.
 
The potential victims are 120 VAC powered televisions, radios, disk 
players, computers, etc. The environment is a recreational vehicle which 
uses an inverter to create 120 VAC from onboard batteries.
 
In current practice, inverters fall into two categories; very expensive 
?pure? sine wave and less expensive ?modified? sine wave output. I can 
understand ?pure? as being relatively clean, but ?modified? is a very 
subjective term which the inverter manufacturers don?t seem willing to 
define.
 
First, is there some definition of just how much distortion is allowed for 
the category of ?modified? sine wave? And second, has anyone done any 
examination of typical consumer electronic equipment to determine 
susceptibility to ?modified? sine wave power? Could we say that compliance 
with typical EN CS requirements would be good enough to ensure operation 
in the ?modified? sine wave power environment?
 
Thanks in advance!
 
Ed Price
El Cajon, CA
USA

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[PSES] SV: [PSES] R&TTE compliance test reports

[Amund Westin]

My input on this issue:

 

. Notified Body = Appointed by authorities for testing /
certification according to an EU directive

. Accredited laboratory = Fulfil ISO/IEC 17025 Laboratory
Accreditation (criteria for laboratories to demonstrate the technical
competence to carry out specific test methods)

 

I assume that a Notified body must also be an Accredited laboratory, but not
visa versa.

 

Best regards

Amund

 

 

Fra: Michael Derby [mailto:micha...@acbcert.com] 
Sendt: 28. februar 2012 17:27
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] R&TTE compliance test reports

 

If the tests are all done to a harmonised standard (standard fully applied,
and passes), then there's no need to go to a Notified Body.

(You can, if you wish to, but there's no need to)

 

If you can't or don't fully apply a harmonised standard, then you must go to
a Notified Body for their opinion.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE compliance test reports

 

I notice that some compliance reports of R&TTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

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Re: [PSES] Consumer Equipment CS

[Cortland Richmond]

No we can't. It's not a modified SINE wave; that's just salesmanship, 
Ed.  It's more like 50% duty cycle bipolar pulses.


The far from technical Mr. Barney  (AKA Google[tm]) leads me to 
http://www.rvtechlibrary.com/electrical/sinewave.htm:


quote:
... Desktop computers are not in the same category though and you will 
probably smoke them pretty quick. Modified sine wave inverters will also 
generate RF noise in the line so ...

:end quote

Did you see the waveform on that site? What's allowed? Whatever the 
consumer will fall for.


For what it is worth, my radio backup power is 200AH of deep cycle 
battery and a 400W pure sine wave inverter.  I got a 600 watt pure sine 
wave inverter to run my mobile EMC stuff.  They're not terribly 
expensive unless the gold-anodized standard is blister-pack junk.



Cortland Richmond
KA5S

On 2/28/2012 1210, Ed Price wrote:
*...**First, is there some definition of just how much distortion is 
allowed for the category of "modified" sine wave? And second, has 
anyone done any examination of typical consumer electronic equipment 
to determine susceptibility to "modified" sine wave power? Could we 
say that compliance with typical EN CS requirements would be good 
enough to ensure operation in the "modified" sine wave power environment?*



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Re: [PSES] R&TTE compliance test reports

[Michael Derby]

Hello Amund.

 

No, there's no requirement for a Notified Body to be associated with a test
laboratory.

 

Presently, there's no requirement for a Notified Body to be accredited under
the R&TTE Directive.. Although each nation typically does have an
accreditation requirement before submitting Notified Body applications to
the European Commission.   I hope that makes sense.

For example, a company in the USA wishing to act as a Notified Body would
have to apply through NIST, who would then assess their ability to do it
through accreditation etc., even though the Directive does not mandate it.

 

Under the NLF re-cast, this will change and I suspect the accreditation for
a Notified Body would be to something like Guide 65.

 

The R&TTE Directive is due to be included in the NLF changes but it's not
being grouped in the 'omnibus re-cast list' of Directives because the R&TTE
Directive is also actually being re-written for technical changes.

 

Directives like the EMC Directive are just being 're-cast' for the NLF and
should therefore not include any technical changes; whereas the R&TTE
Directive is actually being re-written and will certainly contain some
technical and administrative changes.

 

I'm sure I'll get corrected on some of my political terminology details here
but I hope the general idea makes sense.

 

Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 28 February 2012 17:11
To: Michael Derby; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] R&TTE compliance test reports

 

My input on this issue:

 

. Notified Body = Appointed by authorities for testing /
certification according to an EU directive

. Accredited laboratory = Fulfil ISO/IEC 17025 Laboratory
Accreditation (criteria for laboratories to demonstrate the technical
competence to carry out specific test methods)

 

I assume that a Notified body must also be an Accredited laboratory, but not
visa versa.

 

Best regards

Amund

 

 

Fra: Michael Derby [mailto:micha...@acbcert.com] 
Sendt: 28. februar 2012 17:27
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] R&TTE compliance test reports

 

If the tests are all done to a harmonised standard (standard fully applied,
and passes), then there's no need to go to a Notified Body.

(You can, if you wish to, but there's no need to)

 

If you can't or don't fully apply a harmonised standard, then you must go to
a Notified Body for their opinion.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE compliance test reports

 

I notice that some compliance reports of R&TTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

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[PSES] Consumer Equipment CS

[Ed Price]

I have a personal question about the ruggedness of consumer entertainment
equipment to powerline distortion, and I would like to hear any thoughts you
might have about this.

 

The potential victims are 120 VAC powered televisions, radios, disk players,
computers, etc. The environment is a recreational vehicle which uses an
inverter to create 120 VAC from onboard batteries.

 

In current practice, inverters fall into two categories; very expensive
"pure" sine wave and less expensive "modified" sine wave output. I can
understand "pure" as being relatively clean, but "modified" is a very
subjective term which the inverter manufacturers don't seem willing to
define.

 

First, is there some definition of just how much distortion is allowed for
the category of "modified" sine wave? And second, has anyone done any
examination of typical consumer electronic equipment to determine
susceptibility to "modified" sine wave power? Could we say that compliance
with typical EN CS requirements would be good enough to ensure operation in
the "modified" sine wave power environment?

 

Thanks in advance!

 

Ed Price

El Cajon, CA

USA

 


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Re: [PSES] R&TTE compliance test reports

[Brian Oconnell]

The original 2010 proposals were to include the R&TTE in the NLF as a
re-cast directive. I cannot find any recent activity on this. Any
information if NLF will affect acceptance of these self-generated reports?

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Charlie
Blackham
Sent: Tuesday, February 28, 2012 8:51 AM
To: Scott Xe; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: R&TTE compliance test reports

Scott

Also - as a manufacturer, there is nothing to stop you performing your own
tests - there is no mandatory requirement to use an accredited lab.

If you're not using an accredited Lab and need a Notified Body opinion -
talk to them first about how you will demonstrate suitable competence and
traceability.

Regards
Charlie

From: Scott Xe [mailto:scott...@gmail.com]
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE compliance test reports

I notice that some compliance reports of R&TTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

-

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Re: [PSES] R&TTE compliance test reports

[Charlie Blackham]

Scott

Also - as a manufacturer, there is nothing to stop you performing your own 
tests - there is no mandatory requirement to use an accredited lab.

If you're not using an accredited Lab and need a Notified Body opinion - talk 
to them first about how you will demonstrate suitable competence and 
traceability.

Regards
Charlie

From: Scott Xe [mailto:scott...@gmail.com]
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE compliance test reports

I notice that some compliance reports of R&TTE are reviewed by a notified body 
while some are issued by an accredited laboratory only.  Can someone advise if 
they have different purposes or requirements.

Thanks and regards,

Scott
-


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Re: [PSES] R&TTE compliance test reports

[Michael Derby]

If the tests are all done to a harmonised standard (standard fully applied,
and passes), then there's no need to go to a Notified Body.

(You can, if you wish to, but there's no need to)

 

If you can't or don't fully apply a harmonised standard, then you must go to
a Notified Body for their opinion.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 28 February 2012 16:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] R&TTE compliance test reports

 

I notice that some compliance reports of R&TTE are reviewed by a notified
body while some are issued by an accredited laboratory only.  Can someone
advise if they have different purposes or requirements.

Thanks and regards,

Scott

-


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Re: [PSES] GPS Receivers

[Michael Derby]

Hi Steve,

 

If it's a GPS Receiver that is also located with (for example) a Bluetooth
transmitter, then you could still assess the Bluetooth transmitter to EN 300
328 and EN 301 489-17, then the GPS receiver to EN 300 440 and EN 301 489-3.

 

The comment in TGN 16 comes from the type of GPS equipment which also has a
satellite transmitter included.   In such a case, you might consider using
something like EN 300 441 and EN 401 489-19.

 

I hope that makes sense?

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Steve O'Steen [mailto:steve.ost...@acstestlab.com] 
Sent: 28 February 2012 16:04
To: Michael Derby; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] GPS Receivers

 

Michael,

 

After reviewing the TGN16 a little closer, I noticed the statement below:

 

This Guidance applies to receive-only equipment.  Where GPS/GNSS or other 

receivers are combined with other radio equipment, different principles may
apply.

 

So, back to my question regarding multi-radio devices, is there another
guide to address that equipment or could TGN16 still be applied?

 

Best regards,

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com  

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

CONFIDENTIAL  

This e-mail and any attachments may contain information which is
confidential, proprietary, privileged or otherwise protected by law. The
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From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Tuesday, February 28, 2012 10:15 AM
To: Steve O'Steen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] GPS Receivers

 

Hello Steve,

 

It's not a broadcast receiver and therefore the R&TTE Directive does apply.

 

I've seen people use all sorts of standards in the past but the basic
requirement is really going to be to check the receiver emissions (article
3.2 of the Directive) and also check it has good EMC performance (article
3.1b of the Directive).   Of course, safety too (article 3.1a)

 

Most people recommend use of simply EN 300 440 (assuming it's a 1.5 GHz
device) and then do the EMC testing to EN 301 489-3.   (I'm not sure if
Space is really 'short range' but the tests will do)

 

At the R&TTECA (R&TTE Notified Body group) we wrote the following guidance..

http://rtteca.com/TGN16.pdf

I hope it's useful.

 

For the EN 300 440 tests, most people just test the radiated emissions of
the receiver.   (For example, the sat-nav in a car or on a phone).

The only other thing to note is that if you happen to claim your GPS
receiver is part of a critical lifesaving system that relies on the GPS
working, then you could start considering it to be a different Class of
receiver within EN 300 440.

 

As a receive only device, it's Class 1.   (No Alert Symbol. unless of course
there's a Class 2 transmitter in with it)

 

As for multi-radio equipment.. It's likely that the GPS will be on during
tests of other features, so you may be able to save time and effort by
monitoring/exercising both.

 

I hope this helps,

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Steve O'Steen [mailto:steve.ost...@acstestlab.com] 
Sent: 28 February 2012 14:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] GPS Receivers

 

All,

 

I would be interested in all opinions regarding the compliance requirements
for a GPS receiver.  Annex I, Item 4 excludes all sound and TV broadcast
receivers from the R&TTE Directive.

 

 

Assuming the R&TTE Directive applies, which one of the Product Specific
Standards would be most applicable?  

 

If the GPS receiver were part of a multi-radio equipment, would that affect
the selection of the Product Specific Standard focused on the GPS?

 

Are there other exclusions to the R&TTE Directive I'm not aware of that
would default GPS to the EMC Directive or at least to the EN55022/E55024,
which is harmonized in the R&TTE Directive as well?

 

Best regards, 

 

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com  

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

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confidential, proprietary, privileged or otherwise protected by law. The
information is solely intended for the named addressee (or a person
responsible for delivering it 

[PSES] R&TTE compliance test reports

[Scott Xe]

> I notice that some compliance reports of R&TTE are reviewed by a notified body
> while some are issued by an accredited laboratory only.  Can someone advise if
> they have different purposes or requirements.
> 
> Thanks and regards,
> 
> Scott


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Re: [PSES] GPS Receivers

[Steve O'Steen]

Michael,

 

After reviewing the TGN16 a little closer, I noticed the statement
below:

 

This Guidance applies to receive-only equipment.  Where GPS/GNSS or
other 

receivers are combined with other radio equipment, different principles
may apply.

 

So, back to my question regarding multi-radio devices, is there another
guide to address that equipment or could TGN16 still be applied?

 

Best regards,

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com  

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

CONFIDENTIAL  

This e-mail and any attachments may contain information which is
confidential, proprietary, privileged or otherwise protected by law. The
information is solely intended for the named addressee (or a person
responsible for delivering it to the addressee). If you are not the
intended recipient of this message, you are not authorized to read,
print, retain, copy or disseminate this message or any part of it. If
you have received this e-mail in error, please notify the sender
immediately by return e-mail and delete it from your computer.



From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Tuesday, February 28, 2012 10:15 AM
To: Steve O'Steen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] GPS Receivers

 

Hello Steve,

 

It's not a broadcast receiver and therefore the R&TTE Directive does
apply.

 

I've seen people use all sorts of standards in the past but the basic
requirement is really going to be to check the receiver emissions
(article 3.2 of the Directive) and also check it has good EMC
performance (article 3.1b of the Directive).   Of course, safety too
(article 3.1a)

 

Most people recommend use of simply EN 300 440 (assuming it's a 1.5 GHz
device) and then do the EMC testing to EN 301 489-3.   (I'm not sure if
Space is really 'short range' but the tests will do)

 

At the R&TTECA (R&TTE Notified Body group) we wrote the following
guidance..

http://rtteca.com/TGN16.pdf

I hope it's useful.

 

For the EN 300 440 tests, most people just test the radiated emissions
of the receiver.   (For example, the sat-nav in a car or on a phone).

The only other thing to note is that if you happen to claim your GPS
receiver is part of a critical lifesaving system that relies on the GPS
working, then you could start considering it to be a different Class of
receiver within EN 300 440.

 

As a receive only device, it's Class 1.   (No Alert Symbol... unless of
course there's a Class 2 transmitter in with it)

 

As for multi-radio equipment It's likely that the GPS will be on
during tests of other features, so you may be able to save time and
effort by monitoring/exercising both.

 

I hope this helps,

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Steve O'Steen [mailto:steve.ost...@acstestlab.com] 
Sent: 28 February 2012 14:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] GPS Receivers

 

All,

 

I would be interested in all opinions regarding the compliance
requirements for a GPS receiver.  Annex I, Item 4 excludes all sound and
TV broadcast receivers from the R&TTE Directive.

 

 

Assuming the R&TTE Directive applies, which one of the Product Specific
Standards would be most applicable?  

 

If the GPS receiver were part of a multi-radio equipment, would that
affect the selection of the Product Specific Standard focused on the
GPS?

 

Are there other exclusions to the R&TTE Directive I'm not aware of that
would default GPS to the EMC Directive or at least to the
EN55022/E55024, which is harmonized in the R&TTE Directive as well?

 

Best regards, 

 

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com  

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

CONFIDENTIAL  

This e-mail and any attachments may contain information which is
confidential, proprietary, privileged or otherwise protected by law. The
information is solely intended for the named addressee (or a person
responsible for delivering it to the addressee). If you are not the
intended recipient of this message, you are not authorized to read,
print, retain, copy or disseminate this message or any part of it. If
you have received this e-mail in error, please notify the sender
immediately by return e-mail and delete it from your computer.

 

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Re: [PSES] GPS Receivers

[Steve O'Steen]

All,

 

Thanks for the replies which have been consistent across the board
recommending EN 301 489-3 for the EMC portion.  This is what I was
leaning toward as well, even without the knowledge of TGN16 but based
mostly on the scopes of all parts in the EN 301 489 series of standards.
As an option I was also considering the ITE route with an investigation
to EN55022/EN55024 with justification from ETSI TR 102 070-1.  

Thanks for providing a link to TNG16, this is exactly what I was looking
for.

 

Best regards,

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com  

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

CONFIDENTIAL  

This e-mail and any attachments may contain information which is
confidential, proprietary, privileged or otherwise protected by law. The
information is solely intended for the named addressee (or a person
responsible for delivering it to the addressee). If you are not the
intended recipient of this message, you are not authorized to read,
print, retain, copy or disseminate this message or any part of it. If
you have received this e-mail in error, please notify the sender
immediately by return e-mail and delete it from your computer.



From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Tuesday, February 28, 2012 10:15 AM
To: Steve O'Steen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] GPS Receivers

 

Hello Steve,

 

It's not a broadcast receiver and therefore the R&TTE Directive does
apply.

 

I've seen people use all sorts of standards in the past but the basic
requirement is really going to be to check the receiver emissions
(article 3.2 of the Directive) and also check it has good EMC
performance (article 3.1b of the Directive).   Of course, safety too
(article 3.1a)

 

Most people recommend use of simply EN 300 440 (assuming it's a 1.5 GHz
device) and then do the EMC testing to EN 301 489-3.   (I'm not sure if
Space is really 'short range' but the tests will do)

 

At the R&TTECA (R&TTE Notified Body group) we wrote the following
guidance..

http://rtteca.com/TGN16.pdf

I hope it's useful.

 

For the EN 300 440 tests, most people just test the radiated emissions
of the receiver.   (For example, the sat-nav in a car or on a phone).

The only other thing to note is that if you happen to claim your GPS
receiver is part of a critical lifesaving system that relies on the GPS
working, then you could start considering it to be a different Class of
receiver within EN 300 440.

 

As a receive only device, it's Class 1.   (No Alert Symbol... unless of
course there's a Class 2 transmitter in with it)

 

As for multi-radio equipment It's likely that the GPS will be on
during tests of other features, so you may be able to save time and
effort by monitoring/exercising both.

 

I hope this helps,

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Steve O'Steen [mailto:steve.ost...@acstestlab.com] 
Sent: 28 February 2012 14:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] GPS Receivers

 

All,

 

I would be interested in all opinions regarding the compliance
requirements for a GPS receiver.  Annex I, Item 4 excludes all sound and
TV broadcast receivers from the R&TTE Directive.

 

 

Assuming the R&TTE Directive applies, which one of the Product Specific
Standards would be most applicable?  

 

If the GPS receiver were part of a multi-radio equipment, would that
affect the selection of the Product Specific Standard focused on the
GPS?

 

Are there other exclusions to the R&TTE Directive I'm not aware of that
would default GPS to the EMC Directive or at least to the
EN55022/E55024, which is harmonized in the R&TTE Directive as well?

 

Best regards, 

 

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com  

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

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This e-mail and any attachments may contain information which is
confidential, proprietary, privileged or otherwise protected by law. The
information is solely intended for the named addressee (or a person
responsible for delivering it to the addressee). If you are not the
intended recipient of this message, you are not authorized to read,
print, retain, copy or disseminate this message or any part of it. If
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Re: [PSES] GPS Receivers

[Michael Derby]

Hello Steve,

 

It's not a broadcast receiver and therefore the R&TTE Directive does apply.

 

I've seen people use all sorts of standards in the past but the basic
requirement is really going to be to check the receiver emissions (article
3.2 of the Directive) and also check it has good EMC performance (article
3.1b of the Directive).   Of course, safety too (article 3.1a)

 

Most people recommend use of simply EN 300 440 (assuming it's a 1.5 GHz
device) and then do the EMC testing to EN 301 489-3.   (I'm not sure if
Space is really 'short range' but the tests will do)

 

At the R&TTECA (R&TTE Notified Body group) we wrote the following guidance..

http://rtteca.com/TGN16.pdf

I hope it's useful.

 

For the EN 300 440 tests, most people just test the radiated emissions of
the receiver.   (For example, the sat-nav in a car or on a phone).

The only other thing to note is that if you happen to claim your GPS
receiver is part of a critical lifesaving system that relies on the GPS
working, then you could start considering it to be a different Class of
receiver within EN 300 440.

 

As a receive only device, it's Class 1.   (No Alert Symbol. unless of course
there's a Class 2 transmitter in with it)

 

As for multi-radio equipment.. It's likely that the GPS will be on during
tests of other features, so you may be able to save time and effort by
monitoring/exercising both.

 

I hope this helps,

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Steve O'Steen [mailto:steve.ost...@acstestlab.com] 
Sent: 28 February 2012 14:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] GPS Receivers

 

All,

 

I would be interested in all opinions regarding the compliance requirements
for a GPS receiver.  Annex I, Item 4 excludes all sound and TV broadcast
receivers from the R&TTE Directive.

 

 

Assuming the R&TTE Directive applies, which one of the Product Specific
Standards would be most applicable?  

 

If the GPS receiver were part of a multi-radio equipment, would that affect
the selection of the Product Specific Standard focused on the GPS?

 

Are there other exclusions to the R&TTE Directive I'm not aware of that
would default GPS to the EMC Directive or at least to the EN55022/E55024,
which is harmonized in the R&TTE Directive as well?

 

Best regards, 

 

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com  

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

CONFIDENTIAL  

This e-mail and any attachments may contain information which is
confidential, proprietary, privileged or otherwise protected by law. The
information is solely intended for the named addressee (or a person
responsible for delivering it to the addressee). If you are not the intended
recipient of this message, you are not authorized to read, print, retain,
copy or disseminate this message or any part of it. If you have received
this e-mail in error, please notify the sender immediately by return e-mail
and delete it from your computer.

 

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This message is from the IEEE Product Safety Engineering Society emc-pstc 
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formats), large files, etc.

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Re: [PSES] GPS Receivers

[Charlie Blackham]

Steve

GPS receivers are covered by R&TTE Directive as they are "non-broadcast" 
receive only equipment - have a look at R&TTE Compliance Association Guidance 
Note on this:
http://www.rtteca.com/TGN16.pdf

The most suitable standards are EN 301 489-3 for EMC and EN 300 440-2 for RF 
Spectrum.

Regards
Charlie

From: Steve O'Steen [mailto:steve.ost...@acstestlab.com]
Sent: 28 February 2012 14:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] GPS Receivers

All,

I would be interested in all opinions regarding the compliance requirements for 
a GPS receiver.  Annex I, Item 4 excludes all sound and TV broadcast receivers 
from the R&TTE Directive.


Assuming the R&TTE Directive applies, which one of the Product Specific 
Standards would be most applicable?

If the GPS receiver were part of a multi-radio equipment, would that affect the 
selection of the Product Specific Standard focused on the GPS?

Are there other exclusions to the R&TTE Directive I'm not aware of that would 
default GPS to the EMC Directive or at least to the EN55022/E55024, which is 
harmonized in the R&TTE Directive as well?

Best regards,


Steve O'Steen
EMC Director
Advanced Compliance Solutions, Inc.
sost...@acstestlab.com
770-831-8048 ext. 210
www.acstestlab.com

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

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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://listserv.ieee.org/request/user-guide.html
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For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

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[PSES] GPS Receivers

[Steve O'Steen]

All,

 

I would be interested in all opinions regarding the compliance
requirements for a GPS receiver.  Annex I, Item 4 excludes all sound and
TV broadcast receivers from the R&TTE Directive.

 

 

Assuming the R&TTE Directive applies, which one of the Product Specific
Standards would be most applicable?  

 

If the GPS receiver were part of a multi-radio equipment, would that
affect the selection of the Product Specific Standard focused on the
GPS?

 

Are there other exclusions to the R&TTE Directive I'm not aware of that
would default GPS to the EMC Directive or at least to the
EN55022/E55024, which is harmonized in the R&TTE Directive as well?

 

Best regards, 

 

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com  

 

ATLANTA, GA   -   MELBOURNE, FL   -   BOCA RATON, FL

 

CONFIDENTIAL  

This e-mail and any attachments may contain information which is
confidential, proprietary, privileged or otherwise protected by law. The
information is solely intended for the named addressee (or a person
responsible for delivering it to the addressee). If you are not the
intended recipient of this message, you are not authorized to read,
print, retain, copy or disseminate this message or any part of it. If
you have received this e-mail in error, please notify the sender
immediately by return e-mail and delete it from your computer.

 


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discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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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://listserv.ieee.org/request/user-guide.html
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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Mike Cantwell 

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David Heald: