Re: [PSES] Integrating radio COSTs into other equipment
Hi Lauren, Sorry for the quick mail and lack of exact references but I'm in a rush today.. Firstly, remember that there is no RTTE certified. A product (like a wireless keyboard) might be CE Marked with a DoC based on the intended use. If you incorporate that product into another product.. You might have created a whole new product, which might need CE Marking. Or, you might just be creating a system; such as the Laptop/Monitor/Printer/Keyboard/Mouse octopus that I have on my desk before me, with the device being used in its intended use. If you look at the annexes at the back of EN 301 489-1 V1.9.2, you'll find all sorts of useful guidance on combining equipment. That's where I'd look first. For example, we often see wireless devices with a USB connector. By itself, many of the EMC equipment might not be applicable (less than 3m long cables, etc.), but EN 301 489-1 confirms which tests should be performed with that device connected to a typical host (such as a laptop), which could make the tests suddenly applicable (I think conducted RF immunity, etc). For your wireless keyboard issue, you really need to consider if you are just selling a system with the keyboard used correctly as a part of it; or if you have created a whole new product. I know that Charlie Blackham is on this reflector and I'll bet he could give a good answer about the 'larger scale' compliance management of complex systems. :-) Sorry for my lack of time today! Michael. -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: 12 May 2015 00:11 To: Michael Derby; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] Integrating radio COSTs into other equipment Michael, Do you think this applies to the case for installing a finished product? For example if I make and industrial machine and install a wireless keyboard that is already RTTE certified, have I created a new item (i.e. the machine) that must be assessed for RTTE conformance? I think the common sense answer is 'no', but Commission and ETSI guidance does not seem to address this scenario. Regards, Lauren Crane KLA-Tencor -Original Message- From: Michael Derby [mailto:micha...@acbcert.com] Sent: Monday, May 11, 2015 6:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Integrating radio COSTs into other equipment Hello Amund, This is a general reply about installing CE Marked radio modules into host products.. The important thing to remember is that there no certification process under the RTTE Directive and also no modular approvals. Anyone installing the module into a product becomes responsible for the compliance of the overall product, with the RTTE Directive. Radio, EMC, Safety. It's possible to imagine cases where the test results for the radio performance (made by the module manufacturer, on the module) could be used to show compliance of the overall final product. For example, if the module is installed ok in accordance with manufacturer's instructions, you could imagine that the power, frequency, etc., should not be changed. Many module installers rely on most of the tests in the radio test report of the module for their compliance to Article 3.2 of the RTTE Directive. For radiated emissions of the transmitter module (also Article 3.2) in the final product, I know that most module manufacturers recommend that the final host product should be re-tested and I certainly think this is a good recommendation. Anyone who has tested emissions of final products with modules installed will know that the emissions from the module can sometimes fail when installed in a host. For EMC and Safety, it is very difficult (impossible?) to imagine that any tests of the module might be representative of the radio's performance inside a host; so the host should really be treated as a new product for testing to standards like EN 301 489-7, EN 301 489-24, product safety, etc. Finally; I see an incredibly wide variation in testing approach from module manufacturers for CE Marking a module. Just because it is CE Marked, does not mean they have fully tested it for every possible installation! This link is very useful.. http://www.rtteca.com/TGN01%20-%20May%202013.pdf Michael. -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: 11 May 2015 07:55 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Integrating radio COSTs into other equipment RTTE approved 3G GSM module (EN 301 511) is integrated into an EN 61326-1 measurement product. Maybe this call for new radio tests such as radiated spurious emission. Anyone have experience about the consequences integrating such radio COTS? Regards Amund - 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 emc-p...@ieee.org All emc-pstc postings are archived and
[PSES] SV: [PSES] Integrating radio COSTs into other equipment
Thanks, Michael Let's say a 3G module according to ETSI EN301 511. The module is tested stand-alone and fulfills the specs. Then build into the final product and re-tested. How can the final product fail according to ETSI EN301 511, when the module itself complies? I can see to possibilities: - The final product has another type of antenna compared to antenna used during module stand-alone testing - Conducted and radiated emission from the aux. equipment in the final product are coupled into the radio module itself and generates unwanted spurious in the 3G signal. Could it be other reasons, which justifies re-testing on the final product? Amund -Opprinnelig melding- Fra: Michael Derby [mailto:micha...@acbcert.com] Sendt: 11. mai 2015 13:10 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] Integrating radio COSTs into other equipment Hello Amund, This is a general reply about installing CE Marked radio modules into host products.. The important thing to remember is that there no certification process under the RTTE Directive and also no modular approvals. Anyone installing the module into a product becomes responsible for the compliance of the overall product, with the RTTE Directive. Radio, EMC, Safety. It's possible to imagine cases where the test results for the radio performance (made by the module manufacturer, on the module) could be used to show compliance of the overall final product. For example, if the module is installed ok in accordance with manufacturer's instructions, you could imagine that the power, frequency, etc., should not be changed. Many module installers rely on most of the tests in the radio test report of the module for their compliance to Article 3.2 of the RTTE Directive. For radiated emissions of the transmitter module (also Article 3.2) in the final product, I know that most module manufacturers recommend that the final host product should be re-tested and I certainly think this is a good recommendation. Anyone who has tested emissions of final products with modules installed will know that the emissions from the module can sometimes fail when installed in a host. For EMC and Safety, it is very difficult (impossible?) to imagine that any tests of the module might be representative of the radio's performance inside a host; so the host should really be treated as a new product for testing to standards like EN 301 489-7, EN 301 489-24, product safety, etc. Finally; I see an incredibly wide variation in testing approach from module manufacturers for CE Marking a module. Just because it is CE Marked, does not mean they have fully tested it for every possible installation! This link is very useful.. http://www.rtteca.com/TGN01%20-%20May%202013.pdf Michael. -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: 11 May 2015 07:55 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Integrating radio COSTs into other equipment RTTE approved 3G GSM module (EN 301 511) is integrated into an EN 61326-1 measurement product. Maybe this call for new radio tests such as radiated spurious emission. Anyone have experience about the consequences integrating such radio COTS? Regards Amund - 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 emc-p...@ieee.org 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 sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - 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 emc-p...@ieee.org 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 sdoug...@ieee.org Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org
Re: [PSES] SV: [PSES] Integrating radio COSTs into other equipment
Hi Amund, I think that one of the main things is that the radiated emissions test of the module is not always representative of the emissions from the module in the host. Imagine a little module. Maybe 5cm x 3cm, or less! Some modules are simply chips! Signals flowing around on it, but incapable of successfully radiating off of such a little device. Radiated emissions from that little module might be very low. (a good chance to see a spectrum analyser noise floor) Now put that little module into a host, cables everywhere, cables running over/by the module; the module connected to the host board. Who knows where those little signals are going and who knows how long those cables are. ..the harmonics from that module can suddenly look different! I'm not saying it's guaranteed to be a huge interference risk; but I am saying that the person putting the final product onto the market does not know the emissions profile from their device. I hope this helps. Michael. -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: 12 May 2015 10:33 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] SV: [PSES] Integrating radio COSTs into other equipment Thanks, Michael Let's say a 3G module according to ETSI EN301 511. The module is tested stand-alone and fulfills the specs. Then build into the final product and re-tested. How can the final product fail according to ETSI EN301 511, when the module itself complies? I can see to possibilities: - The final product has another type of antenna compared to antenna used during module stand-alone testing - Conducted and radiated emission from the aux. equipment in the final product are coupled into the radio module itself and generates unwanted spurious in the 3G signal. Could it be other reasons, which justifies re-testing on the final product? Amund -Opprinnelig melding- Fra: Michael Derby [mailto:micha...@acbcert.com] Sendt: 11. mai 2015 13:10 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] Integrating radio COSTs into other equipment Hello Amund, This is a general reply about installing CE Marked radio modules into host products.. The important thing to remember is that there no certification process under the RTTE Directive and also no modular approvals. Anyone installing the module into a product becomes responsible for the compliance of the overall product, with the RTTE Directive. Radio, EMC, Safety. It's possible to imagine cases where the test results for the radio performance (made by the module manufacturer, on the module) could be used to show compliance of the overall final product. For example, if the module is installed ok in accordance with manufacturer's instructions, you could imagine that the power, frequency, etc., should not be changed. Many module installers rely on most of the tests in the radio test report of the module for their compliance to Article 3.2 of the RTTE Directive. For radiated emissions of the transmitter module (also Article 3.2) in the final product, I know that most module manufacturers recommend that the final host product should be re-tested and I certainly think this is a good recommendation. Anyone who has tested emissions of final products with modules installed will know that the emissions from the module can sometimes fail when installed in a host. For EMC and Safety, it is very difficult (impossible?) to imagine that any tests of the module might be representative of the radio's performance inside a host; so the host should really be treated as a new product for testing to standards like EN 301 489-7, EN 301 489-24, product safety, etc. Finally; I see an incredibly wide variation in testing approach from module manufacturers for CE Marking a module. Just because it is CE Marked, does not mean they have fully tested it for every possible installation! This link is very useful.. http://www.rtteca.com/TGN01%20-%20May%202013.pdf Michael. -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: 11 May 2015 07:55 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Integrating radio COSTs into other equipment RTTE approved 3G GSM module (EN 301 511) is integrated into an EN 61326-1 measurement product. Maybe this call for new radio tests such as radiated spurious emission. Anyone have experience about the consequences integrating such radio COTS? Regards Amund - 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 emc-p...@ieee.org 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/
Re: [PSES] Integrating radio COSTs into other equipment
First, there is no such thing as an RTTE certified device. Second, a module is an apparatus and any apparatus, regardless of where used, is to comply with the associated directives. Third. all device using CE marking, must still comply. If it does not comply in a final configuration, then it does not comply and cannot really be considered properly using CE marking. Thanks Dennis Ward This communication and its attachements contain information from PCTEST Engineering Laboratory, Inc., and is intended for the exclusive use of the recipient(s) named above. It may contain information that is confidential and/or legally privileged. Any unauthorized use that may compromise that confidentiality via distribution or disclosure is prohibited. Please notify the sender immediately if you receive this communication in error, and delete it from your computer system. Usage of PCTEST email addresses for non-business related activities is strictly prohibited. No warranty is made that the e-mail or attachments(s) are free from computer virus or other defect. Thank you. -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: Monday, May 11, 2015 4:11 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Integrating radio COSTs into other equipment Michael, Do you think this applies to the case for installing a finished product? For example if I make and industrial machine and install a wireless keyboard that is already RTTE certified, have I created a new item (i.e. the machine) that must be assessed for RTTE conformance? I think the common sense answer is 'no', but Commission and ETSI guidance does not seem to address this scenario. Regards, Lauren Crane KLA-Tencor -Original Message- From: Michael Derby [mailto:micha...@acbcert.com] Sent: Monday, May 11, 2015 6:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Integrating radio COSTs into other equipment Hello Amund, This is a general reply about installing CE Marked radio modules into host products.. The important thing to remember is that there no certification process under the RTTE Directive and also no modular approvals. Anyone installing the module into a product becomes responsible for the compliance of the overall product, with the RTTE Directive. Radio, EMC, Safety. It's possible to imagine cases where the test results for the radio performance (made by the module manufacturer, on the module) could be used to show compliance of the overall final product. For example, if the module is installed ok in accordance with manufacturer's instructions, you could imagine that the power, frequency, etc., should not be changed. Many module installers rely on most of the tests in the radio test report of the module for their compliance to Article 3.2 of the RTTE Directive. For radiated emissions of the transmitter module (also Article 3.2) in the final product, I know that most module manufacturers recommend that the final host product should be re-tested and I certainly think this is a good recommendation. Anyone who has tested emissions of final products with modules installed will know that the emissions from the module can sometimes fail when installed in a host. For EMC and Safety, it is very difficult (impossible?) to imagine that any tests of the module might be representative of the radio's performance inside a host; so the host should really be treated as a new product for testing to standards like EN 301 489-7, EN 301 489-24, product safety, etc. Finally; I see an incredibly wide variation in testing approach from module manufacturers for CE Marking a module. Just because it is CE Marked, does not mean they have fully tested it for every possible installation! This link is very useful.. http://www.rtteca.com/TGN01%20-%20May%202013.pdf Michael. -Original Message- From: Amund Westin [mailto:am...@westin-emission.no] Sent: 11 May 2015 07:55 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Integrating radio COSTs into other equipment RTTE approved 3G GSM module (EN 301 511) is integrated into an EN 61326-1 measurement product. Maybe this call for new radio tests such as radiated spurious emission. Anyone have experience about the consequences integrating such radio COTS? Regards Amund - 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 emc-p...@ieee.org 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:
