Re: [PSES] RoHS and renewable energy

[Brian O'Connell]

No. Only for panel materials used in the PV film, and is not a system-level 
exemption. By definition, substances and materials specified in the RoHS and 
REACH directives are considered harmful, so no exclusion for materials in other 
stuff.

Can you offer an 'acceptable' rationale in your D of C for the import 
authorities?

Brian


From: Regan Arndt [mailto:re...@empowermicro.com] 
Sent: Friday, February 17, 2017 2:05 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RoHS and renewable energy

Greetings everyone, 

Regarding the RoHS recast directive; DIRECTIVE 2011/65/EU OF THE EUROPEAN 
PARLIAMENT AND OF THE COUNCIL of 8 June 2011, on the restriction of the use of 
certain hazardous substances in electrical and electronic equipment (recast) – 
see attached.

Article 2 states:
Scope

4. This Directive does not apply to:

(i)   photovoltaic panels intended to be used in a system that 
is designed, assembled and installed by professionals for permanent use at a 
defined location to produce energy from solar light for public, commercial, 
industrial and residential applications;

1.   Does anyone know if this includes micro-inverters?  I 
would assume so as the PV module then becomes an ‘AC PV module’ but maybe not 
….. as there are more RoHS concerning components in a micro-inverter than in a 
DC PV module. 

2.   Does this exemption include combiner boxes? Does the 
exemption include String inverters? Rest of the BOS? I would assume so as it 
also states:

(c) equipment which is specifically designed, and is to be installed, as part 
of another type of equipment that is excluded or does not fall within the scope 
of this Directive, which can fulfil its function only if it is part of that 
equipment, and which can be replaced only by the same specifically designed 
equipment;

Most installations do not have such specific restrictions on the usage of which 
inverters are to be used for DC panels, etc.

The directive does mention the following:
(17) The development of renewable forms of energy is one of the Union’s key 
objectives, and the contribution made by renewable energy sources to 
environmental and climate objectives is crucial. Directive 2009/28/EC of the 
European Parliament and of the Council of 23 April 2009 on the promotion of the 
use of energy from renewable sources ( 4 ) recalls that there should be 
coherence between those objectives and other Union environmental legislation. 
Consequently, this Directive should not prevent the development of renewable 
energy technologies that have no negative impact on health and the environment 
and that are sustainable and economically viable.

Can someone interpret the bold underlined statement above? It leads to a vague 
interpretation me thinks.

Thanks in advance.

Regan Arndt

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[PSES] RoHS and renewable energy

[Regan Arndt]

Greetings everyone,

Regarding the RoHS recast directive; DIRECTIVE 2011/65/EU OF THE EUROPEAN 
PARLIAMENT AND OF THE COUNCIL of 8 June 2011, on the restriction of the use of 
certain hazardous substances in electrical and electronic equipment (recast) – 
see attached.


Article 2 states:
Scope

4. This Directive does not apply to:



(i)   photovoltaic panels intended to be used in a system that 
is designed, assembled and installed by professionals for permanent use at a 
defined location to produce energy from solar light for public, commercial, 
industrial and residential applications;


1.   Does anyone know if this includes micro-inverters?  I 
would assume so as the PV module then becomes an ‘AC PV module’ but maybe not 
….. as there are more RoHS concerning components in a micro-inverter than in a 
DC PV module.


2.   Does this exemption include combiner boxes? Does the 
exemption include String inverters? Rest of the BOS? I would assume so as it 
also states:

(c) equipment which is specifically designed, and is to be installed, as part 
of another type of equipment that is excluded or does not fall within the scope 
of this Directive, which can fulfil its function only if it is part of that 
equipment, and which can be replaced only by the same specifically designed 
equipment;

Most installations do not have such specific restrictions on the usage of which 
inverters are to be used for DC panels, etc.


The directive does mention the following:
(17) The development of renewable forms of energy is one of the Union’s key 
objectives, and the contribution made by renewable energy sources to 
environmental and climate objectives is crucial. Directive 2009/28/EC of the 
European Parliament and of the Council of 23 April 2009 on the promotion of the 
use of energy from renewable sources ( 4 ) recalls that there should be 
coherence between those objectives and other Union environmental legislation. 
Consequently, this Directive should not prevent the development of renewable 
energy technologies that have no negative impact on health and the environment 
and that are sustainable and economically viable.

Can someone interpret the bold underlined statement above? It leads to a vague 
interpretation me thinks.

Thanks in advance.

Regan Arndt


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Re: [PSES] EN 55020

[Larry K. Stillings]

Mike,

 

Since both EN 55013 and EN 55020 are not on the harmonized standards
list for the EMCD, my personal opinion is EN 55020 may be used until EN
55035 is adopted, listed in the OJ and provides a date of withdrawal.

 

I understand you are asking about RED here, but there are some issues on
the EMC side that makes it a little challenging to provide a definite
answer, as RED is suppose to be an all encompassing directive for
Radio/EMC/Safety etc. 

 

Fortunately, as has been previously mentioned on this forum, Article 3.1
of the RED provides some wiggle room for EMC and Safety.

 

Right now the only Immunity standards that are to be published by ETSI
under the RED for a device with Bluetooth is EN 301 489-1 V2.1.1 and EN
301 489-17 V3.1.1. So the product would need to be in compliance with
those.

 

I'm sure others here can provide further insight.

Larry K. Stillings
Compliance Worldwide, Inc. 
Test Locally, Sell Globally and Launch Your Products Around the World! 
FCC - Wireless - Telecom - CE Marking - International Approvals -
Product Safety 
357 Main Street
Sandown, NH 03873
(603) 887 3903 Fax 887-6445
www.complianceworldwide.com  

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From: Sundstrom, Mike [mailto:mike.sundst...@garmin.com] 
Sent: Friday, February 17, 2017 3:19 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN 55020

 

Esteemed enlightened colleagues,

Has EN 55020 been given a date of withdrawal?  I ask in relation to RED
(2014-53-EU) for a radio product with AM/FM/Bluetooth(r) ???

 

Thanks,

 

Michael Sundstrom

Garmin Compliance Engineer

(913) 440-1540

KB5UKT

 

"Never give up on a dream just because of the time it will take to
accomplish it.

The time will pass anyway."

Earl Nightingale

 

 




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[PSES] EN 55020

[Sundstrom, Mike]

Esteemed enlightened colleagues,
Has EN 55020 been given a date of withdrawal?  I ask in relation to RED 
(2014-53-EU) for a radio product with AM/FM/Bluetooth(r) ???

Thanks,

Michael Sundstrom
Garmin Compliance Engineer
(913) 440-1540
KB5UKT

"Never give up on a dream just because of the time it will take to accomplish 
it.
The time will pass anyway."
Earl Nightingale




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the intended recipient(s) and contain information that may be Garmin 
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in error, please notify the sender by reply email and delete the message. Any 
disclosure, copying, distribution or use of this communication (including 
attachments) by someone other than the intended recipient is prohibited. Thank 
you.

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Re: [PSES] Conformity assessment under RED

[Dave Heald]

Charlie Blackham just pointed me to EN 301 489-52 - so now I know.
Nevermind!

On Fri, Feb 17, 2017 at 11:18 AM, Dave Heald  wrote:

> Thanks for that clarification - I suppose this might explain why there are
> nof RED updates for EN 301 489-7/-24, but I am of course curious if there
> is more to it (such as if these 2G/3G/LTE EMC standards have migrated to a
> new standard).
>
> Thanks & Best Regards,
> -David
>
> On Wed, Jan 4, 2017 at 6:00 AM, Michael Derby 
> wrote:
>
>> Hi Nick,
>>
>> You are completely correct.
>>
>> Actually, this approach (NB is only needed for deviations in testing to
>> Articles 3.2 and 3.3; but not needed for deviations in testing for 3.1) was
>> apparently the original intention with 1999/5/EC, but it was not correctly
>> or clearly written.   2014/53/EU corrects that.
>>
>> Thanks,
>>
>> Michael.
>>
>>
>>
>> -Original Message-
>> From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
>> Sent: 04 January 2017 12:18
>> To: EMC-PSTC@LISTSERV.IEEE.ORG
>> Subject: [PSES] Conformity assessment under RED
>>
>> Happy New Year, EMC-PSTC listers!
>>
>> 2014/15/EU article 17 separates the conformity assessment procedures for
>> essential requirement 3.1 (safety and EMC) from those which are applied for
>> essential requirements 3.2 and 3.3 (spectrum efficiency and special
>> provisions). Notified Body intervention is required for ER’s 3.2 and 3.3 if
>> the manufacturer has not applied harmonised standards, but no such
>> requirement is applied for ER 3.1.
>>
>> My reading of this is that the manufacturer has complete freedom of
>> approach under RED for safety and EMC compliance in exactly the same way
>> that they do under the LVD and EMC Directive, and can self-certifiy even if
>> they do not apply harmonised standards, irrespective of whether or not they
>> are required to involve a NoBo for compliance with ER’s 3.2 & 3.3.
>>
>> This is not how things worked under 1999/5/EC.
>>
>> Is my interpretation correct, and if not, why not?
>>
>> -
>> 
>> 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.
>>
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>>
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>>
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>>
>> -
>> 
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>> 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:
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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.
>>
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>>
>
>

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Re: [PSES] 2G & 3G/LTE EMC standards under RED - EN 301 489-7/-24 replacements?

[Charlie Blackham]

David

ETSI have taken the opportunity to combine product standards with new numbers 
starting from -50 to be used in conjunction with the new -1.
Have a look at Draft ETSI EN 301 489-52 
V1.1.0
Electromagnetic Compatibility (EMC) standard for radio equipment and services; 
Part 52: Specific conditions for Cellular Communication Mobile and portable 
(UE) radio and ancillary equipment; Harmonised Standard covering the essential 
requirements of article 3.1(b) of Directive 2014/53/EU

Regards
Charlie


Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com
Registered in England and Wales, number 05466247

From: Dave Heald [mailto:emcp...@gmail.com]
Sent: 17 February 2017 18:05
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 2G & 3G/LTE EMC standards under RED - EN 301 489-7/-24 
replacements?

Hi All,
  I have been tracking the standards activity for the RED transition, and there 
are two troubling standards for cellular EMC that do not appear to have new 
versions in process.

These are the EN 301 489-7 (GSM)  and 301 489-24 (3G/LTE) EMC immunity 
standards.

Does anyone know if these requirements have migrated out of the 301 489 series 
to something new, or what the overall status is?
(or possibly the new 301 489-1v2.1.1 standard will *presumably* meet the needs 
of the RED (I think it should be listed in the OJ on 2nd May), and the -7/-24 
standards don't need an update as they only apply test conditions to the -1 
standard?


Any insight on this would be greatly appreciated.

Thanks!
-David Heald

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>

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Re: [PSES] Document and Project Management Systems?

[Dave Heald]

Hi Jamison,
  If you have SAP, presumably you might have a PLM tool like Agile PLM or
some other tool that manages Bills of Material.

I developed a system a while ago that created a sub-BOM of 'fake' items to
capture and track regulatory status.

The top-level sub-BOM was for the regulatory-unique ID (so that it could be
applied to multiple top-level-assemblies that share the same regulatory
approvals but might differ in software loads, plastic colors, or the like).
The next level was countries.
The third level was the various certs for each country.  Revision control
on the attachments allowed multiple attachments to be stored and
maintained.
A spreadsheet template was used to import the BOM structure, which could
then be assigned to the appropriate top-level-assemblies.

As the necessary attachments were collected for each certs, they were moved
to "release' status in the PLM tool.
When all of the certs were at release, the country could be set to
'release' status.

A custom nightly (or manual) script went through the PLM system to scan for
the 'released' countries on each top level assembly (they had a very
defined format) and set the sales flags in SAP for the country on that
top-level-assembly (assuming the other sales-readiness flags were also
set).

It took a while to develop, but it would allow easy maintenance of certs,
and I believe we were able to put expiration dates on the certs so that we
could run searches and flag upcoming certs.
The other great part was that you only had to update documentation in the
PLM tool once - since it was assigned to multiple top-level-assemblies, one
update would take care of all applicable variants of that product.


Best Regards,
-David Heald



On Fri, Jan 13, 2017 at 9:55 AM, Kortas, Jamison 
wrote:

> Hello All,
>
>
>
> I wanted to see if anyone would be willing to share what they use for
> document and project management. Technical file contents, DoCs, Project
> Submittal Data, pertinent project information, correspondence, etc.
> Doesn’t matter if it is a standalone software tool, an external firm, a
> module within a larger system (SAP), I am curious.  Looking for ways to
> streamline the tracking, maintenance, expiration/renewal, dissemination,
> and versioning expectations.
>
>
>
> If it ties into your project management software, I would love to hear
> about what you use in that regard as well.
>
>
>
> Thanks and have a great weekend.
> CONFIDENTIALITY NOTICE: This e-mail communication and any attachments may
> contain proprietary and privileged information for the use of the
> designated recipients named above. Any unauthorized review, use, disclosure
> or distribution is prohibited. If you are not the intended recipient,
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> -
> 
>
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Re: [PSES] Conformity assessment under RED

[Dave Heald]

Thanks for that clarification - I suppose this might explain why there are
nof RED updates for EN 301 489-7/-24, but I am of course curious if there
is more to it (such as if these 2G/3G/LTE EMC standards have migrated to a
new standard).

Thanks & Best Regards,
-David

On Wed, Jan 4, 2017 at 6:00 AM, Michael Derby  wrote:

> Hi Nick,
>
> You are completely correct.
>
> Actually, this approach (NB is only needed for deviations in testing to
> Articles 3.2 and 3.3; but not needed for deviations in testing for 3.1) was
> apparently the original intention with 1999/5/EC, but it was not correctly
> or clearly written.   2014/53/EU corrects that.
>
> Thanks,
>
> Michael.
>
>
>
> -Original Message-
> From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
> Sent: 04 January 2017 12:18
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] Conformity assessment under RED
>
> Happy New Year, EMC-PSTC listers!
>
> 2014/15/EU article 17 separates the conformity assessment procedures for
> essential requirement 3.1 (safety and EMC) from those which are applied for
> essential requirements 3.2 and 3.3 (spectrum efficiency and special
> provisions). Notified Body intervention is required for ER’s 3.2 and 3.3 if
> the manufacturer has not applied harmonised standards, but no such
> requirement is applied for ER 3.1.
>
> My reading of this is that the manufacturer has complete freedom of
> approach under RED for safety and EMC compliance in exactly the same way
> that they do under the LVD and EMC Directive, and can self-certifiy even if
> they do not apply harmonised standards, irrespective of whether or not they
> are required to involve a NoBo for compliance with ER’s 3.2 & 3.3.
>
> This is not how things worked under 1999/5/EC.
>
> Is my interpretation correct, and if not, why not?
>
> -
> 
> 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
>
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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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

[PSES] 2G & 3G/LTE EMC standards under RED - EN 301 489-7/-24 replacements?

[Dave Heald]

Hi All,
  I have been tracking the standards activity for the RED transition, and
there are two troubling standards for cellular EMC that do not appear to
have new versions in process.

These are the EN 301 489-7 (GSM)  and 301 489-24 (3G/LTE) EMC immunity
standards.

Does anyone know if these requirements have migrated out of the 301 489
series to something new, or what the overall status is?
(or possibly the new 301 489-1v2.1.1 standard will *presumably* meet the
needs of the RED (I think it should be listed in the OJ on 2nd May), and
the -7/-24 standards don't need an update as they only apply test
conditions to the -1 standard?


Any insight on this would be greatly appreciated.

Thanks!
-David Heald

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