RE: CE Marking requirements

1999-09-26 Thread Ing. Gert Gremmen

I have read most replies to your question and i agree.

You referred to the correct standards and THE GUIDE (you may find it on our
site http://www.cetest.nl ).


There are some pitfalls however.

The manufacturers of CPU boards need emission testing in a enclosure
of their choice.  We actually succeeded a board with heavy emission problems
to pass Class B requirements, by selecting a PC enclosure of a reputable
brand (and that we knew was EMC tight).

My customer was warned that he should recommend his customers
this special brand of PC's to keep ce-compliance.
This is too often overlooked ( voluntarily) .

This means that if the product (now ce-marked) is sold
to a PC assembly company (NO-NAME Ltd) that might use any kind of enclosure
to
make it's NO-NAME brand of PC's, this customer of you
 might encounter serious problems getting compliant.
A few UK based manufacturers said CE+CE=CE and got caught !!!

You dont't want this do you ?  So you should select an average enclosure
of a questionable brand, and/or leave the cover open during testing.

Here the open chassis test  shows some value.

Legally you are wrong too. A ce-marked board that creates interference
in another enclosure then it was tested in, bears it's ce-mark against
the ESSENTIAL REQUIREMENTS  of the EMC-directive, although
it passed Class B of EN 55022.

Remember, appliance of standards alone gives only presumption of
conformity, not proof.  Due Diligence is required when ce-marking.

Regards,

Gert Gremmen Ing.

== Ce-test, Qualified testing ==
Consultants in EMC, Electrical safety and Telecommunication
Compliance tests for European standards and ce-marking
Member of NEC/IEC voting committee for EMC.
Our Web presence: http://www.cetest.nl
List of current harmonized standards http://www.cetest.nl/emc-harm.htm
15 great tips for the EMC-designer http://www.cetest.nl/features01.htm



-Original Message-
From:   owner-emc-p...@majordomo.ieee.org
[mailto:owner-emc-p...@majordomo.ieee.org] On Behalf Of
michael.garret...@radisys.com
Sent:   dinsdag 24 augustus 1999 22:44
To: emc-p...@ieee.org
Subject:CE Marking requirements


Well group, if you care to help out another American confused by the
specific
requirements for Europe, I would appreciate it.  I seem to be getting
varying
stories from different test houses as to what is required for one of our
products.  These are big enough players that pitting one against another is
not
something I want to undertake at this point.

We currently manufacture a motherboard which is sold both by itself and with
a
chassis which includes power supply, hard drive and floppy.  We are
currently
going through our internal EMC validation to ensure that we meet both FCC
Class
B and EN 55022 Class B levels.  Our experience on previous products has been
if
we clear emissions, we haven't had problems in other areas, but we'll be
testing
to EN 55024 of immunity, as well.

The issue arises when we discuss testing of the system versus testing of the
motherboard alone.  Within the US, the FCC regulations permit an additional
6dB
margin for open chassis measurement, so long as those frequencies fall
back
within the class B levels with the cover on.  This does not appear to be a
problem for our product.

We have been told by different parties that for Europe,

(a) there is no requirement to test open chassis and that we can CE mark
the
board as compliant as long as we have shown that it can meet the class B
levels
within a chassis of our choosing

and

(b) we are still required to perform open chassis tests, however, there is
no
6dB margin and the board will have to meet the EN 50022 class B levels with
the
cover off.

We're having a little more difficulty making things work using the (b)
approach.
I am specifically concerned about staying far enough below the levels that
we're
not going to potentially pass today and fail 6 months from now due to a
slight
drift in tolerances of components, test equipment or test engineers'
dispositions.

I have the texts of the EMC directive, as well as the test requirements
specified in the above documents and I'm happy to wade through them if you
can
point me in the right direction.  I will be heading that direction in the
next
day or two if I don't receive a response.  I'm hoping, however, that someone
in
the group can shave a few hours of exceptionally captivating reading from my
life by pointing me in the right direction.

Regards,

Michael Garretson
Compliance Engineer
RadiSys Corporation



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Re: CE Marking requirements

1999-09-20 Thread Don Diego

Allan,

Thank you for your response.

Allow me to play the Devil's Advocate for a moment.

My understanding is that it is illegal for one EU country to make a
rule/law without the agreement of all member states/nations, is this
true?

I understand that laws are interpreted differently depending on who is
reading them but, all things being the same, one must be correct and
the other is not.  TRUE?

Your statements lead me to believe that the EU is not truly harmonized
after all.

Zorro


--- Allan G. Carr e...@acarr.demon.co.uk wrote:
 
 In article
 19990825211939.9807.rocketm...@web1306.mail.yahoo.com,
 Don
 Diego zorro_1...@yahoo.com writes
 
 Charles,
 
 If you want to CE mark a component which has no
 intrinsic value (that
 is, it must be operated via another component),is
 CE marking illegal?
 Also, is a Declaration of Incorporation (DOI)
 needed instead of a
 Declaration of Conformity (DOC)?
 
 CE marking of a component is illegal however the
 definition of component
 is different between the UK  France.   The UK
 definition of a component
 includes a card with no intrinsic function supplied
 only to other
 manufacturers (not the public) however I understand
 that French Customs
 are refusing to allow into the country such cards
 which are not CE
 marked.
 
 Because it is illegal to CE mark the cards in the UK
 I had visions of
 sticking the labels on during the Channel Tunnel
 trip to France after it
 passed the half way point however the UK enforcement
 authority has
 stated they will not prosecute CE marking of
 components if they are
 being marked for export to France.
 
 
 Allan
 -- 
  Allan G.Carr B.Sc.(Elec.Eng) AMIEE  |  AGC-Tel
 Consultants Ltd
  Telecommunications Consultant   |  Tel:
 +44(0)141-956-2506 
  European Approvals Specialist   |  Fax:
 +44(0)141-956-5347
  62 Crawford Road,   Milngavie   |  Voice Mail:
 +44(0)1252-30-3062
  Glasgow,  G62 7LF,   Scotland   | 
 http://www.acarr.demon.co.uk
 
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 roger.volgst...@compaq.com (the list
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__
Do You Yahoo!?
Bid and sell for free at http://auctions.yahoo.com

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Re: CE Marking requirements

1999-09-15 Thread Allan G. Carr

In article 19990825211939.9807.rocketm...@web1306.mail.yahoo.com, Don
Diego zorro_1...@yahoo.com writes

Charles,

If you want to CE mark a component which has no intrinsic value (that
is, it must be operated via another component),is CE marking illegal?
Also, is a Declaration of Incorporation (DOI) needed instead of a
Declaration of Conformity (DOC)?

CE marking of a component is illegal however the definition of component
is different between the UK  France.   The UK definition of a component
includes a card with no intrinsic function supplied only to other
manufacturers (not the public) however I understand that French Customs
are refusing to allow into the country such cards which are not CE
marked.

Because it is illegal to CE mark the cards in the UK I had visions of
sticking the labels on during the Channel Tunnel trip to France after it
passed the half way point however the UK enforcement authority has
stated they will not prosecute CE marking of components if they are
being marked for export to France.


Allan
-- 
 Allan G.Carr B.Sc.(Elec.Eng) AMIEE  |  AGC-Tel Consultants Ltd
 Telecommunications Consultant   |  Tel: +44(0)141-956-2506 
 European Approvals Specialist   |  Fax: +44(0)141-956-5347
 62 Crawford Road,   Milngavie   |  Voice Mail: +44(0)1252-30-3062
 Glasgow,  G62 7LF,   Scotland   |  http://www.acarr.demon.co.uk

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RE: CE Marking requirements

1999-08-25 Thread Don Diego

Charles,

If you want to CE mark a component which has no intrinsic value (that
is, it must be operated via another component),is CE marking illegal?
Also, is a Declaration of Incorporation (DOI) needed instead of a
Declaration of Conformity (DOC)?

--- Grasso, Charles (Chaz) gra...@louisville.stortek.com wrote:
 
 As far as I know, the EU has not adopted the insane
 FCC Class B compliance
 process. So there is NO procedure for marking a
 motherboard as a compliant
 unit. 
 
 What you can do is test it in a system (just like
 the old days) and mark the
 motherboard based on that test ALONE.
 
 If I understand your requirement, you are looking to
 adopt the infamous
 CE+CE=CE
 approach. Again, this has proven NOT to work
 especially for emissions.
 
 Comments:
 
 (a) there is no requirement to test open chassis
 and that we can CE mark
 the
 board as compliant as long as we have shown that it
 can meet the class B
 levels
 within a chassis of our choosing.
 
 RESPONSE: There is no requirement NOR is there a
 process for open chassis
 testing.
 The EMC Directive (nor the guidelines) can help you
 here.
 
 
 (b) we are still required to perform open chassis
 tests, however, there is
 no
 6dB margin and the board will have to meet the EN
 50022 class B levels with
 the
 cover off.
 RESPONSE: Nonsense. There is NO open chassis test.
 
 WARNING: Be careful. The next thing the testhouse
 will try is the TCF route.
 
 Ugh.
 
 
 Thank you
 Charles Grasso
 Advisory Engineer
 StorageTek
 1 StorageTek Drive
 Louisville CO 80027 M/S 4247.
 Tel:303-673-2908
 Fax:303-661-7115
 email:gra...@louisville.stortek.com
 RMCEMC Web Site: 
 http://www.ewh.ieee.org/r5/denver/rockymountainemc/
 
 
 
 
 -Original Message-
 From: michael.garret...@radisys.com
 [mailto:michael.garret...@radisys.com]
 Sent: Tuesday, August 24, 1999 2:44 PM
 To: emc-p...@ieee.org
 Subject: CE Marking requirements
 
 
 
 Well group, if you care to help out another American
 confused by the
 specific
 requirements for Europe, I would appreciate it.  I
 seem to be getting
 varying
 stories from different test houses as to what is
 required for one of our
 products.  These are big enough players that pitting
 one against another is
 not
 something I want to undertake at this point.
 
 We currently manufacture a motherboard which is sold
 both by itself and with
 a
 chassis which includes power supply, hard drive and
 floppy.  We are
 currently
 going through our internal EMC validation to ensure
 that we meet both FCC
 Class
 B and EN 55022 Class B levels.  Our experience on
 previous products has been
 if
 we clear emissions, we haven't had problems in other
 areas, but we'll be
 testing
 to EN 55024 of immunity, as well.
 
 The issue arises when we discuss testing of the
 system versus testing of the
 motherboard alone.  Within the US, the FCC
 regulations permit an additional
 6dB
 margin for open chassis measurement, so long as
 those frequencies fall
 back
 within the class B levels with the cover on.  This
 does not appear to be a
 problem for our product.
 
 We have been told by different parties that for
 Europe,
 
 (a) there is no requirement to test open chassis
 and that we can CE mark
 the
 board as compliant as long as we have shown that it
 can meet the class B
 levels
 within a chassis of our choosing
 
 and
 
 (b) we are still required to perform open chassis
 tests, however, there is
 no
 6dB margin and the board will have to meet the EN
 50022 class B levels with
 the
 cover off.
 
 We're having a little more difficulty making things
 work using the (b)
 approach.
 I am specifically concerned about staying far enough
 below the levels that
 we're
 not going to potentially pass today and fail 6
 months from now due to a
 slight
 drift in tolerances of components, test equipment or
 test engineers'
 dispositions.
 
 I have the texts of the EMC directive, as well as
 the test requirements
 specified in the above documents and I'm happy to
 wade through them if you
 can
 point me in the right direction.  I will be heading
 that direction in the
 next
 day or two if I don't receive a response.  I'm
 hoping, however, that someone
 in
 the group can shave a few hours of exceptionally
 captivating reading from my
 life by pointing me in the right direction.
 
 Regards,
 
 Michael Garretson
 Compliance Engineer
 RadiSys Corporation
 
 
 
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 To cancel your subscription, send mail to
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 jim_bac...@monarch.com, ri...@sdd.hp.com, or
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 jim_bac

RE: CE Marking requirements

1999-08-25 Thread Gary McInturff

The recent August 1999 issue of Conformity magazine indicates that indeed
the test methodology of C63.4 does include the open chassis test and the 6
dB above limits. The article indicates a clarification was made about this
process in a recent OET notice. The notice itself wasn't identified so you
would have to search the FCC's site for it.
Before one and all start throwing daggers and putting hexes on me. I want to
point out that I am not endorsing the process, although I certainly
understand, why folk like Michael might want this type of system.
Finally, I will resist a dig at the sanity of many of the European rules.
Gary

-Original Message-
From:   Grasso, Charles (Chaz) [SMTP:gra...@louisville.stortek.com]
Sent:   Tuesday, August 24, 1999 4:18 PM
To: 'michael.garret...@radisys.com'; emc-p...@ieee.org
Subject:RE: CE Marking requirements


As far as I know, the EU has not adopted the insane FCC Class B
compliance
process. So there is NO procedure for marking a motherboard as a
compliant
unit. 

What you can do is test it in a system (just like the old days) and
mark the
motherboard based on that test ALONE.

If I understand your requirement, you are looking to adopt the
infamous
CE+CE=CE
approach. Again, this has proven NOT to work especially for
emissions.

Comments:

(a) there is no requirement to test open chassis and that we can
CE mark
the
board as compliant as long as we have shown that it can meet the
class B
levels
within a chassis of our choosing.

RESPONSE: There is no requirement NOR is there a process for open
chassis
testing.
The EMC Directive (nor the guidelines) can help you here.


(b) we are still required to perform open chassis tests, however,
there is
no
6dB margin and the board will have to meet the EN 50022 class B
levels with
the
cover off.
RESPONSE: Nonsense. There is NO open chassis test.

WARNING: Be careful. The next thing the testhouse will try is the
TCF route.

Ugh.


Thank you
Charles Grasso
Advisory Engineer
StorageTek
1 StorageTek Drive
Louisville CO 80027 M/S 4247.
Tel:303-673-2908
Fax:303-661-7115
email:gra...@louisville.stortek.com
RMCEMC Web Site:
http://www.ewh.ieee.org/r5/denver/rockymountainemc/




-Original Message-
From: michael.garret...@radisys.com
[mailto:michael.garret...@radisys.com]
Sent: Tuesday, August 24, 1999 2:44 PM
To: emc-p...@ieee.org
Subject: CE Marking requirements



Well group, if you care to help out another American confused by the
specific
requirements for Europe, I would appreciate it.  I seem to be
getting
varying
stories from different test houses as to what is required for one of
our
products.  These are big enough players that pitting one against
another is
not
something I want to undertake at this point.

We currently manufacture a motherboard which is sold both by itself
and with
a
chassis which includes power supply, hard drive and floppy.  We are
currently
going through our internal EMC validation to ensure that we meet
both FCC
Class
B and EN 55022 Class B levels.  Our experience on previous products
has been
if
we clear emissions, we haven't had problems in other areas, but
we'll be
testing
to EN 55024 of immunity, as well.

The issue arises when we discuss testing of the system versus
testing of the
motherboard alone.  Within the US, the FCC regulations permit an
additional
6dB
margin for open chassis measurement, so long as those frequencies
fall
back
within the class B levels with the cover on.  This does not appear
to be a
problem for our product.

We have been told by different parties that for Europe,

(a) there is no requirement to test open chassis and that we can
CE mark
the
board as compliant as long as we have shown that it can meet the
class B
levels
within a chassis of our choosing

and

(b) we are still required to perform open chassis tests, however,
there is
no
6dB margin and the board will have to meet the EN 50022 class B
levels with
the
cover off.

We're having a little more difficulty making things work using the
(b)
approach.
I am specifically concerned about staying far enough below the
levels that
we're
not going to potentially pass today and fail 6 months from now due
to a
slight
drift in tolerances of components, test equipment or test engineers

RE: CE Marking requirements

1999-08-25 Thread Pierre Selva

Dear Michael,

For European requirements, you have to read the EN55022 and its Amendments 1 
and 2. In the Amendment1, the chapter 9.1 explain what you have to do with your 
mother board. You have to test it in a commercial unit (classB) and if the test 
results are OK, then you can affix the CE marking on your board. 

Pierre Selva
Laboratory responsible  EMC and Safety laboratory
SMEE Actions MesuresPh : 33 4 76 65 76 50
ZI des Blanchisseries   Fx : 33 4 76 66 18 30
38500 VOIRON - France   e-mail : actionsmesu...@compuserve.com



-Original Message-
From:   michael.garret...@radisys.com [SMTP:michael.garret...@radisys.com]
Sent:   Tuesday, August 24, 1999 10:44 PM
To: emc-p...@ieee.org
Subject:CE Marking requirements

 

Well group, if you care to help out another American confused by the specific
requirements for Europe, I would appreciate it.  I seem to be getting varying
stories from different test houses as to what is required for one of our
products.  These are big enough players that pitting one against another is not
something I want to undertake at this point.

We currently manufacture a motherboard which is sold both by itself and with a
chassis which includes power supply, hard drive and floppy.  We are currently
going through our internal EMC validation to ensure that we meet both FCC Class
B and EN 55022 Class B levels.  Our experience on previous products has been if
we clear emissions, we haven't had problems in other areas, but we'll be testing
to EN 55024 of immunity, as well.

The issue arises when we discuss testing of the system versus testing of the
motherboard alone.  Within the US, the FCC regulations permit an additional 6dB
margin for open chassis measurement, so long as those frequencies fall back
within the class B levels with the cover on.  This does not appear to be a
problem for our product.

We have been told by different parties that for Europe,

(a) there is no requirement to test open chassis and that we can CE mark the
board as compliant as long as we have shown that it can meet the class B levels
within a chassis of our choosing

and

(b) we are still required to perform open chassis tests, however, there is no
6dB margin and the board will have to meet the EN 50022 class B levels with the
cover off.

We're having a little more difficulty making things work using the (b) approach.
I am specifically concerned about staying far enough below the levels that we're
not going to potentially pass today and fail 6 months from now due to a slight
drift in tolerances of components, test equipment or test engineers'
dispositions.

I have the texts of the EMC directive, as well as the test requirements
specified in the above documents and I'm happy to wade through them if you can
point me in the right direction.  I will be heading that direction in the next
day or two if I don't receive a response.  I'm hoping, however, that someone in
the group can shave a few hours of exceptionally captivating reading from my
life by pointing me in the right direction.

Regards,

Michael Garretson
Compliance Engineer
RadiSys Corporation



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Re: CE Marking requirements

1999-08-25 Thread Michael J. Azar

Michael,

In looking at the standard to answer your question, you should refer to
Section 8.1 of the most current  EN55022 (EN55022:1998/CISPR 22:1997), which
was published in the OJ earlier this year and was mandatory as of January of
this year.

Specifically, the 10th paragraph of section 8.1 statesIn the case of
printed wiring board assemblies (PWBA), separately marketed for the
enhancement of divers host units, the PWBA  (such as ISDN, interface, CPU,
adaptor cards, etc.) shall be tested in at least one appropriate
representative host unit of the PWBA manufacturer's choice so as to ensure
compliance of the PWBA with the entire population of hosts in which it is
intended to be installed.  The host shall be a typical compliant production
sample.  PWBA intended to be class B shall not be tested in host which are
class A.

If one interprets the phrase such as ISDN, interface, CPU, adaptor cards,
etc. to mean such as ISDN cards, interface cards, CPU cards, adaptor cards
etc. then neither of your options would be valid.  If one interprets the
reference to CPU to mean motherboard, then it seems that your option a is
valid.

You may find further guidance in the following document:

GUIDELINES ON THE APPLICATION OF COUNCIL
DIRECTIVE 89/336/EEC OF 3 MAY 1989 ON THE APPROXIMATION OF THE LAWS OF THE
MEMBER STATES RELATING TO ELECTROMAGNETIC COMPATIBILITY
(DIRECTIVE 89/336/EEC AMENDED BY DIRECTIVES
91/263/EEC, 92/31/EEC, 93/68/EEC, 93/97/EEC)

This document states that any component, which performs a direct function is
considered to be an apparatus as defined by the EMC Directive and thus
subject to the Directive.  The most pertinent section of this document
follows:

6.2.3. Components performing a direct function

These are components that can be placed on the market in retail outlets for
distribution and/or putting into service, fulfilling the criteria defined in
6.2.1, therefore delivering a direct function.
Plug-in cards, such as smart cards or input/output modules, designed for
incorporation into computers are apparatus commonly found in retail outlets,
and available to the general public. Once cards of this type are inserted in
a PC they perform a direct function for the user.  They must therefore be
considered as apparatus and are, consequently, subject to the provisions of
the EMC Directive.

This does not mean that they must necessarily be intrinsically compliant
from the EMC point of view in all cases, if this is either impossible or
impracticable . However, in such cases, they must be designed in such a way
that they become fully EMC compliant (emissions and immunity) when they are
installed as intended in the apparatus, in any of its possible variants and
configurations, without exceptions, and used in the electromagnetic
environment determined by the manufacturer. The instructions accompanying
the component must clearly indicate these requirements, the pertinent
limitations of use and how to comply without resorting to an EMC specialist
(such components are available to non-EMC specialists, for a wide range of
applications). The manufacturer has the ultimate responsibility for this
decision.

Similar examples of components with a direct function are:

* plug-in cards for computer systems, micro-processor cards, central
processing unit cards/mother boards, electronic mail cards,
telecommunication cards, etc.;

* programmable logic controllers;

* lift controls;

* electric motors (except for induction motors, see chapter 5.4);

* computer disk drives;

* power supply units (PSU), where they take the form of autonomous
equipment;

* electronic temperature controls;

Perhaps the above might shorten your research time or just further confuse
you. Hopefully it's the former.  The full text of the above quoted
guidelines are available on the internet.  I've lost the link from which I
got it, but perhaps someone on the list can lead you there.  If you have no
luck finding it, please email me directly and I'll forward you a pdf file
via email attachment.

Best Regards




Michael J. Azar / Senior Program Manager
EMC Compliance Management Group
http://www.emc-turntech.com
Tel:  650-988-0900 x 103
Fax: 650-988-6647

High quality EMC/Safety Consultancy and Approvals



-Original Message-
From: michael.garret...@radisys.com michael.garret...@radisys.com
To: emc-p...@ieee.org emc-p...@ieee.org
List-Post: emc-pstc@listserv.ieee.org
Date: Tuesday, August 24, 1999 3:20 PM
Subject: CE Marking requirements



Well group, if you care to help out another American confused by the
specific
requirements for Europe, I would appreciate it.  I seem to be getting
varying
stories from different test houses as to what is required for one of our
products.  These are big enough players that pitting one against another is
not
something I want to undertake at this point.

We currently manufacture a motherboard which is sold both by itself and
with a
chassis

RE: CE Marking requirements

1999-08-25 Thread Grasso, Charles (Chaz)

As far as I know, the EU has not adopted the insane FCC Class B compliance
process. So there is NO procedure for marking a motherboard as a compliant
unit. 

What you can do is test it in a system (just like the old days) and mark the
motherboard based on that test ALONE.

If I understand your requirement, you are looking to adopt the infamous
CE+CE=CE
approach. Again, this has proven NOT to work especially for emissions.

Comments:

(a) there is no requirement to test open chassis and that we can CE mark
the
board as compliant as long as we have shown that it can meet the class B
levels
within a chassis of our choosing.

RESPONSE: There is no requirement NOR is there a process for open chassis
testing.
The EMC Directive (nor the guidelines) can help you here.


(b) we are still required to perform open chassis tests, however, there is
no
6dB margin and the board will have to meet the EN 50022 class B levels with
the
cover off.
RESPONSE: Nonsense. There is NO open chassis test.

WARNING: Be careful. The next thing the testhouse will try is the TCF route.

Ugh.


Thank you
Charles Grasso
Advisory Engineer
StorageTek
1 StorageTek Drive
Louisville CO 80027 M/S 4247.
Tel:303-673-2908
Fax:303-661-7115
email:gra...@louisville.stortek.com
RMCEMC Web Site:  http://www.ewh.ieee.org/r5/denver/rockymountainemc/




-Original Message-
From: michael.garret...@radisys.com
[mailto:michael.garret...@radisys.com]
Sent: Tuesday, August 24, 1999 2:44 PM
To: emc-p...@ieee.org
Subject: CE Marking requirements



Well group, if you care to help out another American confused by the
specific
requirements for Europe, I would appreciate it.  I seem to be getting
varying
stories from different test houses as to what is required for one of our
products.  These are big enough players that pitting one against another is
not
something I want to undertake at this point.

We currently manufacture a motherboard which is sold both by itself and with
a
chassis which includes power supply, hard drive and floppy.  We are
currently
going through our internal EMC validation to ensure that we meet both FCC
Class
B and EN 55022 Class B levels.  Our experience on previous products has been
if
we clear emissions, we haven't had problems in other areas, but we'll be
testing
to EN 55024 of immunity, as well.

The issue arises when we discuss testing of the system versus testing of the
motherboard alone.  Within the US, the FCC regulations permit an additional
6dB
margin for open chassis measurement, so long as those frequencies fall
back
within the class B levels with the cover on.  This does not appear to be a
problem for our product.

We have been told by different parties that for Europe,

(a) there is no requirement to test open chassis and that we can CE mark
the
board as compliant as long as we have shown that it can meet the class B
levels
within a chassis of our choosing

and

(b) we are still required to perform open chassis tests, however, there is
no
6dB margin and the board will have to meet the EN 50022 class B levels with
the
cover off.

We're having a little more difficulty making things work using the (b)
approach.
I am specifically concerned about staying far enough below the levels that
we're
not going to potentially pass today and fail 6 months from now due to a
slight
drift in tolerances of components, test equipment or test engineers'
dispositions.

I have the texts of the EMC directive, as well as the test requirements
specified in the above documents and I'm happy to wade through them if you
can
point me in the right direction.  I will be heading that direction in the
next
day or two if I don't receive a response.  I'm hoping, however, that someone
in
the group can shave a few hours of exceptionally captivating reading from my
life by pointing me in the right direction.

Regards,

Michael Garretson
Compliance Engineer
RadiSys Corporation



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