RE: Odd CE Marking Question

[Allen, John]

Hi Folks

Hate to be a doom-bringer on this one and introduce another issue, but - to
bring a note of sanity - I think the General Product Safety Directive
(92/59/EEC) might actually apply to this type of kit! It applies to
virtually anything where there is no sector-specific directive.

However, watch out, the CE Marking is only to be used in conjunction with a
DoC against a Directive which actually specifies the use of both, and -
happily -the GPS Directive is not a CE Marking Directive. Therefore if that
is the most appropriate directive then you must NOT use the CE Marking.

John Allen
Thales Defence Communications Division Bracknell
UK.


> -Original Message-
> From: Grant, Tania (Tania) [mailto:tgr...@lucent.com]
> Sent: 09 April 2001 21:30
> To:   EMC-PSTC (E-mail); 'Louis Fischer'
> Subject:  RE: Odd CE Marking Question
> 
> I hope not;--  please don't give these  (B)(E)urocrats any ideas!
>   
> Tania Grant,  tgr...@lucent.com
> Lucent Technologies, Switching Solutions Group
> Intelligent Network and Messaging Solutions
> 
> --
> From: Louis Fischer[SMTP:lofis...@cisco.com]
> Reply To: Louis Fischer
> Sent: Monday, April 09, 2001 3:02 PM
> To:   EMC-PSTC (E-mail)
> Subject:  RE: Odd CE Marking Question
> 
> Is there a Directive for decorative items, or perhaps for props or stage
> equipment, which might be more appropriate?  LEF
> ---
> Louis E. Fischer
> Compliance Engineer
> Cisco Systems, Inc.
> 12515 Research Blvd, Bldg 4
> Austin, TX 78759
> (512) 378-1723
> FAX: (512) 378-1251
> 
>-Original Message-
>   From:   owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]  On
> Behalf Of Grant, Tania (Tania)
>   Sent:   Monday, April 09, 2001 11:24 AM
>   To: Kevin Harris; 'Steve Brody'
>   Cc: EMC-PSTC (E-mail)
>   Subject:RE: Odd CE Marking Question
> 
>   I don't know, Steve.   That might be jumping from the frying pan
> into the fire;--   has the dummy been evaluated to be a safe
> toy??? ;)
>   
>   Tania Grant,  tgr...@lucent.com
>   Lucent Technologies, Switching Solutions Group
>   Intelligent Network and Messaging Solutions
> 
>   --
>   From:   Steve Brody[SMTP:sbr...@prodigy.net]
>   Reply To:   Steve Brody
>   Sent:   Sunday, April 08, 2001 1:21 PM
>   To: Kevin Harris
>   Cc: EMC-PSTC (E-mail)
>   Subject:Re: Odd CE Marking Question
> 
> 
>   Having read through most of the responses as of this writing, and
> finding, as
>   expected, very valid and well positioned recommendations and
> suggestions, I
>   submit that if this is intended to be a dummy intended to make
> people believe
>   that it is what it is supposed to be, even if it is not, then a CE
> Marking and
>   other labels may be required to complete the ruse.  If, as some of
> our
>   colleagues believe that CE Marking and claiming compliance to LVD or
> EMC is not
>   valid and should not be done, then treat the dummy as it is and
> claim compliance
>   to the Toys Directive and mark the product with a CE Marking.
> 
>   Steve Brody
>   Sr. Compliance Engineer
>   Thermo NESLAB
>   steve.br...@neslab.com or sbr...@prodigy.net
>   .
> 
>   Kevin Harris wrote:
> 
>   > Hello Group,
>   >
>   > I just had a question posed to me that made me think a little bit.
> So I will
>   > pose it to all of you.  First some preamble. A device is going to
> be made
>   > for the European market. It is in fact a "dummy" device in that it
> looks
>   > like the real thing but it is not. The only electronics inside is
> a bridge
>   > rectifier and a RC circuit to blink a LED. The device can be
> powered by
>   > either an AC or DC source up to 30 V. The power source is not
> supplied. For
>   > this industry (security) there is a product family standard for
> EMC. The
>   > device is not a mock up for store display purposes but is in fact
> used in
>   > the industry to give the impression that there are more of these
> devices
>   > around than there really are.
>   >
>   > So the moment has arrived, do you CE mark the device? If you say
> yes, what
>   > directive did you apply? If you say no, what is your reasoning?
>   >
>   > Best Regards,
>   >
>   > Kevin Harris
>   > Manager, Approval Services
>   > Digital Security Controls
>   > 3301 Langstaff

RE: Odd CE Marking Question

[ggarside]

I suppose if there were a "Directive for Decorative Items", (DDI), ugly
products would be exempt?  For example, certain stylish computers (I have a
certain brand or two in mind!) might fall in the scope of LVD, EMC, and
"DDI", whereas a typical "beige-brick" PC, being "merely" functional would
only have to consider LVD & EMC requirements?

Further, I imagine that efforts to harmonize European and North American
ideas of styling to produce a common definition of "decorative" could take
years:
"...Exception 7: Extensive usage of CHROME shall be considered 'decorative'
in the following country/ies: ..."
"...Exception 23: Wristwatches, and similar consumer products, consisting
of black indicator-hands and black letters on a black background, mounted
in a black case and furnished with a black wrist strap, shall be considered
'decorative products' in the following countries/economic areas:" ...

Oh well, back to work...
-Glyn (in a private capacity as usual...)


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RE: Odd CE Marking Question

[Grant, Tania (Tania)]

I hope not;--  please don't give these  (B)(E)urocrats any ideas!
  
Tania Grant,  tgr...@lucent.com
Lucent Technologies, Switching Solutions Group
Intelligent Network and Messaging Solutions

> --
> From: Louis Fischer[SMTP:lofis...@cisco.com]
> Reply To: Louis Fischer
> Sent: Monday, April 09, 2001 3:02 PM
> To:   EMC-PSTC (E-mail)
> Subject:  RE: Odd CE Marking Question
> 
> Is there a Directive for decorative items, or perhaps for props or stage
> equipment, which might be more appropriate?  LEF
> ---
> Louis E. Fischer
> Compliance Engineer
> Cisco Systems, Inc.
> 12515 Research Blvd, Bldg 4
> Austin, TX 78759
> (512) 378-1723
> FAX: (512) 378-1251
> 
>  -Original Message-
> From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]  On
> Behalf Of Grant, Tania (Tania)
> Sent: Monday, April 09, 2001 11:24 AM
> To:   Kevin Harris; 'Steve Brody'
> Cc:   EMC-PSTC (E-mail)
> Subject:  RE: Odd CE Marking Question
> 
> I don't know, Steve.   That might be jumping from the frying pan into the
> fire;--   has the dummy been evaluated to be a safe toy??? ;)
>   
> Tania Grant,  tgr...@lucent.com
> Lucent Technologies, Switching Solutions Group
> Intelligent Network and Messaging Solutions
> 
> --
> From: Steve Brody[SMTP:sbr...@prodigy.net]
> Reply To:     Steve Brody
> Sent: Sunday, April 08, 2001 1:21 PM
> To:   Kevin Harris
> Cc:   EMC-PSTC (E-mail)
> Subject:  Re: Odd CE Marking Question
> 
> 
> Having read through most of the responses as of this writing, and finding,
> as
> expected, very valid and well positioned recommendations and suggestions,
> I
> submit that if this is intended to be a dummy intended to make people
> believe
> that it is what it is supposed to be, even if it is not, then a CE Marking
> and
> other labels may be required to complete the ruse.  If, as some of our
> colleagues believe that CE Marking and claiming compliance to LVD or EMC
> is not
> valid and should not be done, then treat the dummy as it is and claim
> compliance
> to the Toys Directive and mark the product with a CE Marking.
> 
> Steve Brody
> Sr. Compliance Engineer
> Thermo NESLAB
> steve.br...@neslab.com or sbr...@prodigy.net
> .
> 
> Kevin Harris wrote:
> 
> > Hello Group,
> >

> > I just had a question posed to me that made me think a little bit. So I
> will
> > pose it to all of you.  First some preamble. A device is going to be
> made
> > for the European market. It is in fact a "dummy" device in that it looks
> > like the real thing but it is not. The only electronics inside is a
> bridge
> > rectifier and a RC circuit to blink a LED. The device can be powered by
> > either an AC or DC source up to 30 V. The power source is not supplied.
> For
> > this industry (security) there is a product family standard for EMC. The
> > device is not a mock up for store display purposes but is in fact used
> in
> > the industry to give the impression that there are more of these devices
> > around than there really are.
> >
> > So the moment has arrived, do you CE mark the device? If you say yes,
> what
> > directive did you apply? If you say no, what is your reasoning?
> >
> > Best Regards,
> >
> > Kevin Harris
> > Manager, Approval Services
> > Digital Security Controls
> > 3301 Langstaff Road
> > Concord, Ontario
> > CANADA
> > L4K 4L2
> >
> > Tel: +1 905 760 3000 Ext. 2378
> > Fax +1 905 760 3020
> >
> > Email: harr...@dscltd.com <mailto:harr...@dscltd.com>
> >
> > ---
> > This message is from the IEEE EMC Society Product Safety
> > Technical Committee emc-pstc discussion list.
> >
> > Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> >
> > To cancel your subscription, send mail to:
> >  majord...@ieee.org
> > with the single line:
> >  unsubscribe emc-pstc
> >
> > For help, send mail to the list administrators:
> >  Michael Garretson:pstc_ad...@garretson.org
> >  Dave Healddavehe...@mediaone.net
> >
> > For policy questions, send mail to:
> >  Richard Nute:   ri...@ieee.org
> >  Jim Bacher: j.bac...@ieee.org
> >
> > All emc-pstc postings are archived and searchable on the web at:
> > http://www.rcic.com/  click on "Virtual Conference Hall,"
> 
> 
> 

RE: Odd CE Marking Question

[Louis Fischer]

Is there a Directive for decorative items, or perhaps for props or stage
equipment, which might be more appropriate?  LEF
---
Louis E. Fischer
Compliance Engineer
Cisco Systems, Inc.
12515 Research Blvd, Bldg 4
Austin, TX 78759
(512) 378-1723
FAX: (512) 378-1251

>  -Original Message-
> From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]  On
> Behalf Of Grant, Tania (Tania)
> Sent: Monday, April 09, 2001 11:24 AM
> To:   Kevin Harris; 'Steve Brody'
> Cc:   EMC-PSTC (E-mail)
> Subject:  RE: Odd CE Marking Question
> 
> I don't know, Steve.   That might be jumping from the frying pan into the
> fire;--   has the dummy been evaluated to be a safe toy??? ;)
>   
> Tania Grant,  tgr...@lucent.com
> Lucent Technologies, Switching Solutions Group
> Intelligent Network and Messaging Solutions
> 
> --
> From: Steve Brody[SMTP:sbr...@prodigy.net]
> Reply To: Steve Brody
> Sent: Sunday, April 08, 2001 1:21 PM
> To:   Kevin Harris
> Cc:   EMC-PSTC (E-mail)
> Subject:  Re: Odd CE Marking Question
> 
> 
> Having read through most of the responses as of this writing, and finding,
> as
> expected, very valid and well positioned recommendations and suggestions,
> I
> submit that if this is intended to be a dummy intended to make people
> believe
> that it is what it is supposed to be, even if it is not, then a CE Marking
> and
> other labels may be required to complete the ruse.  If, as some of our
> colleagues believe that CE Marking and claiming compliance to LVD or EMC
> is not
> valid and should not be done, then treat the dummy as it is and claim
> compliance
> to the Toys Directive and mark the product with a CE Marking.
> 
> Steve Brody
> Sr. Compliance Engineer
> Thermo NESLAB
> steve.br...@neslab.com or sbr...@prodigy.net
> .
> 
> Kevin Harris wrote:
> 
> > Hello Group,
> >
> > I just had a question posed to me that made me think a little bit. So I
> will
> > pose it to all of you.  First some preamble. A device is going to be
> made
> > for the European market. It is in fact a "dummy" device in that it looks
> > like the real thing but it is not. The only electronics inside is a
> bridge
> > rectifier and a RC circuit to blink a LED. The device can be powered by
> > either an AC or DC source up to 30 V. The power source is not supplied.
> For
> > this industry (security) there is a product family standard for EMC. The
> > device is not a mock up for store display purposes but is in fact used
> in
> > the industry to give the impression that there are more of these devices
> > around than there really are.
> >
> > So the moment has arrived, do you CE mark the device? If you say yes,
> what
> > directive did you apply? If you say no, what is your reasoning?
> >
> > Best Regards,
> >
> > Kevin Harris
> > Manager, Approval Services
> > Digital Security Controls
> > 3301 Langstaff Road
> > Concord, Ontario
> > CANADA
> > L4K 4L2
> >
> > Tel: +1 905 760 3000 Ext. 2378
> > Fax +1 905 760 3020
> >
> > Email: harr...@dscltd.com <mailto:harr...@dscltd.com>
> >
> > ---
> > This message is from the IEEE EMC Society Product Safety
> > Technical Committee emc-pstc discussion list.
> >
> > Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> >
> > To cancel your subscription, send mail to:
> >  majord...@ieee.org
> > with the single line:
> >  unsubscribe emc-pstc
> >
> > For help, send mail to the list administrators:
> >  Michael Garretson:pstc_ad...@garretson.org
> >  Dave Healddavehe...@mediaone.net
> >
> > For policy questions, send mail to:
> >  Richard Nute:   ri...@ieee.org
> >  Jim Bacher: j.bac...@ieee.org
> >
> > All emc-pstc postings are archived and searchable on the web at:
> > http://www.rcic.com/  click on "Virtual Conference Hall,"
> 
> 
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
> 
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> 
> To cancel your subscription, send mail to:
>  majord...@ieee.org
> with the single line:
>  unsubscribe emc-pstc
> 
> For help, send mail to the list administrators:
>  Michael Garretson:pstc_ad...@garretson.org
>  Dave Healddavehe...@mediaone.net
> 
> For policy questions, send mail to:
>  Richard Nute:   ri...@ieee.org
>  Jim Bacher: j.bac...@ieee.org
> 
> All emc-pstc postings are archived and searchable on the web at:
> http://www.rcic.com/  click on "Virtual Conference Hall,"
> 
<>

RE: Odd CE Marking Question

[Grant, Tania (Tania)]

I don't know, Steve.   That might be jumping from the frying pan into the
fire;--   has the dummy been evaluated to be a safe toy??? ;)

Tania Grant,  tgr...@lucent.com
Lucent Technologies, Switching Solutions Group
Intelligent Network and Messaging Solutions

> --
> From: Steve Brody[SMTP:sbr...@prodigy.net]
> Reply To: Steve Brody
> Sent: Sunday, April 08, 2001 1:21 PM
> To:   Kevin Harris
> Cc:   EMC-PSTC (E-mail)
> Subject:  Re: Odd CE Marking Question
> 
> 
> Having read through most of the responses as of this writing, and finding,
> as
> expected, very valid and well positioned recommendations and suggestions,
> I
> submit that if this is intended to be a dummy intended to make people
> believe
> that it is what it is supposed to be, even if it is not, then a CE Marking
> and
> other labels may be required to complete the ruse.  If, as some of our
> colleagues believe that CE Marking and claiming compliance to LVD or EMC
> is not
> valid and should not be done, then treat the dummy as it is and claim
> compliance
> to the Toys Directive and mark the product with a CE Marking.
> 
> Steve Brody
> Sr. Compliance Engineer
> Thermo NESLAB
> steve.br...@neslab.com or sbr...@prodigy.net
> .
> 
> Kevin Harris wrote:
> 
> > Hello Group,
> >
> > I just had a question posed to me that made me think a little bit. So I
> will
> > pose it to all of you.  First some preamble. A device is going to be
> made
> > for the European market. It is in fact a "dummy" device in that it looks
> > like the real thing but it is not. The only electronics inside is a
> bridge
> > rectifier and a RC circuit to blink a LED. The device can be powered by
> > either an AC or DC source up to 30 V. The power source is not supplied.
> For
> > this industry (security) there is a product family standard for EMC. The
> > device is not a mock up for store display purposes but is in fact used
> in
> > the industry to give the impression that there are more of these devices
> > around than there really are.
> >
> > So the moment has arrived, do you CE mark the device? If you say yes,
> what
> > directive did you apply? If you say no, what is your reasoning?
> >
> > Best Regards,
> >
> > Kevin Harris
> > Manager, Approval Services
> > Digital Security Controls
> > 3301 Langstaff Road
> > Concord, Ontario
> > CANADA
> > L4K 4L2
> >
> > Tel: +1 905 760 3000 Ext. 2378
> > Fax +1 905 760 3020
> >
> > Email: harr...@dscltd.com <mailto:harr...@dscltd.com>
> >
> > ---
> > This message is from the IEEE EMC Society Product Safety
> > Technical Committee emc-pstc discussion list.
> >
> > Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> >
> > To cancel your subscription, send mail to:
> >  majord...@ieee.org
> > with the single line:
> >  unsubscribe emc-pstc
> >
> > For help, send mail to the list administrators:
> >  Michael Garretson:pstc_ad...@garretson.org
> >  Dave Healddavehe...@mediaone.net
> >
> > For policy questions, send mail to:
> >  Richard Nute:   ri...@ieee.org
> >  Jim Bacher: j.bac...@ieee.org
> >
> > All emc-pstc postings are archived and searchable on the web at:
> > http://www.rcic.com/  click on "Virtual Conference Hall,"
> 
> 
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
> 
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> 
> To cancel your subscription, send mail to:
>  majord...@ieee.org
> with the single line:
>  unsubscribe emc-pstc
> 
> For help, send mail to the list administrators:
>  Michael Garretson:pstc_ad...@garretson.org
>  Dave Healddavehe...@mediaone.net
> 
> For policy questions, send mail to:
>  Richard Nute:   ri...@ieee.org
>  Jim Bacher: j.bac...@ieee.org
> 
> All emc-pstc postings are archived and searchable on the web at:
> http://www.rcic.com/  click on "Virtual Conference Hall,"
> 
<>

Re: Odd CE Marking Question

[Steve Brody]

Having read through most of the responses as of this writing, and finding, as
expected, very valid and well positioned recommendations and suggestions, I
submit that if this is intended to be a dummy intended to make people believe
that it is what it is supposed to be, even if it is not, then a CE Marking and
other labels may be required to complete the ruse.  If, as some of our
colleagues believe that CE Marking and claiming compliance to LVD or EMC is not
valid and should not be done, then treat the dummy as it is and claim compliance
to the Toys Directive and mark the product with a CE Marking.

Steve Brody
Sr. Compliance Engineer
Thermo NESLAB
steve.br...@neslab.com or sbr...@prodigy.net
..

Kevin Harris wrote:

> Hello Group,
>
> I just had a question posed to me that made me think a little bit. So I will
> pose it to all of you.  First some preamble. A device is going to be made
> for the European market. It is in fact a "dummy" device in that it looks
> like the real thing but it is not. The only electronics inside is a bridge
> rectifier and a RC circuit to blink a LED. The device can be powered by
> either an AC or DC source up to 30 V. The power source is not supplied. For
> this industry (security) there is a product family standard for EMC. The
> device is not a mock up for store display purposes but is in fact used in
> the industry to give the impression that there are more of these devices
> around than there really are.
>
> So the moment has arrived, do you CE mark the device? If you say yes, what
> directive did you apply? If you say no, what is your reasoning?
>
> Best Regards,
>
> Kevin Harris
> Manager, Approval Services
> Digital Security Controls
> 3301 Langstaff Road
> Concord, Ontario
> CANADA
> L4K 4L2
>
> Tel: +1 905 760 3000 Ext. 2378
> Fax +1 905 760 3020
>
> Email: harr...@dscltd.com 
>
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
>
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
>
> To cancel your subscription, send mail to:
>  majord...@ieee.org
> with the single line:
>  unsubscribe emc-pstc
>
> For help, send mail to the list administrators:
>  Michael Garretson:pstc_ad...@garretson.org
>  Dave Healddavehe...@mediaone.net
>
> For policy questions, send mail to:
>  Richard Nute:   ri...@ieee.org
>  Jim Bacher: j.bac...@ieee.org
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.rcic.com/  click on "Virtual Conference Hall,"


---
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
 majord...@ieee.org
with the single line:
 unsubscribe emc-pstc

For help, send mail to the list administrators:
 Michael Garretson:pstc_ad...@garretson.org
 Dave Healddavehe...@mediaone.net

For policy questions, send mail to:
 Richard Nute:   ri...@ieee.org
 Jim Bacher: j.bac...@ieee.org

All emc-pstc postings are archived and searchable on the web at:
http://www.rcic.com/  click on "Virtual Conference Hall,"

Re: Odd CE Marking Question

[Cortland Richmond]

Some years ago, a firm was fined by the
FCC here in America for displaying at
a trade show a non-functional modem
which neither bore the  FCC marking
(ID, at that time) nor the precautionary
"This device has not met..." label.
I used to think you had more sense on
that side of the Atlantic, but considering
Brussels ... Better safe than sorry!

Since it seems there may not be any
standard your device fails to meet, you
could hardly be challenged for violating
one if you mark it, and since, as well,
a government functionary might reflexively
penalize you for marketing a device
(ostensibly a security device) without
such a marking, it seems to me that
applying it is the better part of valor.

Too, a criminal might learn that while real
security systems DO bear markings, dummy
ones don't, and use that distinction to
target premises "protected" by dummy
security systems. A customer might well in
that event call you to task, claiming you
knew, or should have known, that this would
happen when you made a device recognizably
fake. Another reason to add the mark!

Cortland Richmond

== Original Message Follows 

(headers and trailers snipped)

Kevin Harris  wrote:
 

Hello Group,

I just had a question posed to me that
made me think a little bit. So I will
pose it to all of you.  First some preamble.
A device is going to be made for the
European market. It is in fact a "dummy"
device in that it looks like the real
thing but it is not. The only electronics
inside is a bridge rectifier and a RC
circuit to blink a LED. The device can
be powered by either an AC or DC source
up to 30 V. The power source is not
supplied. For this industry (security)
there is a product family standard for
EMC. The device is not a mock up for
store display purposes but is in fact
used in the industry to give the
impression that there are more of these
devices around than there really are.

So the moment has arrived, do you CE
mark the device? If you say yes, what
directive did you apply? If you say
no, what is your reasoning?

== End of Original Message =

---
This message is from the IEEE EMC Society Product Safety
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Re: Odd CE Marking Question

[John Woodgate]

<009c01c0bf00$767f3fd0$3e3e3...@corp.auspex.com>, Doug McKean
 wrote:
>Couldn't someone be a total speedbump with 
>the LED having to be declared to 60825? 

It might need a 'laser safety' label, but no EU Directive is involved.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. Phone +44 (0)1268 747839
Fax +44 (0)1268 777124. http://www.jmwa.demon.co.uk Why not call a vertically-
applied manulo-pedally-operated quasi-planar chernozem-penetrating and 
excavating implement a SPADE?

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Re: Odd CE Marking Question

[John Woodgate]

,
donald.han...@exgate.tek.com wrote:
>The LVD covers devices that operate from a source 50V AC or 75 V DC, since
>your dummy operates from 30 V it is not covered by the scope of the LVD. In
>fact it is illegal to claim compliance to it.

On what basis do you claim that? If you have been looking at the UK
implementation of the LVD, that is affected by over-zealous
interpretation of the Directive and is not supported by other EU Member
States.
-- 
Regards, John Woodgate, OOO - Own Opinions Only. Phone +44 (0)1268 747839
Fax +44 (0)1268 777124. http://www.jmwa.demon.co.uk Why not call a vertically-
applied manulo-pedally-operated quasi-planar chernozem-penetrating and 
excavating implement a SPADE?

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Re: Odd CE Marking Question

[Doug McKean]

Just some curiosity/discussion type questions among the answers ... 

> The device can be powered by either an AC or DC source up to 30 V. 

In this 'either' situation, doesn't compliance whatever it 
ends up being, have to default in some way to 60950 
by way of the AC regardless of the 30vdc?  

> The only electronics inside is a bridge
> rectifier and a RC circuit to blink a LED.  

Couldn't someone be a total speedbump with 
the LED having to be declared to 60825? 

- Doug McKean 




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Re: Odd CE Marking Question

[Dan Kwok]

Kevin Harris wrote:
> 
> So the moment has arrived, do you CE mark the device? If you say yes, what
> directive did you apply? If you say no, what is your reasoning? 


I guess you can always mark it with a "dummy" CE mark (=:

-- 

Daniel Kwok, P.Eng.
Principal EMC Engineer 
Intetron Consulting, Inc.  
Vancouver, Canada
Phone (604) 432-9874
Email dk...@intetron.com
Web http://www.intetron.com

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RE: Odd CE Marking Question

[donald . hanson]

Kevin,

The LVD covers devices that operate from a source 50V AC or 75 V DC, since
your dummy operates from 30 V it is not covered by the scope of the LVD. In
fact it is illegal to claim compliance to it.

Don Hanson
Tektronix,. Inc. 

-Original Message-
From:   Grant, Tania (Tania) [mailto:tgr...@lucent.com]
Sent:   Friday, April 06, 2001 10:01 AM
To: emc-p...@ieee.org; 'wo...@sensormatic.com'
Subject:        RE: Odd CE Marking Question 

Kevin,

I would CE mark the dummy.   My justification is as follows:
it is low voltage and safe, and therefore meets the LVD.   I do think that
the LVD applies even if the dummy itself does not have a power source.
Consider that with the wrong power source applied, there COULD be a hazard
(unlikely, but possible).   There could be other components inside that
could ignite, etc., once power is applied.   By marking it you are telling
everyone in Europe that this dummy has been evaluated to safety and meets
the requirements.As for the EMC Directive, I don't think that this one
applies since the dummy neither receives nor generates signals at any
frequency.   
 
Tania Grant,  tgr...@lucent.com
Lucent Technologies, Switching Solutions Group
Intelligent Network and Messaging Solutions

--
From:   wo...@sensormatic.com[SMTP:wo...@sensormatic.com]
Reply To:   wo...@sensormatic.com
Sent:   Friday, April 06, 2001 9:29 AM
To: emc-p...@ieee.org
Subject:    RE: Odd CE Marking Question 


If the product does not include the power source, the LVD
does not apply
since the source voltage is not within the range covered by
the directive.
If the power source is included with the product, the LVD
applies to the
complete product, and I would say that EN 60950 applies. 

The EMC directive applies to all electrical equipment. I
would not classify
this product as a security device since it's primary
function is not to
protect persons or property; rather, the primary function is
to blink an
LED. You have no control over what people will infer from
that light.
Therefore, the generic emissions and immunity standards
apply as do the
power line harmonics and flicker standards. I believe that
it can be safely
said that, based upon inspection of the product and its
schematic, there is
no need to perform tests, just declare compliance with the
standards and
place your justifications in the technical file. Perhaps,
the cleanest
method would be to ask a Notified Body for an opinion and
place it in the
technical file.

--
From:  Kevin Harris
Sent:  Friday, April 06, 2001 12:04 PM
To:  EMC-PSTC (E-mail)
            Subject:  Odd CE Marking Question 


Hello Group,

I just had a question posed to me that made me think a
little bit. So I will
pose it to all of you.  First some preamble. A device is
going to be made
for the European market. It is in fact a "dummy" device in
that it looks
like the real thing but it is not. The only electronics
inside is a bridge
rectifier and a RC circuit to blink a LED. The device can be
powered by
either an AC or DC source up to 30 V. The power source is
not supplied. For
this industry (security) there is a product family standard
for EMC. The
device is not a mock up for store display purposes but is in
fact used in
the industry to give the impression that there are more of
these devices
around than there really are.

So the moment has arrived, do you CE mark the device? If you
say yes, what
directive did you apply? If you say no, what is your
reasoning?


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 

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RE: Odd CE Marking Question

[Wagner, John P (John)]

Let me take a wild stab at this one.

First, presumably the value of  this "dummy" device is that it convinces
its "audience" that it indeed is a real security device.  Given that, it
seems that the more accurately it mimics the real device the better.  If
the real device is CE marked, you probably should CE mark the dummy.  If
not, those alert individuals wishing to circumvent security will be able
to tell the real from the dummy simply be looking for the presence of a
CE Mark.

Second,  if you do CE mark the dummy, why not apply the same standards
as you apply to the real product.  After all, even though it is a dummy
device, it still is a security device and presumably falls in the same
product category as the real device.  Because of the dummy device's
simlplicity, testing for or declaring compliance should not be
aprticularly involved. 
John P. Wagner
AVAYA Communication
1300 W. 120th Ave, Room B3-D16
Phone/Fax: (303) 538-4241
johnwag...@avaya.com




> --
> From: Kevin Harris[SMTP:harr...@dscltd.com]
> Reply To: Kevin Harris
> Sent: Friday, April 06, 2001 10:03 AM
> To:   EMC-PSTC (E-mail)
> Subject:  Odd CE Marking Question 
> 
> 
> Hello Group,
> 
> I just had a question posed to me that made me think a little bit. So
> I will
> pose it to all of you.  First some preamble. A device is going to be
> made
> for the European market. It is in fact a "dummy" device in that it
> looks
> like the real thing but it is not. The only electronics inside is a
> bridge
> rectifier and a RC circuit to blink a LED. The device can be powered
> by
> either an AC or DC source up to 30 V. The power source is not
> supplied. For
> this industry (security) there is a product family standard for EMC.
> The
> device is not a mock up for store display purposes but is in fact used
> in
> the industry to give the impression that there are more of these
> devices
> around than there really are.
> 
> So the moment has arrived, do you CE mark the device? If you say yes,
> what
> directive did you apply? If you say no, what is your reasoning?
> 
> 
> Best Regards,
> 
> 
> Kevin Harris
> Manager, Approval Services
> Digital Security Controls
> 3301 Langstaff Road
> Concord, Ontario
> CANADA
> L4K 4L2
> 
> Tel: +1 905 760 3000 Ext. 2378
> Fax +1 905 760 3020
> 
> Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 
> 
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
> 
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> 
> To cancel your subscription, send mail to:
>  majord...@ieee.org
> with the single line:
>  unsubscribe emc-pstc
> 
> For help, send mail to the list administrators:
>  Michael Garretson:pstc_ad...@garretson.org
>  Dave Healddavehe...@mediaone.net
> 
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>  Jim Bacher: j.bac...@ieee.org
> 
> All emc-pstc postings are archived and searchable on the web at:
> http://www.rcic.com/  click on "Virtual Conference Hall,"
> 
> 

RE: Odd CE Marking Question

[Grant, Tania (Tania)]

Kevin,

I would CE mark the dummy.   My justification is as follows:   it is low
voltage and safe, and therefore meets the LVD.   I do think that the LVD
applies even if the dummy itself does not have a power source.   Consider
that with the wrong power source applied, there COULD be a hazard (unlikely,
but possible).   There could be other components inside that could ignite,
etc., once power is applied.   By marking it you are telling everyone in
Europe that this dummy has been evaluated to safety and meets the
requirements.As for the EMC Directive, I don't think that this one
applies since the dummy neither receives nor generates signals at any
frequency.   
 
Tania Grant,  tgr...@lucent.com
Lucent Technologies, Switching Solutions Group
Intelligent Network and Messaging Solutions

> --
> From: wo...@sensormatic.com[SMTP:wo...@sensormatic.com]
> Reply To: wo...@sensormatic.com
> Sent: Friday, April 06, 2001 9:29 AM
> To:   emc-p...@ieee.org
> Subject:  RE: Odd CE Marking Question 
> 
> 
> If the product does not include the power source, the LVD does not apply
> since the source voltage is not within the range covered by the directive.
> If the power source is included with the product, the LVD applies to the
> complete product, and I would say that EN 60950 applies. 
> 
> The EMC directive applies to all electrical equipment. I would not
> classify
> this product as a security device since it's primary  function is not to
> protect persons or property; rather, the primary function is to blink an
> LED. You have no control over what people will infer from that light.
> Therefore, the generic emissions and immunity standards apply as do the
> power line harmonics and flicker standards. I believe that it can be
> safely
> said that, based upon inspection of the product and its schematic, there
> is
> no need to perform tests, just declare compliance with the standards and
> place your justifications in the technical file. Perhaps, the cleanest
> method would be to ask a Notified Body for an opinion and  place it in the
> technical file.
> 
> --
> From:  Kevin Harris
> Sent:  Friday, April 06, 2001 12:04 PM
> To:  EMC-PSTC (E-mail)
> Subject:  Odd CE Marking Question 
> 
> 
> Hello Group,
> 
> I just had a question posed to me that made me think a little bit. So I
> will
> pose it to all of you.  First some preamble. A device is going to be made
> for the European market. It is in fact a "dummy" device in that it looks
> like the real thing but it is not. The only electronics inside is a bridge
> rectifier and a RC circuit to blink a LED. The device can be powered by
> either an AC or DC source up to 30 V. The power source is not supplied.
> For
> this industry (security) there is a product family standard for EMC. The
> device is not a mock up for store display purposes but is in fact used in
> the industry to give the impression that there are more of these devices
> around than there really are.
> 
> So the moment has arrived, do you CE mark the device? If you say yes, what
> directive did you apply? If you say no, what is your reasoning?
> 
> 
> Best Regards,
> 
> 
> Kevin Harris
> Manager, Approval Services
> Digital Security Controls
> 3301 Langstaff Road
> Concord, Ontario
> CANADA
> L4K 4L2
> 
> Tel: +1 905 760 3000 Ext. 2378
> Fax +1 905 760 3020
> 
> Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 
> 
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
> 
> Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/
> 
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>  majord...@ieee.org
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> 
> ---
> This message is from the IEEE EMC Society Product Safety
> Technical Committee emc-pstc discussion list.
> 
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RE: Odd CE Marking Question

[WOODS]

If the product does not include the power source, the LVD does not apply
since the source voltage is not within the range covered by the directive.
If the power source is included with the product, the LVD applies to the
complete product, and I would say that EN 60950 applies. 

The EMC directive applies to all electrical equipment. I would not classify
this product as a security device since it's primary  function is not to
protect persons or property; rather, the primary function is to blink an
LED. You have no control over what people will infer from that light.
Therefore, the generic emissions and immunity standards apply as do the
power line harmonics and flicker standards. I believe that it can be safely
said that, based upon inspection of the product and its schematic, there is
no need to perform tests, just declare compliance with the standards and
place your justifications in the technical file. Perhaps, the cleanest
method would be to ask a Notified Body for an opinion and  place it in the
technical file.

--
From:  Kevin Harris
Sent:  Friday, April 06, 2001 12:04 PM
To:  EMC-PSTC (E-mail)
Subject:  Odd CE Marking Question 


Hello Group,

I just had a question posed to me that made me think a little bit. So I will
pose it to all of you.  First some preamble. A device is going to be made
for the European market. It is in fact a "dummy" device in that it looks
like the real thing but it is not. The only electronics inside is a bridge
rectifier and a RC circuit to blink a LED. The device can be powered by
either an AC or DC source up to 30 V. The power source is not supplied. For
this industry (security) there is a product family standard for EMC. The
device is not a mock up for store display purposes but is in fact used in
the industry to give the impression that there are more of these devices
around than there really are.

So the moment has arrived, do you CE mark the device? If you say yes, what
directive did you apply? If you say no, what is your reasoning?


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com <mailto:harr...@dscltd.com> 

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Odd CE Marking Question

[Kevin Harris]

Hello Group,

I just had a question posed to me that made me think a little bit. So I will
pose it to all of you.  First some preamble. A device is going to be made
for the European market. It is in fact a "dummy" device in that it looks
like the real thing but it is not. The only electronics inside is a bridge
rectifier and a RC circuit to blink a LED. The device can be powered by
either an AC or DC source up to 30 V. The power source is not supplied. For
this industry (security) there is a product family standard for EMC. The
device is not a mock up for store display purposes but is in fact used in
the industry to give the impression that there are more of these devices
around than there really are.

So the moment has arrived, do you CE mark the device? If you say yes, what
directive did you apply? If you say no, what is your reasoning?


Best Regards,


Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2

Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020

Email: harr...@dscltd.com  

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All emc-pstc postings are archived and searchable on the web at:
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