Re: [PSES] Experts and Wisdom

[Michael Derby]

It’s an old one but it still makes me smile…….   Regarding the difference 
between wisdom and knowledge…….

 

 

Knowledge is knowing that a tomato is a fruit.

Wisdom is knowing not to put it in a fruit salad.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Pettit, Ghery
Sent: 03 January 2012 20:57
To: McInturff, Gary; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: Experts and Wisdom

 

Could well have been.

 

Ghery S. Pettit

 

From: McInturff, Gary [mailto:gary.mcintu...@esterline.com] 
Sent: Tuesday, January 03, 2012 12:57 PM
To: Pettit, Ghery; 'EMC-PSTC@LISTSERV.IEEE.ORG'
Subject: RE: Experts and Wisdom

 

Probably right after the battle of Gettysburg

 

Gary

 

From: Pettit, Ghery [mailto:ghery.pet...@intel.com] 
Sent: Tuesday, January 03, 2012 12:23 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Experts and Wisdom

 

“Judgment comes from experience.  Experience comes from poor judgment.”   
Robert E. Lee

 

Ghery S. Pettit

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Doug Powell
Sent: Tuesday, January 03, 2012 10:44 AM
To: EMC-PSTC
Subject: Experts and Wisdom

 

 

 

All,

 

With some folks retiring and others I know are changing careers (recently 
termed “retooling”), I had some pensive thoughts about losing many folks who 
are experts in the field or those with great wisdom.  So it occurs to me, I 
would like to hear your favorite quotes on Wisdom and Experts.  I’ll prime the 
pump with a few I know.

*   Wisdom is the “stuff” you get immediately after you need it most. 
*   An expert is one who has already made all of the necessary mistakes. 
*   ex·pert/ˈekspərt/  Noun: compound word  “ex + spurt”.  EX meaning “has 
been”, SPURT meaning a “drip under pressure”, therefore a “Has been drip under 
pressure!”

thanks, –doug  

Douglas E Powell

Independent Compliance Engineering
doug...@gmail.com 
http://www.linkedin.com/in/dougp01

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Re: [PSES] Radiated Emissions Testing of Intentional Radiators - Practicalities?

[Michael Derby]

Hi James,

 

You can try putting the support access point down on the floor, outside the
beam of your site's measurement antenna.   Covering it with a little spare
anechoic material helps too.

 

If you're just worried about the main fundamental signal (2.4 GHz, etc.)
from your support access point, you can ensure the antenna from it is not in
line with your site's measuring antenna.   If possible, you could even
remove the support access point's regular (omni) antenna and fit a more
directional horn to it.   This would allow you to point the support access
point's antenna at your 'EUT' and not at your site's receiving antenna.

 

If you're worried about the general broader emissions from your supporting
access point, and if the floor location with anechoic tent isn't helping,
maybe you could locate it outside your chamber and have an RF cable through
a waveguide to the supporting access point antenna.

 

I hope this helps a little.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Pawson, James [mailto:james.paw...@echostar.com] 
Sent: 10 January 2012 16:13
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Radiated Emissions Testing of Intentional Radiators -
Practicalities?

 

 

Hello list members,

 

We are wanting to test one of our products, which contains a WiFi interface,
in our anechoic chamber. To ensure the WiFi is active we would need to set
up antennae in the anechoic chamber itself - the irony of introducing radio
into a radio-quiet environment is not lost on me.

 

I'm concerned about separating out the emissions from the WiFi access point
and the emissions of the equipment under test. Does anyone have any
practical pointers / hints / tips / experience / pitfalls of doing this?

 

Thanks in advance

James

 

James Pawson

Leading Hardware Engineer - EMC

EchoStar Europe

 

 

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Re: [PSES] RTTE - Alert Calss 2 identifier

[Michael Derby]

Hello,

 

I'm not aware of any requirement for it to be on the DoC.   Just the
equipment, the packaging and the user manual.

 

I find this labelling guidance document very useful:

 

http://ec.europa.eu/enterprise/sectors/rtte/files/guidance/guidance_en.pdf

 

 

Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 17 January 2012 09:12
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RTTE - Alert Calss 2 identifier

 

For Class 2 RTTE equipment, the Alert symbol shall be affixed to the
equipment as part of the CE marking.

 

I can't find any requirements that the Alert symbol should be included in
the Declaration of Conformity document.

Shall it be included in the DoC or not?

Best regards

Amund  

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Re: [PSES] FCC requirements for Inductive Chargers

[Michael Derby]

Hello,

Please note that not all of these wireless chargers would be Part 15
(47CFR15, as stated).   Some might be Part 18, depending on the operation.

I think you'd need to look at the operation of the charger and see if any
form of 'handshaking' is taking place; even if it's just a recognition
signal.
If it is, you could say that's data or communication and Part 15 could
apply.
If not, this could be a Part 18 device.

It's a little like the European debate of  Does the EMC Directive or RTTE
Directive apply?
You need to ask yourself if it is just using RF for a process, or if there
is some form of communication taking place.


Thanks,   Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com] 
Sent: 25 January 2012 19:03
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC requirements for Inductive Chargers

ICNIRP
29CFR1926
29CFR1910
ANSI C95.x
47CFR15
CISPR 11,12,14,22

When human exposure mentioned, I think about Star Trek's 'subnucleonic
radiation' - will CISPR32 address these limits?

Brian

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Moshe Henig
Sent: Wednesday, January 25, 2012 10:19 AM
To: emc-pstc-requ...@listserv.ieee.org; emc-p...@ieee.org;
EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: FCC requirements for Inductive Chargers

Thanks group,
But what are the FCC requirements for wireless chargers that does not comply
with WPC?
Thanks
Moshe

2012/1/23 Moshe Henig moshe.he...@gmail.com

Dear Group,

What are FCC requirements for Mobile Phone Battery Inductive Charger and
what are the conditions?

Thanks

Moshe Henig Dipl. Ing.
NCE SMIEEE
iNarte Certified EMC engineer
EMC and Safety consultant
Mobile +972 52 8951449
Skype mhenig
he...@bezeqint.net

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Re: [PSES] FCC requirements for Inductive Chargers

[Michael Derby]

 

This makes me realise how boring my reply was.

 

I'm sorry.

 

I'll try harder next time.

 

 

I don't want to be one of those guys in the red shirt who only turns up for
one episode and you know he's going to get killed.

 

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Bob Richards [mailto:b...@toprudder.com] 
Sent: 25 January 2012 19:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC requirements for Inductive Chargers

 


Is that the same gallium alloy used in the turbo entabulator? ;-)



--- On Wed, 1/25/12, John Woodgate j...@jmwa.demon.co.uk wrote:


From: John Woodgate j...@jmwa.demon.co.uk
Subject: Re: FCC requirements for Inductive Chargers
To: EMC-PSTC@LISTSERV.IEEE.ORG
Date: Wednesday, January 25, 2012, 2:18 PM

In message b4c40db49fd3404c80870094ce1b0...@tamuracorp.com
http://us.mc1616.mail.yahoo.com/mc/compose?to=B4C40DB49FD3404C80870094CE1B0
e...@tamuracorp.com , dated Wed, 25 Jan 2012, Brian Oconnell
oconne...@tamuracorp.com
http://us.mc1616.mail.yahoo.com/mc/compose?to=oconne...@tamuracorp.com 
writes:

 When human exposure mentioned, I think about Star Trek's 'subnucleonic
radiation' - will CISPR32 address these limits?

Yes, in the 6th edition, published in 2042. I've already commissioned a
supply of gallium foil helmets to screen against the Higgs field.
-- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
Some people who are peeling the finch of the financial crisis are thinking
of
biting a rook.

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Re: [PSES] Is this common knowledge - Electrical Ratings

[Michael Derby]

Labelling is an interesting topic, though also a source of great frustration
it seems.   In response to a couple of the comments below..


 As a consumer, why do I need to know the meaning of EMC and Radio
markings?
 As a consumer, I only need to know efficiency ratings at the time I
choose the appliance/equipment.

I wonder how many people understand the Alert Symbol (!) of the RTTE
Directive.   When you see the Alert Symbol on your radio product (such as on
most mobile phones, wireless internet, UWB devices, etc.), it is often there
to alert the user that there is a restriction of use for the product.
The user then knows (???) to go to the user manual and read the restrictions
of their device before they power it on.
.right?   :-)


 Such ratings need not be a permanent part of the equipment, but can be
on a disposable tag.  There is no post-purchase need for such data.

One word. e-bay
:-)
Do we all buy our products new, from the original supplier?


Just to stir the pot,

Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 28 January 2012 20:39
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Is this common knowledge - Electrical Ratings

Hi Peter:


 I believe rating markings, energy efficiency ratings, EMC and Radio 
 markings should be harmonized worldwide and governments/regulators 
 should be involved to train consumers the meaning these markings.

As a consumer, why do I need to know the meaning of EMC and Radio markings?

As a consumer, I only need to know efficiency ratings at the time I choose
the appliance/equipment.
Such ratings need not be a permanent part of the equipment, but can be on a
disposable tag.  There is no post-purchase need for such data.

As a consumer, I simply plug the equipment into the wall outlet.  The
equipment is pre-configured for voltage and is provided with the proper plug
for my house.  I don't need to know voltage, current, watts, or frequency
ratings of the equipment.

If a house circuit-breaker trips when I turn on my equipment, I may need to
know the current or power rating of my equipment in order to balance the
load on the circuit.

So, who are the rating markings for?  The certifiers and regulators.  The
ratings could just as well be in the accompanying documents.


Best regards,
Rich
;-)

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Re: [PSES] GPS Receivers

[Michael Derby]

Hello Steve,

 

It's not a broadcast receiver and therefore the RTTE Directive does apply.

 

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

 

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

 

At the RTTECA (RTTE Notified Body group) we wrote the following guidance..

http://rtteca.com/TGN16.pdf

I hope it's useful.

 

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

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

 

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

 

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

 

I hope this helps,

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

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

 

All,

 

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

 

 

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

 

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

 

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

 

Best regards, 

 

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com http://www.acstestlab.com/ 

 

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

 

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Re: [PSES] GPS Receivers

[Michael Derby]

Hi Steve,

 

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

 

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

 

I hope that makes sense?

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

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

 

Michael,

 

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

 

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

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

 

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

 

Best regards,

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com http://www.acstestlab.com/ 

 

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

 

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

 

Hello Steve,

 

It's not a broadcast receiver and therefore the RTTE Directive does apply.

 

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

 

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

 

At the RTTECA (RTTE Notified Body group) we wrote the following guidance..

http://rtteca.com/TGN16.pdf

I hope it's useful.

 

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

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

 

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

 

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

 

I hope this helps,

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

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

 

All,

 

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

 

 

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

 

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

 

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

 

Best regards, 

 

 

Steve O'Steen

EMC Director

Advanced Compliance Solutions, Inc.

sost...@acstestlab.com

770-831-8048 ext. 210

www.acstestlab.com http://www.acstestlab.com/ 

 

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

 

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

Re: [PSES] RTTE compliance test reports

[Michael Derby]

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

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

 

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

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

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

 

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

Thanks and regards,

Scott

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Re: [PSES] RTTE compliance test reports

[Michael Derby]

Hello Amund.

 

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

 

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

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

 

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

 

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

 

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

 

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

 

Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

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

 

My input on this issue:

 

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

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

 

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

 

Best regards

Amund

 

 

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

 

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

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

 

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

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

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

 

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

Thanks and regards,

Scott

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Re: [PSES] RTTE compliance test reports

[Michael Derby]

Hello,

 

Not quite Scott, I think what Thomas and Charlie were (correctly) saying,
was..

 

With harmonized and published standard, we do not need to use accredited
laboratory for the test.  

...in fact, regardless of whether you use a harmonised standard or not, the
lab does not need to be accredited.

 

If a laboratory is not accredited, how does a client know if the laboratory
is capable of doing the required tests.

..that's a very good question and it explains why so many accredited labs
(with their extra overheads) are still in business.   You somehow need to
trust your lab.   There's no certification for the RTTE or EMC Directives,
so all the responsibility is on the person signing the DoC.   Good idea to
find a good lab!   That's why people use an accredited lab or one that they
really trust.

 

The capability includes equipment and its calibration, knowledge of standard
interpretation and skill set of actual testing.

.Yes.   You could look at the capability of the lab, how they calibrate
their equipment, chat to them about the standards and the staff, visit their
lab, etc.

 

 

Michael

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 29 February 2012 12:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RTTE compliance test reports

 

Hi Thomas,

Thanks for your advice.  With harmonized and published standard, we do not
need to use accredited laboratory for the test.  If a laboratory is not
accredited, how does a client know if the laboratory is capable of doing the
required tests.  The capability includes equipment and its calibration,
knowledge of standard interpretation and skill set of actual testing.

Regards,

Scott


On 29/2/12 6:45 AM, Thomas Cokenias t...@tncokenias.org wrote:

Hi Scott,

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

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

best regards

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


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

RTTE compliance test reports 

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

Thanks and regards,

Scott

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Attachments

Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

[Michael Derby]

I think there are two things to consider here.   Firstly, the word 'opinion'
is important, specifically with regard to the fact that it's not
'certification'.   J

 

Secondly, I think it could depend on the circumstances of this apparent
problem.

 

For example, you could easily test to all harmonised standards and pass, yet
still experience an interference problem in the real world.   It's very
possible and has happened on many occasions.

The answer to this is that these harmonised standards give a good
presumption of conformity but never give a guarantee of conformity.

 

Even if you meet all the harmonised standards tests.. If your device causes
a problem in the real world, you'll need to work to fix it.

 

Similarly, if a Notified Body assesses some partial testing of a device,
that too would help give you confidence and assist in your presumptions to
sign your DoC.

However, much like the folks at ETSI and CENELEC, the Notified Body cannot
see into the future and therefore cannot know every eventuality.

 

Now, with the Notified Body aspect, it could come down to their whole
approach to the situation..

 

Let's say that the Notified Body did a good job of assessing the device and
its environment but, just like with the harmonised standard approach,
something unforeseen happens and interference exists.   I think in that case
the Notified Body's opinion may still have been ok; just like you could say
a harmonised standard is assumed to be ok.   However, everyone learned a
lesson and the manufacturer must fix the problem.

 

However, if the Notified Body completely missed something,  or allowed
testing to completely the wrong limits, or forgot to consider the other
devices using the band, or perhaps assessed the transmit parameters but
ignored receiver parameters, etc. etc. etc. and the interference was a
direct result of this omission.   Well, then I suspect the Notified Body
would need to answer to their accreditation body or the commission.

...just like Gert Gremmen said in his reply.

 

If you ask two Notified Bodies for their opinions and they give different
opinions, that's ok, that can happen.   If you decide to sell that device,
you must put both the Notified Body numbers on the product of course.
Again, this is because it's not certification, it's an opinion.   Even if
the Notified Body says no, you can sell the device with their NB number on
it.   If the device has a problem in the real world and a regulator contacts
the Notified Body, the Notified Body can say sure, we gave our opinion, we
said no.

 

 

Some people like the freedom of a DoC system.   Some don't like the
responsibility.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: John Cotman [mailto:john.cot...@conformance.co.uk] 
Sent: 08 March 2012 10:04
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

 

Notified Body opinion is supposed to be authoritative.

Legally, standards are voluntary, compliance with the Directive is
mandatory.  So, if the NB says it meets the Directive, then you've been told
that you meet the law, and you have good evidence to support due
diligence.  If the NB turn out to be wrong, they should have plenty of
insurance cover in place.

However:

1) Your customers may want to see a test cert with a nice pass to a
standard, and not really like an NB statement.

2) What happens when 2 different NBs come to a different conclusion
about the legal compliance of an item, always fun in court?

 

John C

 

  _  

From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: 08 March 2012 09:54
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

 

The NOBO will have a serious problem ;)

 

No without joking, that is possible, especially

if the TCF route chosen was because the device absolutely cannot

meet a standard for physical, or design reasons.

 

If the NOBO overlooked something evident, such as spurious

emission limits without any necessity, they will have a problem

with their accreditations (if they are).

 

For the product it makes no difference, their opinion has been made.

 

But as the manufacturer remains liable for compliance, they better

know what they risk. 

 

 

Regards,

Ing.  Gert Gremmen, BSc

 

 

 

g.grem...@cetest.nl

www.cetest.nl


Kiotoweg 363

3047 BG Rotterdam

T 31(0)104152426
F 31(0)104154953

 

Before printing, think about the environment. 

 

 

Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Anthony Thomson
Verzonden: Thursday, March 08, 2012 10:31 AM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Notified Body Opinion vs. Harmonised Standards (RTTED)

 

What should happen if a Notified Body has given a positive opinion that a
wireless device complies with the RTTE Directive (Articles 3.1a, 3.1b, 
3.2) based on limited testing results (not to Harmonised Standards

Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

[Michael Derby]

Hello,

I guess one example might be the (relatively) recent issue with weather radar 
and 5 GHz WLAN devices.   Products were tested and complied with harmonised 
standards.   As it happened, the devices were unable to detect weather radar 
and an interference potential existed.   It's just something that wasn't really 
considered during the writing of the standard and it wasn't expected.
Products met the harmonised standard but did not meet the Directive!
I don't know if any/many products were recalled or asked to switch off but I do 
know that manufacturers needed to find a way to detect and avoid weather radars 
(basically, fix the problem).   Otherwise, if they did not, they could be 
failing to meet the Directive (even though they met the harmonised standard).
Of course, it wasn't long before a new Official Journal was released with notes 
to supplement the harmonised standard and instruct the manufacturer that they 
needed to do more than just meet the standard.

It could happen at any time and the text even leans towards it a little.   If 
you look at the early commission decisions for devices like UWB, they include 
text that really imply things along the lines of  We'll give this a go and 
see.   If there's any interference, we'll re-think it
It helps to get harmonised standards out there and get the technology moving, 
without having to wait until the perfect standard exists.

I think the situation you're leaning towards below is if two devices interfere 
with each other and one is the villain and one is not.   In that instance, I'm 
not saying the 'good guy' would necessarily need to switch off.

That said... imagine a licensed device and an unlicensed device having a battle 
of interference.   (Particularly somewhere like the USA).   One transmitter has 
paid a lot of money for the license and the other has not.   Who do you think 
will get to stay switched on?   :-)

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Macy [mailto:m...@basicisp.net] 
Sent: 08 March 2012 17:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

--- micha...@acbcert.com wrote:

From: Michael Derby micha...@acbcert.com
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)
Date: Thu, 8 Mar 2012 14:44:30 +

...snip...

Even if you meet all the harmonised standards tests…. If your device causes a 
problem in the real world, you’ll need to work to fix it.

...snip...

Michael,

Would you clarify. 

When does the responsibility for a product's susceptibility fall back onto THAT 
Product's manufacturer?

Especially when the only way to stop bothering the 'poorly made' product is to 
NOT operate your 'well made' product?

Regards,

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Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

[Michael Derby]

exactly John, hence the 2-part FCC statement on the label of the
unlicensed device.   :-)


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 08 March 2012 17:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notified Body Opinion vs. Harmonised Standards (RTTED)

In message 1b7f01ccfd51$64d7e2f0$2e87a8d0$@acbcert.com, dated Thu, 8 Mar
2012, Michael Derby micha...@acbcert.com writes:

That said... imagine a licensed device and an unlicensed device having 
a battle of interference.   (Particularly somewhere like the USA). 
One transmitter has paid a lot of money for the license and the other 
has not.   Who do you think will get to stay switched on? :-)

That isn't arbitrary: unlicensed devices are normally allowed on condition
that they have no redress against legal emissions.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John
Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK If 'QWERTY' is an
English keyboard, what language is 'WYSIWYG' for?

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Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

[Michael Derby]

Yes, I think you're thinking of the RTTE Directive Monrad.

For the RTTE Directive, the lack of a harmonised standard would require a
Notified Body opinion.
For the EMC Directive, the use of a Notified Body is optional.

Remember that if the RTTE Directive applies to your device, then the EMC
Directive does not apply.   You don't apply them both.

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 12 March 2012 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

Monrad

My understanding is that unless the DOC cites the current harmonized 
standards, then a company must go to a notified body to get an 
exception and cite that finding/exception in the DOC

That is not required - the use of a NB is completely voluntary under the EMC
Directive as per Article 7. You can put whatever standards you choose on
your DoC.

Regards
Charlie

-Original Message-
From: Monrad Monsen [mailto:monrad.mon...@oracle.com]
Sent: 12 March 2012 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

John,
Regarding the question Are you implying that a notified body would freely
support a product not updating to comply with new revisions of the
harmonized standards?, you wrote:
  Yes: It's possible. For example, an update might well require   emission
testing above 1 GHz. If the product clearly has no   possibility of
producing such emissions, since previous tests   have shown no significant
emissions above 100 MHz, it does   not need to be tested. But the
manufacturer can justify that   in his EMC assessment, it is not necessary
to involve a   Notified Body.
The declaration of conformity (DOC) must be signed by the manufacturer using
the harmonized standards.  Your example is inadequate.  Avoiding even
testing the new radiated emissions testing above 1GHz for based on whether
there is significant emissions above 100 MHz is very risky.
In fact, the emissions standard (EN55022:2006+A1:2007) states product must
be tested if the product has a clock/oscillator over 108MHz.  More likely,
the product will be sold also in USA and Canada, so the product is already
tested above 1GHz even if there was a slightly different test methodology.
My e-mail was addressing the case if a hardware change is required to meet
the new requirement.

Are you saying that a manufacturer can justify in his EMC assessment
to avoid having to complying with the new 4dB tighter limits given in the
1-3GHz range and implementing a known hardware change?

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an exception and
cite that finding/exception in the DOC.  To do any less would invite some
regulator to take time to investigate your product documentation with a risk
of either stopping a product in customs or demanding a recall of any
products that did get through to customers.

You also state:
  Again, no Notified Body need be involved. Revised standards apply   in
Europe only after a (normally) 3 year transition period. For   some types
of product, that is short compared with the normal   product replacement
cycle, but surely it isn't for ITE. Your   preference is thus often
achievable.
Might be true for laptops, but I normally deal with professional products
like servers and massed storage products that  have a sales life going as
long as  4-8 years with minor updates (drop-in CPU updates or drop-in
replacements with faster disk or tape drives).  Even beyond the period of
new product sales, there is also a market for used product sales that could
bring products to Europe from outside years later.  As you know, the
directives apply to all products (new or used) at the time when it is
placed on the market and/or put into service which impacts used product
sales when it first enters the European market.

By the way, the Europe Commission issued Decision 2010/571/EU on 24 Sep
2010 that announced expiration dates for several RoHS exemptions that were
within a year of the decision.  Fortunately, the more frequently used RoHS
exemptions 7(c)-III and 11(b) expiration dates were given two years notice.
Hence, even your hopeful 3 year transition period is not rigorously
followed by Europe.

Note:  All opinions expressed in this e-mail are my own only and do not
necessarily reflect the opinions of any company I work for or have ever
worked for.   In fact, my opinions may change in the progress of this
discussion.

Monrad

On 3/12/2012 10:18 AM, John Woodgate wrote:
 In message 4f5e1878.2000...@oracle.com, dated Mon, 12 Mar 2012, 
 Monrad Monsen monrad.mon...@oracle.com writes:

 You made a very interesting statement ... especially for someone 
 whose e-mail address indicates that you are in Europe.  You said:
 You have also complicated the issue

Re: [PSES] Identifying Apparatus in Europe Declarations of Conformity (DOCs)

[Michael Derby]

Then it's an RTTE Device.

 

If you have a piece of apparatus that has no radio or telecoms
(wirelessless?), you would normally apply the EMC and Safety Directives.
Then you add a radio device to it and it becomes an RTTE Directive device.

The RTTE Directive includes EMC (article 3.1b) and Safety (article 3.1a)
and states that once you apply the RTTE Directive, you no longer apply the
EMC and Safety Directives.

 

Now, you might say.. But my device is complex and the harmonised standards
I apply are in the EMC OJ and the Safety OJ, not the RTTE OJ!

..well, that's ok, you can use standards from the EMC OJ and the Safety OJ
to demonstrate compliance with articles 3.1b and 3.1a of the RTTE Directive
but that doesn't mean you're applying the EMC or Safety Directives.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 13 March 2012 12:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

 

 Or a laptop (EMC) with a wireless mouse (RTTE)?

 

Presumably there'd be some wireless in the laptop as well J

 

Regards

Charlie

 

From: Robert Heller [mailto:rehel...@mmm.com] 
Sent: 13 March 2012 11:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

 

What if your equipment is multi-functional? Say a passport reader that has a
RFID mode (RTTE) as well as a functional mode to read UV inks or
invisible data (EMC). Or a laptop (EMC) with a wireless mouse (RTTE)? 

Bob Heller
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252
=




From:Michael Derby micha...@acbcert.com 
To:'Charlie Blackham' char...@sulisconsultants.com,
EMC-PSTC@LISTSERV.IEEE.ORG 
Date:03/13/2012 04:33 AM 
Subject:RE: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs) 
Sent by:emc-p...@ieee.org 

  _  




Yes, I think you're thinking of the RTTE Directive Monrad.

For the RTTE Directive, the lack of a harmonised standard would require a
Notified Body opinion.
For the EMC Directive, the use of a Notified Body is optional.

Remember that if the RTTE Directive applies to your device, then the EMC
Directive does not apply.   You don't apply them both.

Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [ mailto:char...@sulisconsultants.com
mailto:char...@sulisconsultants.com] 
Sent: 12 March 2012 20:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

Monrad

My understanding is that unless the DOC cites the current harmonized 
standards, then a company must go to a notified body to get an 
exception and cite that finding/exception in the DOC

That is not required - the use of a NB is completely voluntary under the EMC
Directive as per Article 7. You can put whatever standards you choose on
your DoC.

Regards
Charlie

-Original Message-
From: Monrad Monsen [ mailto:monrad.mon...@oracle.com
mailto:monrad.mon...@oracle.com]
Sent: 12 March 2012 18:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Identifying Apparatus in Europe Declarations of
Conformity (DOCs)

John,
Regarding the question Are you implying that a notified body would freely
support a product not updating to comply with new revisions of the
harmonized standards?, you wrote:
 Yes: It's possible. For example, an update might well require   emission
testing above 1 GHz. If the product clearly has no   possibility of
producing such emissions, since previous tests   have shown no significant
emissions above 100 MHz, it does   not need to be tested. But the
manufacturer can justify that   in his EMC assessment, it is not necessary
to involve a   Notified Body.
The declaration of conformity (DOC) must be signed by the manufacturer using
the harmonized standards.  Your example is inadequate.  Avoiding even
testing the new radiated emissions testing above 1GHz for based on whether
there is significant emissions above 100 MHz is very risky.
In fact, the emissions standard (EN55022:2006+A1:2007) states product must
be tested if the product has a clock/oscillator over 108MHz.  More likely,
the product will be sold also in USA and Canada, so the product is already
tested above 1GHz even if there was a slightly different test methodology.
My e-mail was addressing the case if a hardware change is required to meet
the new requirement.

Are you saying that a manufacturer can justify in his EMC assessment
to avoid having to complying with the new 4dB tighter limits given in the
1-3GHz range and implementing a known hardware change?

My understanding is that unless the DOC cites the current harmonized
standards, then a company must go to a notified body to get an exception and
cite that finding/exception in the DOC.  To do any less would

Re: [PSES] Compliance costs too much.

[Michael Derby]

I guess to measure the cost of compliance; you certainly need to understand
the cost of non-compliance.

Safety, with regard to reputation, conscience, law suits, sleeping well at
night, jail time, etc.
EMC and Radio, with regard to quality, reputation, harmony within society,
etc.

In the USA, Canada and Europe, I see very real examples of how poor
compliance rates do lead to a tightening in the requirements.
So, you could also consider it an investment.

Just a thought.   :-)

Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Richard Nute [mailto:ri...@ieee.org] 
Sent: 30 March 2012 12:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Compliance costs too much.

I once worked with an EMC engineer who measured the performance of himself
and his time by the cost of the components that were used in the equipment
solely for the purpose of EMC control.

His objective was to reduce the cost of compliance by advising designers of
careful layout so as to minimize the need for EMC components.

Safety is a bit different because many safety components are also functional
components.
Nevertheless, a ground wire can be eliminated if double-insulation is
employed.  In this example, a cost trade-off between the power cord and the
extra insulation.  But, these days, most primary circuit designs are indeed
double-insulated as transformers simply don't use internal shields.

Enclosures... only needed for primary circuits and secondary circuits
exceeding 30 V.  (Yes, you still want an enclosure, but not for safety!)

Etc.  So, compliance should not cost too much.

I look forward to your comments on compliance costing too much.


Rich
  

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Re: [PSES] Two Notified Body numbers on a product

[Michael Derby]

Notice that although the RTTE Directive does not mention NB number height
directly... the Commission's RTTE Guidance document states (advises?) that
the NB number should be the same height as the CE Mark.

 

I think Charlie's suggestion makes good sense but be warned that an
enthusiastic surveillance authority could ask questions.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 06 June 2012 09:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Two Notified Body numbers on a product

 

Amund

 

Yes - put two NB numbers next to the CE mark - this can be done by placing
the two number on top of each other next to the CE mark such that their
total height is same as that of CE mark

 

Regards

Charlie

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 06 June 2012 04:46
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Two Notified Body numbers on a product

 

A product has to fulfill the EU directives RTTE and CPR. Two different
Notified Bodies are involved for the directives.

Are we talking about double NB numbering on the CE label?

 

So far, I have not seen any product with two NB identification numbers ...

 

#Amund

 

 

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Re: [PSES] ANSI C63.4: 2009

[Michael Derby]

Hi,

 

I assume you're asking when they will formally write it into their rules,
rather than when it is acceptable.

 

I can't imagine how long it takes the FCC to change the text of their rules,
but certainly not overnight.

 

Luckily though, the 2009 version is acceptable now.   It's not written in
the rules yet but it is an acceptable standard to use.

 

http://transition.fcc.gov/oet/ea/eameasurements.html

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: itl-emc user group [mailto:itl...@itl.co.il] 
Sent: 15 July 2012 04:48
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] ANSI C63.4: 2009

 

Hello

Does anyone know when the FCC is planning to replace ANSI 63.4: 2003 with
ANSI 63.4: 2009 if at all?

 

Regards,

David Shidlowsky | Technical Writer

Address 1 Bat-Sheva St. POB 87, LOD 71100 Israel

Tel 972-8-9186113 Fax 972-8-9153101

Mail e...@itl.co.i/dav...@itl.co.ill  Web  http://www.itl.co.il
www.itl.co.il

 

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Re: [PSES] SAR standards

[Michael Derby]

Hello Bob,

 

It's the basic RF Exposure assessment standards that are harmonised, such as
EN 50360, EN 62479, EN 62311.

 

EN 62209-1 and EN 62209-2 are more like the test procedure standards.

 

For example, EN 62311 is a standard for assessing a device to RF Exposure
requirements.   If you follow EN 62311 through and realise that you need to
do a SAR test, then you will find the requirements match EN 62209-1.   EN
62209-1 and EN 62209-2 would be good test procedure standards to use for SAR
testing to demonstrate compliance.

EN 62311 does list EN 62209-1 as a reference document.

 

I hope this helps,

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Robert Heller [mailto:rehel...@mmm.com] 
Sent: 23 July 2012 12:07
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SAR standards

 

Are SAR standards (EN 62209-1 for example) harmonized to any Directive for
Europe? I don't see them listed in the standards harmonized to the RTTE
Directive? 

Bob Heller
St. Paul, MN 55107-1208
Tel: 651-778-6336
Fax: 651-778-6252

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Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

[Michael Derby]

Renewed annually.

I don't recall if a dog license is cheaper if you have a black and white
dog.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 08 August 2012 21:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

Is the TV License a onetime deal or to you have to renew it on an annual
bases like a dog license?


-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John
Woodgate
Sent: Wednesday, August 08, 2012 4:14 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

In message FCA549BE3ECF9D4CB8CB8576837EA489140853@ZEUS.cetest.local,
dated Wed, 8 Aug 2012, ce-test, qualified testing bv - Gert Gremmen
g.grem...@cetest.nl writes:

If they want people to pay for it than have it scrambled.

That, of course, is possible now, but wasn't in the past. Who will buy
everyone a new TV (or 4 or 5 new TVs) with a descrambler?

The UK want you to pay but do not provide a License, and there is no 
delivery clause either,

Oh, you get a licence. It's the size of two A5 sheets joined at the short
sides and printed in black and a pretty green colour. A bargain at
£145.(;-)
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Instead of saying that the government is doing too little, too late or too
much, too early, say they've got is exactly right, thus throwing them into
total confusion.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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LECO Corporation Notice: This communication may contain confidential
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Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

[Michael Derby]

Hello,

 

I am enjoying this conversation.

 

It's worth pointing out to the non-BBC watchers that there are no
commercials/adverts on the BBC.   They get their money through the license
fee.

So, basically, we are paying for the privilege/opportunity to watch
television without any commercials or advert breaks.   It's nice for films,
where there isn't an interruption every 20 minutes (unless you need the
toilet, of course).

 

We also have the opportunity to complain about BBC services, since we're
paying for them.   It also helps keep them politically neutral, since they
don't have sponsors to worry about.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: ce-test, qualified testing bv - Gert Gremmen
[mailto:g.grem...@cetest.nl] 
Sent: 08 August 2012 19:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

Subscribing suggest a written consent, and a received license in return, so
a contract.

Receiving BBC is possible without that, so it is stupid to require citizen
to pay for that.

If they want people to pay for it than have it scrambled.

The UK want you to pay but do not provide a License, and there is no
delivery clause either,

It's a one-way benefit system, it's theft. Like making people paying for
books in the store

they never intent to buy nor read.

 

 

Gert gremmen

 

Van: ralph.mcdiar...@schneider-electric.com
[mailto:ralph.mcdiar...@schneider-electric.com] 
Verzonden: woensdag 8 augustus 2012 20:34
Aan: ce-test, qualified testing bv - Gert Gremmen
CC: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 


I like the idea about the right to receive anything.  However, if you're
watching BBC, then you are in effect subscribing to it, and so I can see the
rationale for a license to receive.  (just as there is a subscription to
satellite radio) 

Some folks also think it's their right to transmit without an license.
Fortunately they are few and far between, but there are some who insist it's
a right, not a privilege to use the radio spectrum.  I've got my license and
I use it sparingly and at lowest power necessary to make a QSO.

___ 

Ralph McDiarmid  |   Schneider Electric   |  Solar Business  |   CANADA  |
Regulatory Compliance Engineering 


From: 

ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl 


To: 

EMC-PSTC@LISTSERV.IEEE.ORG 


Date: 

08/07/2012 11:13 PM 


Subject: 

[PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

  _  




In the Netherlands the right to receive  is very well defended, to the
extent that speed radar detection systems cannot be prohibited.

The right to receive is seen in the same way as the right to speak , which
is not so odd because having the right to speak when no one listens makes no
sense ;)

This is not the same all over Europe, in spite of trying to harmonise
legislaton.

Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953

P Before printing, think about the environment. 



-Oorspronkelijk bericht-
Van: emc-p...@ieee.org [ mailto:emc-p...@ieee.org
mailto:emc-p...@ieee.org] Namens John Woodgate
Verzonden: Wednesday, August 08, 2012 6:44 AM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] EU sets EMC limits for London Olympics

In message 006801cd74e6$a5614d90$f023e8b0$@cox.net, dated Tue, 7 Aug 2012,
Ed Price edpr...@cox.net writes:

The British apparently never had the mindset of public ownership of the 
spectrum, so its government had no precedent to keep it from realizing 
yet another revenue stream. John  Chris, do you agree with that?

Yes: the GPO owned the spectrum.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
Instead of saying that the government is doing too little, too late or too
much, too early, say they've got is exactly right, thus throwing them into
total confusion.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

[Michael Derby]

I confess to a hint of British irony in my e-mail.   J

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Peter Tarver [mailto:ptar...@enphaseenergy.com] 
Sent: 09 August 2012 23:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

I've watched BBC News rebroadcast in the US.  One thing BBC absolutely is
not is politically unbiased.

 

Peter Tarver

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Thursday, August 09, 2012 00:45
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

Hello,

 

I am enjoying this conversation.

 

It's worth pointing out to the non-BBC watchers that there are no
commercials/adverts on the BBC.   They get their money through the license
fee.

So, basically, we are paying for the privilege/opportunity to watch
television without any commercials or advert breaks.   It's nice for films,
where there isn't an interruption every 20 minutes (unless you need the
toilet, of course).

 

We also have the opportunity to complain about BBC services, since we're
paying for them.   It also helps keep them politically neutral, since they
don't have sponsors to worry about.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 
 
This email message is for the sole use of the intended recipient(s) and may
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Re: [PSES] France no longer having restriction on WIFI ?‏

[Michael Derby]

Hello Jasmine,

 

The most official and ‘legal’ document is this one.

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2009:289:0019:002
0:EN:PDF

It was written in 2009 and shows that the French restriction expires from
1st July 2012.

 

As additional guidance, the European Commission post this page on ‘Class 1’
devices.

http://ec.europa.eu/enterprise/sectors/rtte/files/rtte_subclass_july2012_en.
pdf

You can see sub-class 22 is for WLAN devices.

In June, it said  “2400-2454 MHz”   Now, from July, it says  “2400-2483.5
MHz”

 

I hope this helps,

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: jasmine tan [mailto:jastan...@hotmail.com] 
Sent: 10 August 2012 09:03
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] France no longer having restriction on WIFI ?‏
Importance: High

 

Dear Folks,
I had heard that as of July 1, 2012, France removed the 100 mW indoor use
requirement . Thus the Alert Symbol (!),is no longer required.
Does any one has the officail documents to verify this rumour. Please share
with me,
Thanks in advance.
 
 
Best  Regards,
jasmine

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Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

[Michael Derby]

Thanks Ed,

 

I was thinking back to my days of living in the USA.   Maybe I should have
said  relatively  neutral.J

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Ed Price [mailto:edpr...@cox.net] 
Sent: 10 August 2012 13:57
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

Michael:

 

The BBC's sponsor is the UK government, so I suppose they still have
somebody looking over their shoulder.

 

Ed Price

El Cajon, CA

USA

 

 

From: Peter Tarver [mailto:ptar...@enphaseenergy.com] 
Sent: Thursday, August 09, 2012 3:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

I've watched BBC News rebroadcast in the US.  One thing BBC absolutely is
not is politically unbiased.

 

Peter Tarver

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Thursday, August 09, 2012 00:45
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: [PSES] EU sets EMC limits for London Olympics

 

Hello,

 

We also have the opportunity to complain about BBC services, since we're
paying for them.   It also helps keep them politically neutral, since they
don't have sponsors to worry about.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

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Re: [PSES] CE+CE ...

[Michael Derby]

In addition to Charlie's words..

Although you may choose to 'carry forward' some of the radio transmitter
test results from the module; you are not actually carrying forward the
equipment authorisation and this does not mean you are any less
responsible for the radio performance of the end product.

The end product supplier is still responsible.
(It's not like FCC or IC modular approval, where the module manufacturer
retains some responsibility).

So, yes, you can carry forward (trust?) the radio test results from the
module if you choose, if you trust them and you think they're applicable to
your application.


Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 12 October 2012 13:19
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE+CE ...

Amund

There's guidance on integrating assessed radio modules into products at
http://www.rtteca.com/TGN01Rev5.pdf 

Basically, you may well be able to carry forward the RF spectrum
compliance of the module, subject to meeting some criteria, but you will
need to assess the finished product for EMC and safety

Regards
Charlie

-Original Message-
From: amund [mailto:am...@westin-emission.no] 
Sent: 12 October 2012 12:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE+CE ...

Consider a radio system under development (radiomodule, SMPS, hard disk,
main board, etc) All parts in the system are COST (and CE marked) and the
main work is now an engineering job and make some SW. 

When system is functioning and ready for putting it on the marked, the
complete RTTE approval must be carried out, even though that all modules are
CE marked. 

No other outcome, agree?

#Amund

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Re: [PSES] Possible Counterfeit EMC Components?

[Michael Derby]

I was chatting with a power supply manufacturer who told me he had worked
hard to design his power supply and get it through all the necessary
regulations.   When complete, he sent the design and instructions out to the
manufacturing company.

After many of them had been made and sold, he realised the components in the
power supply were all cheaper imitations of the components he had instructed
the manufacturer to use.

D'oh.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 30 October 2012 20:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Possible Counterfeit EMC Components?

I recently preformed a safety evaluation of a product made in the far east
which contained a suspicious looking rf line filter. Instead of the nice
silkscreened markings showing the company name, numbers and a schematic of
the filter components, it just had a basic printed label. When I removed the
filter and turned it over I found that the case was not soldered but just
spot welded in four spots.

Are line filter companies cutting corners to save money or might this filter
be a counterfeit?

The filter manufacturer's website doesn't show this model filter (anymore?)
but you can buy them from several online electronic component companies.

Has anyone run across counterfeit components and is this something we need
to keep an eye out for? My biggest concern is with safety certified
components which smaller companies like ours have to purchase through
distributors who get them from who knows where.

Is this a real concern or am I just being paranoid?

Thanks,
The Other Brian




LECO Corporation Notice: This communication may contain confidential
information intended for the named recipient(s) only. If you received this
by mistake, please destroy it and notify us of the error. Thank you.

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

Hello all,

A mandatory requirement to have a Medium Access Protocol has existed in EN
300 328 since V1.7.1, which was published in 2006, first introduced onto the
Official Journal sometime soon after that.   (the oldest OJ I have on record
is 2008 and it's on there).

There were a lot of complaints that the section on Medium Access Protocol
was not clear enough and people did not know what it meant.   Or, they knew
what it meant but didn't know how thorough it needed to be.   We knew that
IEEE 802.11 had it and we knew that Bluetooth hopped away from trouble.
Zigbee was listed in the scope of the standard so we all felt happy about
IEEE 802.15.4.   But what about everything else?

Industry called out for a better explanation and more clarification, which
is summarised as the text we are discussing below.
So, it is simply a clarification of an existing requirement.   It's not some
sudden new requirement.

EN 300 328 V1.8.1 makes it even more clear and removes the requirement for
clarifications in the OJ.

As a final comment, yes, there are manufacturers involved in the ETSI group
for EN 300 328. :-) 


Thanks,   Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 27 November 2012 13:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

In message
3f0347ac6ed9504191f91f07629fbb0c014f0...@thhsle14mbx2.hslive.net,
dated Tue, 27 Nov 2012, Charlie Blackham char...@sulisconsultants.com
writes:

The reference has been in public domain for some years, and whilst the 
ETSI website is not always the easiest thing to navigate, draft 
standards are available, free of charge.

Even to non-members? I tried to get a draft document and couldn't.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to
make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

I agree with Charlie that it is not saying you must test to V1.8.1.   It is
saying that you must have spectrum sharing mechanisms (we know that, it's in
V1.7.1) but we don't necessarily know what that means.   It gives examples,
followed by an idea of where to find tests if you want them.

 

 

Imagine the text from the OJ:

This version of the standard gives presumption of conformity with the
requirements of Article 3(2) of Directive 1999/5/EC under the following

condition: The equipment shall implement an adequate spectrum sharing
mechanism, e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in

order to comply with the requirement specified in clause 4.3.5 of this
version. Such a mechanism shall facilitate sharing between the various

technologies and applications which currently exist and in case of
congestion, users will be ensured equal access (and as a consequence a
graceful

degradation of service to all users). The efficiency of the various sharing
mechanisms can be assessed using the appropriate clauses of EN 300328

version 1.8.1.

 

Now imagine a conversation between an industry person (let's call him IP)
and the OJ itself.   For the OJ, I shall use only the text above..

 

OJ:   This version of the standard gives presumption of conformity with the
requirements of Article 3(2) of Directive 1999/5/EC under the following

condition: The equipment shall implement an adequate spectrum sharing
mechanism,

 

IP:   What is a spectrum sharing mechanism?

 

OJ:e.g. LBT (Listen Before Talk), DAA (Detect And Avoid), etc., in order
to comply with the requirement specified in clause 4.3.5 of this version. 

 

IP:   Oh, I see that, but what is it for?   If you explain it, maybe I can
use some other way to meet that requirement.

 

OJ:   Such a mechanism shall facilitate sharing between the various
technologies and applications which currently exist and in case of
congestion, users will be ensured equal access (and as a consequence a
graceful degradation of service to all users). 

 

IP:   I see.   That would be really easy if I had a WLAN or Bluetooth device
but I don't, I have this cool new technology I invented.   Are there any
tests I can follow?

 

OJ:   The efficiency of the various sharing mechanisms can be assessed using
the appropriate clauses of EN 300328 version 1.8.1.

 

IP:   Thank you, you've been very helpful.

 

 

 

Honestly, I don't actually hear these voices in my head.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 29 November 2012 08:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

Mark

 

Harmonised Standards don't always contain all the requirements - Spectrum
Requirements also apply and these are regulated by the various national
radio interface regulations and not in the standards.

The base for the use of the 2400-2483.5 MHz frequency band may be found in
Annex 3 of ERC/REC 70-03.

http://www.erodocdb.dk/Docs/doc98/official/pdf/REC7003e.pdf . This is the
latest, October 2012 version, but the previous February 2011 version
contained the following note: The equipment shall implement an adequate
spectrum sharing mechanism in order to facilitate sharing between the
various technologies and applications covered by this annex 3. 

 

In other words  an adequate spectrum sharing requirement has been needed
for some time.

 

The wording in the OJ has changed (evolved) from, if you like, pointing to
where ways for assessing this requirement could be found, to telling you
where they can be found. It does not say that the Spectrum Sharing
requirements of V1.8.1 must be followed, it says can be found.

 

In my opinion, the note in the OJ referring to V1.8.1 is not mandatory.
Demonstration with requirement could be made through consideration of
sharing requirements already built in though conformity with relevant 802.11
requirements of WiFI or BT standards. But whatever you choose, you should be
prepared to justify it to a Spectrum Authority if required.

 

The manufacturer must fully apply the relevant Harmonised Standard if they
want to apply the CE mark without the use of a Notified Body and the
Spectrum Requirements must also be followed before the device is put into
service.

 

The requirement hasn't actually changed when applying V1.7.1 it's just that
the guidance has been improved as it has been found to be not as clear as it
might have been. Though whether it's completely clear now . . . . J

 

Regards

Charlie

 

 

 

From: Mark Gandler [mailto:markgand...@hotmail.com] 
Sent: 28 November 2012 19:51
To: Charlie Blackham; j...@jmwa.demon.co.uk; emc-pstc@listserv.ieee.org
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

Charlie,

current mandatory version is 1.7.1. Future (2015) is 1.8.1. Both harmonized.


 

There is an application note in question which describes

Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

I blame too much time between the helmholz coils!!!

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sent: 29 November 2012 21:32
To: Michael Derby
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

 

You would not be alone if you did, Michael...

 

 

 

On 29 Nov 2012, at 20:01, Michael Derby micha...@acbcert.com wrote:





 

 

Honestly, I don't actually hear these voices in my head.

 

 

 


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Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

[Michael Derby]

If he had a kind of high pitched, squeaky voice, yes.

I do recall I did get a headache every time I put the surge generator
through the coils but perhaps that's to be expected.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: don_borow...@selinc.com [mailto:don_borow...@selinc.com] 
Sent: 29 November 2012 22:05
To: Michael Derby
Cc: emc-p...@ieee.org; 'Nick Williams'
Subject: RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements

So do you hear the voice of Helmholtz?

Donald Borowski
EMC Compliance Engineer
Schweitzer Engineering Labs
Pullman, Washington, USA



From:   Michael Derby micha...@acbcert.com
To: 'Nick Williams' nick.willi...@conformance.co.uk
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Date:   11/29/2012 01:56 PM
Subject:RE: [PSES] EN 300 328 V1.8.1 new Adaptive equipment 
requirements
Sent by:emc-p...@ieee.org



I blame too much time between the helmholz coils!!!
 
 
Michael Derby
Regulatory Engineer
ACB Europe
 
From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sent: 29 November 2012 21:32
To: Michael Derby
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 300 328 V1.8.1 new Adaptive equipment requirements
 
You would not be alone if you did, Michael...
 
 
 
On 29 Nov 2012, at 20:01, Michael Derby micha...@acbcert.com wrote:


 
 
Honestly, I don?t actually hear these voices in my head.
 
 
 
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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

[Michael Derby]

Hello,

 

I think that in the past, there was always the general understanding that a
full copy of the DoC must be supplied with each device sold.

 

However, more and more people are simply adding a statement to their user
manual to state something like:   This device complies with the relevant
provisions of Directive 1999/5/EC  and then making sure that their full DoC
is available online, or something like that.

If you're going to do that, it's recommended to make sure the statement is
in every language, or at least in the language of the country it's arriving
into.

 

This document is very useful..

http://ec.europa.eu/enterprise/sectors/rtte/files/guidance/guidance_en.pdf

 

I have known people to have their product stopped at customs because the
package did not include the full DoC in, for example, Polish.   However, the
manufacturer quickly got one translated and supplied, so their product was
allowed in.

 

I know that some people still insist that the full DoC must be supplied with
each device but I think it's generally considered acceptable to just make
sure the 'statement of compliance' is provided and that the full DoC is at
least available.   Online is good.

I believe that the proposed new RTTE Directive text should officially allow
this approach, I hope.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 03 December 2012 08:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

 

 

It's covered in the Europa Interpretation of the RTTE Directive:

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm#h2-23 

 

regards

Charlie

 

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 30 November 2012 19:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

 

In message  mailto:3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk
3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk,

dated Thu, 29 Nov 2012, Nick Williams 
mailto:nick.willi...@conformance.co.uk nick.willi...@conformance.co.uk

writes:

 

AIUI, the R+TTE Directive also requires this, and there are others 

which do the same.

 

Article 6 3. of the RTTED says:

 

  3. Member States shall ensure that the manufacturer or the person
responsible for placing the apparatus on the market provides information for
the user on the intended use of the apparatus, together with the declaration
of conformity to the essential requirements.

 

Nowhere that I can find does it say a DoC has to accompany every unit.

--

OOO - Own Opinions Only. See  http://www.jmwa.demon.co.uk
www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it
proves to be.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

 

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Re: [PSES] iPhone 5 TxRx frequencies on 4g

[Michael Derby]

Hello Derek,

 

I guess like most people have answered, this could be a two part question.

 

Are you interested in which bands are supported by your carrier?   Or are
you interested in which bands your iPhone 5 is technically capable of?

 

What's the FCC ID of your phone?

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Derek Walton [mailto:lfresea...@aol.com] 
Sent: 06 January 2013 17:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] iPhone 5 TxRx frequencies on 4g

 

HI folks, can anyone tell me what transmit and receive frequencies my iPhone
5 uses here on the US 4G network please. 

 

Thanks,


Derek.

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Re: [PSES] One DoC per manufactured Unit?!

[Michael Derby]

I think that's part of the history, John.

I believe one of the situations that arises from the NLF is that the 
requirements of each Directive are being harmonised.
This often means looking at all the Directives, finding the 'most strict 
requirement' and then applying it to all the others.

So, you couldn't have this requirement for the Toy Safety Directive and then 
say that it doesn't apply to other Directives, because that would not be in 
line with the Directive harmonisation and NLF.
The alternative would be to remove the requirement from the Toy Safety 
Directive, which obviously it not what they want to do.

I witnessed similar conversations with regard to the 5mm height of the CE Mark. 
  Some Directives don't (didn't) worry too much about CE Mark height but they 
will need to, to align through the NLF.

My glasses/spectacles have thin little stems of about 2.5mm thickness, so the 
CE Mark on the stem is about 2mm high.
I'm not sure how they could fit a 5mm CE Mark onto a 2.5mm stem.

Of course, I need to take my glasses off to see the CE Mark.   But without my 
glasses on, I cannot see a 2mm CE Mark.
So, maybe I just don't care.   Ignorance is bliss.


Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Cotman [mailto:john.cot...@conformance.co.uk] 
Sent: 14 January 2013 16:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] One DoC per manufactured Unit?!

The Toy Safety Directive already has the picture requirement on the D of C.

John C

-Original Message-
From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl]
Sent: 14 January 2013 14:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] One DoC per manufactured Unit?!

You can make fun of it, but all these things have been introduced with the goal 
of creating a better level playing field, thus making possible to find, an 
pursue those manufacturers that spoil the market by selling untested, possible 
unsafe cheap rubbish.


Customs are better able to simply stop products with false DoC, this way.

Imagine the poor customs guy, having to tell if these little green pieces of 
plastic with copper screws on it really are the KML032-1234-s-XX as the DoC 
states ?? 
If they are, they may withold the product and dupe the honest manufacturer, if 
they assume it's ok, another batch of unsafe rubbish may dupe the consumer (in 
the end).


If you look at it like that, the costs for even (if it were required) a serial 
number and a hologram and color image and a fully operating miniature  model 
with each DoC are a bargain compared to the increased benefit that goes with 
increased sales.;))  if you are not on the side of the cheaters. 


And of course, it also brings the cheating to a higher level, so expect
even more stringent measures in the future... it's an everlasting battle
between the GOOD and the BAD

Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953

P Before printing, think about the environment. 



-Oorspronkelijk bericht-
Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate
Verzonden: Monday, January 14, 2013 3:00 PM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: One DoC per manufactured Unit?!

In message
64D32EE8B9CBDD44963ACB076A5F6ABB0262C6D0@Mailbox-Tech.lecotech.local,
dated Mon, 14 Jan 2013, Kunde, Brian brian_ku...@lecotc.com writes:

As far as the color picture, well, that?s just stupid. Why not ask for 
a hologram of the product?

A fully working full-size model would be even better. But for some suppliers, 
that would be too difficult.(;-)

Our DOC is included in our manual and we are not going to add color for 
a single picture.

I?m not sure where we would put a picture anyway. Our DOC is a full 
page now. It would most likely have to be very small or on a separate 
page.

Does the manual have a picture of the product on the front cover already?
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a 
point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] FCC IC and Product Information

[Michael Derby]

Hello,

 

You cannot get confidentiality or even short term confidentiality on a test
report.   You can't keep the results private, sorry.

 

David is correct in his summary below.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: itl-emc user group [mailto:itl...@itl.co.il] 
Sent: 30 January 2013 05:15
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FCC  IC and Product Information

 

In my experience, TCB's don't charge extra for confidentiality unlike the
FCC.

I have not heard of short term confidentiality for a test report.

Internal photos can be kept confidential only under certain circumstances
such as the device being filled and sealed with epoxy. Permanent
confidentiality request for schematics, block diagram and parts list is
given without any problem. 

 

Regards,

David Shidlowsky | Technical Writer

Address 1 Bat-Sheva St. POB 87, LOD 71100 Israel

Tel 972-8-9186113 Fax 972-8-9153101

Mail e...@itl.co.il/dav...@itl.co.il  Web  http://www.itl.co.il/
www.itl.co.il

 

 http://app.sqm.co.il/SitePages/Questionnaire.aspx Fill out Customer
Satisfaction Survey

Global Certifications You Can Trust 

 

 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Mark Gandler
Sent: Tuesday, January 29, 2013 9:50 PM
To: emc-pstc@listserv.ieee.org
Subject: RE: [PSES] FCC  IC and Product Information

 

You can submit 180 days Short term request for confidentiality pretty much
on most of the  information (phots, manuals, test setup) and later on ask
for 90 days extension.

The longer the request higher the fee

 

There is also an option for permanent confidentiality request on some of the
more critical info: block diagram, schematics. There is also a fee for that.


 

Mark

  _  

From: edpr...@cox.net
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] FCC  IC and Product Information
Date: Mon, 28 Jan 2013 21:27:46 -0800

Bill:

 

Wow, I never knew about this source. This will keep me up all night!

 

Ed Price

WB6WSN

Chula Vista, CA  USA

 

From: Bill Owsley [mailto:wdows...@yahoo.com] 
Sent: Monday, January 28, 2013 8:40 PM
To: Ed Price
Subject: Re: [PSES] FCC  IC and Product Information

 

http://transition.fcc.gov/oet/ea/fccid/
and explore from there...

 


  _  


From: Ed Price edpr...@cox.net
To: EMC-PSTC@LISTSERV.IEEE.ORG 
Sent: Monday, January 28, 2013 10:05 PM
Subject: RE: [PSES] FCC  IC and Product Information


I didn't realize that the FCC releases any information to the public, other
than cross-referencing to your approval status. Do you mean something like
the information in your FRN (FCC Registration Number) that you have in order
to do business with the FCC?

BTW, I think it would be really great if I could access the test data
submitted to the FCC for things like Part 15 compliance. For one thing, as a
consumer, I could use that as a component of my purchasing decision. For
instance, if I were buying a DC to AC inverter, I could look at several and
be able to choose which one had the lowest emission signature, which is a
lot better than just the assurance that they all passed the limit.

Ed Price
WB6WSN
Chula Vista, CA  USA


-Original Message-
From: Peter Merguerian [mailto:pmerguerian2...@yahoo.com] 
Sent: Monday, January 28, 2013 6:47 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC  IC and Product Information

Dear Members

How long can we prevent the FCC or IC from releasing any testing/product
information to the public?

Peter

Sent from my iPhone

Peter S. Merguerian
pe...@goglobalcompliance.com
Go Global Compliance Inc.
www.goglobalcompliance.com http://www.goglobalcompliance.com/ 
(408) 931-3303

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Re: [PSES] Retesting to latest standards

[Michael Derby]

Hello,

 

If the latest version of the standard is 'harmonised' (on the Official
Journal) and if the old version has been removed from the Official Journal,
then you are recommended and encouraged to make sure your device complies
with the new version (so that  you can show you meet the latest harmonised
standards).   This is to make sure that devices which stay on the market for
a long time, keep up with the changing requirements.

 

If you look at the old standard and the new standard, then decide that none
of the changes really affect your device or your test results, then you
could say that your device meets the new standard without a need to re-test.
You can confidently put the new standard on your DoC in your TCF, having
performed the assessment.

 

If you find some new tests have been added that your device has not been
tested for, then you should test to those new tests.

 

Typically if a product is on the market for years and years, then it may
need to have a few reassessments to new standards, to make sure it's kept up
to date.

If a product is only on the market for a year or two, then typically it
would not require any re-assessments during its lifetime.

 

And yes, this is a volatile topic on this e-mail forum.   J

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Mcburney, Ian [mailto:ian.mcbur...@dmh-global.com] 
Sent: 05 February 2013 09:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Retesting to latest standards

 

Dear Colleagues;

 

I know this question has been ask before so please humour me.

We have an old product that was tested to the 1996 version of EN 55103 parts
1  2.

The latest versions are dated 2009 with some changes to testing.

Am I required to retest the product to the new version even though there
have been no changes to it since its original introduction.

 

Many thanks in advance

 

Ian McBurney

Design Engineer

 

Allen  Heath Ltd

Kernick Industrial Estate

Penryn, Cornwall

TR10 9LU

United Kingdom

 

+44 (0)1326 370121


ian.mcbur...@dmh-global.com

www.allen-heath.com http://www.allen-heath.com/ 
 http://www.dmh-global.com/ A DMH Pro Company.

 

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Re: [PSES] EN 60065 A12 - Sound Pressure Restriction

[Michael Derby]

Hello,

I'm not really giving an opinion here, I'm just sharing some observations.

There have been a lot of conversations in Notified Body groups about this topic.

It's important to remember that the Directives (either the LVD or the RTTED) 
require that a device is safe and will not cause harm.   That's the basic 
requirement.   The Directives are more important than the standards.
The standards are there to help you demonstrate that.   Though, they do provide 
'presumption of conformity'.

I think the history of the scope of this document comes from a study that 
personal portable music players present a safety risk.   Therefore, the 
standard was created and references those devices.

As for other devices which put sound into your ear?   Well, that's the debate.
You still need to ensure that the device is not going to cause harm.

Some people say that the standard only covers portable music players and 
therefore something like a laptop or tablet does not need to worry about it.
Other people say that it's easy to sit at your desk for 8 hours and listen to 
music while you work, so therefore those devices should be assessed too.
Some say that a portable music player is a greater risk because you could walk 
away from your desk and still be listening.
Some say that a laptop/tablet is a greater risk because many people sit at 
their desk for longer than they walk around.

Ultimately, the standards are written based on a need that has been proposed to 
(for example) CENELEC.

Regardless of what you think poses the greatest risk; if you sell a device that 
allows people to listen to music, you are still responsible for being confident 
that there are no safety risks; regardless of whether this standard applies to 
your device or not.
That said, you may agree with the standard that a device outside the scope of 
A12 does not present a safety risk.

As ever, the Directives are more important than the standards.


Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 06 February 2013 14:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 60065 A12 - Sound Pressure Restriction

Hi Ted,

Appreciate your valid points.  Where does the standard specify to use the 
device while walking?  We can easily find people to watch the film or play the 
game with mobile phones and/or tablets in public transport.  To avoid dispute 
on this point, let us focus on CD players (all DVD players are backward 
compatible to CD players).  Lots of ads are showing that youngsters are holding 
the player by one hand.  Does the standard restrict that the device must be put 
into the pocket as a qualified unit?  The player can be placed in hand bag.  
Samsung Note 2 and other tablets are considered not as portable units?  However 
lots of people are holding such items on the go.

If a CD player is qualified as an exemption, does the supplier need to update 
the original LVD report to include this A12 although it is not required to 
comply with any requirements in A12?

Thanks and regards,

Scott


On 6/2/13 12:08 AM, Ted Eckert ted.eck...@microsoft.com wrote:

 Hi Scott,

 The people who sit on CENELEC committees are humans and they are prone 
 to human errors. They write standards in plain language that is easy 
 to understand. The problem comes when these standards are adopted into 
 law. Laws that are very precise are easy to interpret, but are very 
 complicated. Take the Low Voltage Directive as an example. It tells us 
 that products must be safe, but doesn't give much more detail. If that 
 were the only regulation in place, we would need armies of lawyers to 
 argue whether specific products are acceptably safe or have 
 unreasonable hazards. We are given the option of complying with standards 
 that give us more detail on one route to compliance.
 If you have an IT product that meets EN 60950-1, you have met one 
 legal interpretation of acceptably safe.

 In addition, standards are written by committee. The words need to be 
 acceptable to a specified majority of the committee before the 
 standard can be adopted. Precise language can be harder to pass 
 sometimes because some committee members may object to one particular 
 item. The whole committee may agree on the general intent of the 
 standard but not every specific item. A more general wording can be easier to 
 pass.

 The CENELEC audio requirements have three tests to determine if a 
 product is within the scope. The product is within the scope if:
 − is designed to allow the user to listen to recorded or broadcast 
 sound or video; and − primarily uses headphones or earphones that can 
 be worn in or on or around the ears; and − allows the user to walk 
 around while in use.

 Let's take the example of a portable DVD player. It meets the first 
 clause as playing recorded video is its primary function. Many meet 
 the second clause having headphone jacks, and often multiple headphone

Re: [PSES] Pager and EMC in US

[Michael Derby]

Hello Niels,

 

It can all depend on what is happening within the ‘other parts’ of the
device.

 

Firstly, I assume that the pager has a transceiver within it.   Perhaps a
WLAN transceiver, based on your testing and authorisation to 15.247.

 

Now, as you say, the “ordinary EMC” needs to be done on the non-transmitter
parts of the device.   (Probably testing to 15.109 and maybe also 15.107).
It can really depend on what the rest of the device is doing……

 

For example, if the pager has a USB port for sharing data or installing new
software from your computer, then it would be classified as a “computer
peripheral” and would need either Certification or DoC for that function.

If it does not operate as a computer peripheral and if it is basically just
“some electronics”, then most likely it just needs Verification.

 

DoC testing must be done at a recognised, accredited, test lab.   That means
a lab which is accredited but also registered on the FCC’s website for DoC
testing.

 

Verification and Certification testing does not require the lab to be
accredited.

However…..   although Verification and Certification testing does not
require an accredited test laboratory company; it is important to note that
any radiated measurements for Part 15 must be made on a test site that is
‘listed’ with the FCC.

 

So, let’s take Verification for example……

If you were doing Verification on the non-transmitter parts; then you don’t
need to use an accredited company but your Part 15.109 measurements (and
Part 15.209) tests must be performed on a listed test site.

 

https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm

 

 

I hope this helps?

 

 

Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Niels Hougaard [mailto:n...@bolls.dk] 
Sent: 14 May 2013 07:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Pager and EMC in US

 

Dear list members

 

A pager (small, portable) is tested according to FCC 47 CFR part 15, §15.247
and is getting a FCC grant authorization.

 

Must the ordinary EMC emission testing on such a product be performed by a
FCC accredited test lab, for a certification, or is verification acceptable
to FCC?

 

Best regards,

Niels Hougaard

Niels Hougaard

Bolls ApS

Ved Gadekæret 11F

DK-3660 Stenløse

Denmark

 

T: +45 48 18 35 66

F: +45 48 18 35 30

n...@bolls.dk

www.bolls.dk http://www.bolls.dk/ 

 

 

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Re: [PSES] Grandfathered ETSI standards for CE Marking?

[Michael Derby]

You are correct Carl.   The device always needs to be 'assessed' to the
latest 'requirements'.

 

...and the easiest way to do this, is to 'test' to the latest 'standard'.

 

If they are following the harmonised standard route, then they will need to
show compliance with EN 300 328 V1.8.1 before December 2014.   (Some tests
will need re-testing)

 

If they do not wish to do that, then they will need to go to a Notified Body
for an opinion because they will no longer have the luxury of presumption
of conformity because the standard listed on their DoC will no longer be
the harmonised one (from December 2014).

 

Of course, if they do go to a Notified Body with their old results (V1.7.1)
and ask for an opinion to the new requirements (V1.8.1), then the Notified
Body should ask for some justification.   You don't need to test to
harmonised standards when you go to a Notified Body, but the Notified Body
should be asking for some justification for compliance, which is typically
equivalent to the latest harmonised standards.

Most likely, the Notified Body would ask them to demonstrate how it would
meet the V1.8.1 requirements.   J

 

You're right that there's no certification for Europe on RTTE equipment.
It's all DoC, to the latest requirements.

 

So, I think you are right.   The lab and manufacturer seem like they are
wrong.

 

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Carl Newton [mailto:emcl...@gmail.com] 
Sent: 15 July 2013 17:02
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Grandfathered ETSI standards for CE Marking?

 

Group,

 

I'm in a debate with a lab and a manufacturer that insist that a RTTE
device doesn't need to be re-evaluated against a new revision standard when
the previous is withdrawn.

 

ETSI EN 300 228 V1.7.1 loses the presumption of conformity in 2014 (December
I think).  Customer is installing a ZigBee component within his ITE device
and wishes to apply the ZigBee transceiver compliance to his device.   I've
argued that revision V1.8.1 which is listed in the OJ must be applied after
the DoW.  Both the ZigBee component manufacturer and the test lab involved
argue that once a device is certified that retesting is not necessary.  

 

I've double-checked the Blue Guide and I believe that their interpretation
is not correct and that after the DoW the current revision listed in the OJ
must be stated on the DoC.   Safety in numbers, looking for a sanity check
here.

 

Thanks,

 

Carl

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Re: [PSES] Grandfathered requirements for ETSI

[Michael Derby]

Hello,

 

In general, no.   The standards change to keep up with changes in
interference level, spectrum planning, problems seen, etc.

As I think John Woodgate already said..  You can sit on the standards
committee and influence it.

I used to be on the group for writing EN 300 328 and EN 301 893 (I am not
anymore, I should add!   V1.8.1 was not me!  J ) and the group was mostly
made up of manufacturers protecting the interests of their companies, and
regulators protecting their spectrum.

 

Can I ask exactly what the problem is?   Is it the Medium Access Protocol
issue?   Are you concerned that your device may choose to change channel
mid-operation, or something?

Actually, I'm guessing that (spectrum sharing) cannot be the issue because
that aspect of V1.8.1 became mandatory on 23rd October 2012.

Is it the new power measurements?

 

I'm curious because maybe there is a solution, after all.

 

If that fails, I have the ETSI group chairman's e-mail address, if you want
it.   J

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Mark Tucker [mailto:mtuc...@murata.com] 
Sent: 07 August 2013 18:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Grandfathered requirements for ETSI

 

Hi, 

My company makes 2.4 GHz proprietary wireless products for European use (not
WiFi, BT or ZB). These units are qualified under EN 300 328. We understand
that EN 300328 v1.8.1 will become law the 1st of 2015. 

We've been selling wireless products for many years in the EU and the
installed base is in the 10s of thousands of units. However, the changes
dictated by v1.8.1 will break our radio protocol and destroy the
compatibility between new units (that must be v1.8.1 compliant) and those
already installed in the field. This is a huge issue for us and any other
vendor that may have the misfortune of having a large installed base of
pre-existing products. 

Is there any provision in ETSI rules that allows for backwards compatibility
with preexisting products? I have a hard time believing that they wouldn't
have made some sort of provision for this. 

Any help or advice would be greatly appreciated. 

Mark 
















Mark Tucker
Director of Hardware Engineering
RFM
3079 Premiere Parkway, Suite 140
Duluth GA 30097
mtuc...@murata.com 

- Forwarded by Mark Tucker/US/MuRata on 08/07/2013 12:57 PM - 

From:IEEE LISTSERV Server (16.0) lists...@ieee.org 
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Date:08/07/2013 12:56 PM 
Subject:Welcome to the emc-pstc email list 

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Re: [PSES] Lists Of Harmonised Standards

[Michael Derby]

Hello,

 

I'll start by saying I don't know when the next version of the Official
Journal (harmonised standards) for the EMC and R%TTE Directives is due out.

 

For the EMC and RTTE  Directives, the last release was 23 October 2012, so
I would expect to see a new version released soon.   (Within 2013, I would
assume, but that's a guess)

 

As for the proposed Radio Equipment Directive (to replace the RTTE
Directive), the 'proposed' timeline is:

 

RE-D draft text was proposed on 17 October 2012.
EU Parliament discussions from Q1 of 2013.   Discussions estimated to take
approximately 1 year.
Final text expected in Q1 of 2014.
Transition period of 18 months expected, so the old RTTE approach should
finally be replaced by the end of 2015.

 

 

Of course, that was just the plan.   When do things ever really happen
early, or even on time?   J

I suspect that schedule has already slipped.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: itl-emc user group [mailto:itl...@itl.co.il] 
Sent: 22 August 2013 05:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Lists Of Harmonised Standards

 

Hi,

Does anyone have any leads as to when a new list of harmonized standards to
the EMC, Medical Devices, and RTTE Directives will be published.

I recall reading in some previous posts that the RTTE Directive is going to
be discontinued and a Directive concerning radio only will be published.

 

Regards,

David Shidlowsky | Technical Writer

Address 1 Bat-Sheva St. POB 87, LOD 71100 Israel

Tel 972-8-9186113 Fax 972-8-9153101

Mail e...@itl.co.il/dav...@itl.co.il  Web  http://www.itl.co.il/
www.itl.co.il

 

 http://app.sqm.co.il/SitePages/Questionnaire.aspx Fill out Customer
Satisfaction Survey

Global Certifications You Can Trust 

 

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Re: [PSES] Verification under FCC rules and our Digital Class A product for industrial use only

[Michael Derby]

Hello  all,

 

I agree with Tom that it only applies to Class B computer peripherals.

 

However, I thought I'd share an interesting recent experience with you, for
your information.

 

I sent a KDB to the FCC about a boat (luxury yacht) that had a USB port on
the dashboard (I'm not sure if boat users employ the terminology
'dashboard'?   I guess I mean the place where the 'driver' stands, to guide
the 'pointy end' of the boat).   J

 

The USB port on the dashboard was there to allow a person to use a laptop,
to update the software to the boat's GPS and navigation systems.

 

The FCC confirmed that the GPS etc. within the boat's dashboard would
require a DoC, because it becomes a Class B computer peripheral when you
take a laptop onto the boat and plug it into the dashboard.

 

I suspect this probably comes from the history of the Class B or A decision,
with regard to proximity to television receivers.

Being a luxury yacht, it had many television receivers. 

 

I confess, I was surprised.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Thomas Cokenias [mailto:t...@tncokenias.org] 
Sent: 22 August 2013 21:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Verification under FCC rules and our Digital Class A
product for industrial use only

 

Hi Binayak

 

Your product is used and sold  for use in the non-residential/industrial
environment only, so your product is class A and requires verification only,
even though it could be connected to a class B computer as a peripheral

 

best regards

 

Tom Cokenias

 

On Aug 22, 2013, at 11:48 AM, Binayak Marahatta wrote:





Dear experts,

We wanted to do Verification under FCC rules and We have Digital Class A
product ( touch display for industrial application only). Test required for
verification process is OK (No harmful interference at Industrial
environment). This device has been tested and found to comply with the
limits for a Class A digital device. These limits provide reasonable
protection against harmful interference when equipment is operated in a
commercial environment.


*

I know the following from FCC:

Verification: allows you to use an FCC listed lab or you can use your own
lab. 

 

*   Both require you to maintain test records in a format specified in
the rules: 

Verification:- Retention of Records are in 2.955 of the rules.

1. No additional description of measurement facilities is required if using
a FCC listed lab under 2.948 (1 ) (ii) 

2. If using your own lab then in additional to records defined in 2.955 a
description of measurement facilities is require under 2.948 (1).

*Both the DoC and Verification are called self-declaration
procedures (i.e. the Commission does not formally approve) , but does
require you to produce records of testing if the commission request it:




Additional questions:


If   device has a USB 2.0 port for sharing data or installing new software
from  computer, RJ-45 Ethernet connector, DVI-D, protective conductor
connection, Connection for 24 V DC supply,Serial interface etc, then does it
classified as a computer peripheral and would it  need either
Certification or DoC for that function??

Do you think we just needs Verification for this industrial Class A device?

 

Please advise.


Thank you for your help.

Best regards,

Bin





KEB products are Control Technology,Inverters, Converters, Servo
systems,Frequency generators,Communication, EMC, Magnetic Technology, Motor
and Gears, Elevator Technology, Medical Technology, Material Technology,
Automotive etc.







This e-mail, and any attachment to it, contains confidential information
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Re: [PSES] Using existing WiFi FCC data for new FCCID - Yes or No?

[Michael Derby]

Hi Charles,

 

Sorry for the late reply.I'm just back from vacation and it's possible
you may already have your answer.

 

I think there's the engineering aspect and also the legislative aspect.

 

Firstly, if the WiFi part is a fully certified module, then you should not
need to repeat all those WiFi tests.   The module should have been certified
for any host and should therefore not require re-testing for a change in
host.   (Accepting that the host must be re-tested for its own emissions).

If the WiFi part is a Limited Modular Approval, then it may need to be
partially re-tested, to allow use in this newly designed host, if the
changes are significant.

(For example, you might need to consider if the module has a voltage
regulator and if the voltage to the module has changed.

 

Now, based on your question, I am going to guess that the WiFi part does not
actually have a certification or an FCC ID of its own.

So,  you would be taking test results from one unit and applying them to
another unit.

 

As an engineer, I can see that it would most likely not be a problem.   Most
likely, the majority of test results may remain unchanged.   Of course, I
have no idea about the voltage supply to your WiFi transmitter section, or
the temperature change around the WiFi part, etc., etc., all of which can
affect transmitter performance.   (Notice the excessive use of most likely
and may in there).

 

From an admin point of view though, you need to be careful that you're not
calling the WiFi  a reference design, whereby you have certified a device
once and then assume the same design will always comply in other hosts,
environments and circumstances.   There is not (yet?) a place for this in
the FCC rules.

Also, your old device and your new device would have different FCC IDs but
they would have identical test report values for the WiFi sections.

When the FCC are searching for faked test reports, this is one of their
search criteria (two separate certified devices with identical output
powers, for example).

In their search, your two devices would show up as having identical output
powers.   Further investigations would show that all the test results are
identical in the reports for two separate products.

This could be flagged as a faked test report!   At the very, very least, I
suspect it would be called in for audit testing.

 

So, I would say that if you do want to use your old WiFi test results for
your new product, then you should not just include the results and forget
about it.   Instead, you will need to provide very clear and thorough
explanations/justifications to your TCB, for upload to the FCC website.

You may need to do some partial testing to justify it.

 

The FCC's modular approvals (and limited modular approvals) process exists
to allow this sort of data re-use.   Certification of a design within a
device, to be copied by other devices, is not a permitted route.

 

If in doubt, I would recommend a re-test.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Grasso, Charles [mailto:charles.gra...@echostar.com] 
Sent: 30 August 2013 17:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Using existing WiFi FCC data for new FCCID - Yes or No?

 

Hello,

 

Given: A  product that has a front panel and a main board. The front panel
(along with USB and other electronics) also includes
the WiFI circuitry and antenna connectors. The main board also integrates
(on board)  a RF4CE radio for remote functionality.

 

Scenario: As the result of a cost reduction effort, the main board has been
redesigned and a new cheaper RF4CE radio circuit  included - however  there
are *NO*

changes to the front panel.  Of course the  RF4CE radio will be tested to
ensure compliance to FCC regulations, however as the WiFi radio has not
changed - 

there is a desire NOT to repeat the extensive WiFi testing that has already
been previously done. A  query was made to a TCB as to whether the previous
WiFi
data could be used in addition with the new RF4CE data to apply for a new
FCCID. 

 

Question:  Does anyone know why this approach would not be acceptable??

 

Best Regards

Charles Grasso

Compliance Engineer

Echostar Communications

(w) 303-706-5467

(c) 303-204-2974

(t) 3032042...@vtext.com

(e) charles.gra...@echostar.com

(e2) chasgra...@gmail.com

 

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Re: [PSES] USA Canada rf emission test standards

[Michael Derby]

Hello,

 

For the FCC, their rules do state ANSI C63.4-2003 only.   

However, their website confirms you can use either 2003 and 2009.

I can confirm that it is ok to use 2009.

 

http://transition.fcc.gov/oet/ea/eameasurements.html

 

Changing the FCC rules is not a quick process.   There is an FCC rule change
proposal in place, to insert the 2009 version and remove the 2003 version.

 

So, in summary, ANSI C63.4-2009 is ok for FCC and Industry Canada.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Ian McBurney [mailto:ian.mcbur...@allen-heath.com] 
Sent: 17 September 2013 16:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] USA  Canada rf emission test standards

 

Dear Colleagues;

 

I am trying to combine FCC 47 CFR part 15 and Canadian ICES-003:2012
radiated rf emission testing for a digital device that is an unintentional
radiator.

However; looking into the test standards for each country I am getting
perplexed.

 

It appears that for 47 CFR part 15 sub part B, the test standard for
compliance is ANSI UL C63.4 2003 whereas for Canada it is the latest edition
that is acceptable which I believe is the ANSI UL C63.4 2009.

Similarly; if I was to apply the CISPR 22 method then CFR47 part 15
recognises the third edition of CISPR 22 and Canada applies the 6 edition
2008.

 

Is there a common set of standards that can be applied for radiated 
conducted rf emission measurements that is acceptable in both the USA 
Canada?

 

I am carrying out measurements from 30MHz to 2GHz to class B limits.

 

Many thanks in advance.

 

Ian McBurney

Design  Compliance Engineer.

 

Allen  Heath Ltd.

Kernick Industrial Estate,

Penryn, Cornwall. TR10 9LU. UK

T: 01326 372070

E: ian.mcbur...@allen-heath.com

 

 

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Re: [PSES] TCBs FCC Shut Down

[Michael Derby]

Hello,

 

A Grant of certification may be sent to you by the TCB but it comes from the
FCC and their website.   It is an FCC Grant, not a TCB Grant.

The FCC website is down, so nothing can be granted or certified; not by any
TCB.

 

You can submit an application to a TCB and most likely they will perform the
review for you.   I know we are still reviewing applications and working
with manufacturers, despite the shutdown.

You can proceed to work with the TCB to resolve any issues with your
application.

If your application requires a KDB enquiry or a PBA, it will not be possible
to complete that stage because that requires the FCC website.

It will also not be possible to complete the certification.

 

The TCB cannot give you an It's ok to ship voucher.   That would not be a
good thing.

 

C2PCs are an application process also.Again, if you wish to have a C2PC
done, the TCB can help to review it but it cannot be completed or
'authorised'.

 

Yes, many have been affected by this, especially the TCBs of course, but
also the test labs, manufacturers and employees of the FCC.

 

All TCBs are in the same boat on this.   None of us can certify but all of
us could help to do the initial review.   So, I think the shopping around
idea is no different now, to how it was before.

 

I hope this helps,

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: FW Miller [mailto:f_w_mil...@yahoo.com] 
Sent: 02 October 2013 19:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] TCBs  FCC Shut Down

 

I need some advice and information, please.  

What constitutes a grant of certification from a TCB? 

1. Posting on the FCC web site, which is now shut down, until it isn't..

2. Technical evaluation review completed, with something in writing
indicating it's OK to ship.

3. Any other method? Chapter  verse of the source would be appreciated.

4. Following the certification, there's a C2PC for co-location that's
required. 

 

We, as with many many others have been affected by the shut down  are
looking for solutions. Are the TCBs acting in unison on this one, or should
we be shopping around?

 

Many thanks in advance for your support.

 

 

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Re: [PSES] Risk Assessments and mitigation for EMC chambers

[Michael Derby]

If they make microwaves to look more like the carry cases you take a cat to the 
vet in, then it becomes almost impossible to get the cat to go in there.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: IBM Ken [mailto:ibm...@gmail.com] 
Sent: 10 January 2014 16:30
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Risk Assessments and mitigation for EMC chambers

 

I call for flashing hazard lights (and 'silent' dog whistles) to be added to 
all microwaves.

 

On Fri, Jan 10, 2014 at 11:26 AM, McInturff, Gary 
gary.mcintu...@esterline.com wrote:

Yea I can hardly get more than 4 cats on one of them. J

 

Gary

No animals were hurt in writing this email.

From: IBM Ken [mailto:ibm...@gmail.com] 
Sent: Friday, January 10, 2014 7:36 AM


To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Risk Assessments and mitigation for EMC chambers

 

My guess is because a microwave is a much smaller volume; not likely to have a 
human inside it when activated.

 

On Fri, Jan 10, 2014 at 9:13 AM, Sundstrom, Michael 
michael_sundst...@overheaddoor.com wrote:

From a RF Health and Safety point of view, why is a microwave oven allowed 
with just an interlock on the door and not allowed for a RF enclosure for EMC?
 Human Exposure Limit will not apply if no human is in RF chamber when RF is on.

 Michael Sundstrom
OHD TREQ Dallas
Electronic Lab Analyst EMC Lead
(214) 579 6312 tel:%28214%29%20579%206312   office
(940) 390 3644 tel:%28940%29%20390%203644   cell
マイク
KB5UKT


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]

Sent: Thursday, January 09, 2014 3:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Risk Assessments and mitigation for EMC chambers

In message da4b81107b2a4296adcb45d026290...@thhste15d1be4.hs20.net,
dated Thu, 9 Jan 2014, Charlie Blackham char...@sulisconsultants.com
writes:

Anyone have any documents or stories to share as to how they have
satisfied/pacified/dismissed enthusiastic Health  Safety officers who
still want to ?do something??

A safety briefing won't help if a 400 lb EUT slips off the turntable on to your 
foot. I think emergency stops are not only reasonable but would be required by 
law in some jurisdictions, and I don't see any EMC issues. Flashing lights are 
another matter; EMC issues exist and implementation is not as easy as for 
emergency stops.

Can you show that the applicable human exposure limits cannot anywhere be 
exceeded with the max amplifier and antenna?
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Nondum ex 
silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Website: http

Re: [PSES] FCC draft comments on WiFi operation in channels 12 and 13

[Michael Derby]

Hello Curt,

 

It has always been possible to use channels 12 and 13 in the USA because
they are perfectly in band channels.   However, it is very difficult for a
WLAN device to pass the FCC tests on those channels, so most manufacturers
simply choose to disable them.   Some manufacturers choose to reduce the
power on those channels.   Of course, if the whole device has sufficiently
low power, then it might pass channels 12 and 13 (or just 12) without
additional power reduction.

 

This means that most WLAN devices use only channels 1 to 11 but some do use
1 to 12 or 1 to 13.   (12 is easier to get passing than 13, since the tricky
test is a band edge issue)

 

It has always been the case that if you only test and certify your device up
to channel 11, then you cannot sell a device which could transmit on
channels 12 or 13.

 

In the past, manufacturers have asked the FCC if their devices can passive
scan on 12 and 13, even if their device is only certified up to channel 11.

Of course the answer was yes, you can passive scan because passive
scanning does not include transmission.

Of course, the assumption then should be that if the client device sees a
working access point on channel 12 or 13, it must not actually form a link
and transmit!

 

You can imagine that as a TCB, if we see an application which states that a
device transmits on channels 1 to 11 and can also passive scan on channels
12 and 13; it looks perfectly reasonable.   Many did not realise the need to
ask:  Please confirm that it cannot transmit on channels 12 or 13 if
instructed to do so by the access point.

 

It seems that some manufacturers did not make that final step.   I am not
going to say if this was a misunderstanding or avoidance of the rules by the
manufacturer or lack of explanation by the FCC; this is not my comment to
make and I'm sure there is a variety of answers.

 

So, last summer 2013, the FCC clarified the point that you can passive scan
on those channels but you cannot transmit on those channels if you are not
certified to use them, even if instructed to do so by an access point.

(Remember that the access point could be using channels 12 and 13 by
implementing power reduction, or could simply be breaking the rules!)

 

This 'clarification' came as a surprise to some manufacturers (but not all).

 

Due to this 'surprise', the FCC gave a 6 month amnesty where they would
not actively enforce/investigate this issue.   I don't like to call it a
transition period because nothing has actually changed.   It is a
clarification/explanation of the existing rules, it is not a change in the
rules.

 

I believe the amnesty expires next month.

 

 

I hope this helps.

 

 

Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Curtis Mc Namara [mailto:mcnam...@umn.edu] 
Sent: 30 January 2014 23:48
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC draft comments on WiFi operation in channels 12 and 13

 

FCC Draft KDB 594280 Software Configuration Control DR04-41649:
https://apps.fcc.gov/eas/comments/GetPublishedDocument.html?id=352
https://apps.fcc.gov/eas/comments/GetPublishedDocument.html?id=352tn=40250
1 tn=402501

This draft says that operation on channels 12 and 13 in the US cannot rely
on passive scanning alone. However, at this point it is a draft, and the
introductory paragraph says to follow previous guidance.

Has a anyone here evaluated this? I have a customer with products in the
field which use passive scanning, and they are curious whether there will be
a transition time, and whether it is still permissible and practical to ship
devices with passive scanning.

Thanks!

Curt

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Re: [PSES] RFID - USA

[Michael Derby]

Hello Mel,

 

For the RFID devices at 13.56 MHz, these come under FCC Part 15.225.

(For Industry Canada, it would be RSS-210 section A2.6)

 

RFID at 900 MHz is typically certified to FCC Part 15.247 as a DSS device.

 

For lower frequency RFID, such as 125 kHz, etc., people typically use the
general emissions limits of 15.209 and certify to Part 15C.

 

 

Thanks,   Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: mel soliven [mailto:mel_soli...@yahoo.com] 
Sent: 07 March 2014 03:11
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] RFID - USA

 

Dear Experts,

 

Would appreciate if anyone can provide on RFID requirements in America?

Not sure if FCC will suffice this requirements.

The RFID has an operating frequency of 13.56MHz. 

 

Many Thanks

Mel

 

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Re: [PSES] Concerning FCC classification of digital devices

[Michael Derby]

Hello Niels,

 

Sorry to disappoint your customer but this is a computer peripheral.

 

They would connect it to their computer for updating software, etc.
Regardless of how rarely they do it… the fact is, they do it.

It’s like a mobile phone, or a GPS Sat Nav., or a camera, etc.   It is not
normally used while connected to a laptop, but connection to a laptop (or
computer) is one of its modes.

So, yes, it is a computer peripheral.

 

If they wish to DoC as a computer peripheral;  it needs to be tested at a
lab which is accredited and also has its details shown on the ‘accredited’
section of the FCC’s website.

https://apps.fcc.gov/oetcf/eas/reports/TestFirmSearch.cfm

(Search ‘accredited’, not ‘2.948 listed’)

They would then need a DoC and that FCC Logo.

 

Alternatively, if their lab is not on that ‘accredited’ list, then they can
get a certification with a TCB using equipment class JBP.

 

 

Thanks,   Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Niels Hougaard [mailto:n...@bolls.dk] 
Sent: 14 March 2014 14:05
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Concerning FCC classification of digital devices

 

Dear list members,

 

Being an independent testing facility, we have received a question from a
costumer regarding FCC classification. 

The consumer’s product is a small portable device for use with a musical
instrument. When the product is used normally, it is attached to the
instrument by audio Jack cables. The product is battery powered, but can be
powered by a general purpose adaptor. The product has a build-in
microprocessor and therefore clock frequencies that requires a
classification with regards to FCC (47 cfr part 15, §15.101).

For software update, programming purpose , and under these circumstances
also sometimes powering, the product has a MINI-B USB connector – depending
on variant, the product can either be supplied with or without the USB cable
in the shipping box.

 

Question is

– Is this product considered a “Class B Computer Peripheral” – which require
a DoC, and an accredited test report from an NVLAP accredited test lab and
appropriate FCC logo markings (DoC or certification procedure) ?

or 

– is the product considered  “Other Class B digital device - - “ – which
require only a verification and no FCC logo marking (Verification procedure)
?

 

Our costumer states that in their point of view the users only operates the
device with a computer connected, when they are putting the device into
operation initially or for reconfiguration, software upgrade or similar.
Therefore they claims it should not be considered Computer Peripheral since
the use of the product is very different from the use of typical computer
Peripherals like keyboard, mouse or printer.

 

Is having a USB connector enough to classify the product as a “Class B
Computer Peripheral”? Or is the use of the USB connector of importance+

 

Does anyone in here have experience from similar cases?

 

Regards,

Niels

Niels Hougaard

Bolls ApS

Ved Gadekæret 11F

DK-3660 Stenløse

Denmark

 

T: +45 48 18 35 66

F: +45 48 18 35 30

 mailto:n...@bolls.dk n...@bolls.dk

 http://www.bolls.dk/ www.bolls.dk

 

 

 

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Re: [PSES] Concerning FCC classification of digital devices

[Michael Derby]

That's correct Cortland.   If the USB is only used for charging (not data
transfer), then it does not count as a 'peripheral' and therefore
Verification as Digital Device can be used.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: CR [mailto:k...@earthlink.net] 
Sent: 14 March 2014 18:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Concerning FCC classification of digital devices

 

An on-board header is much less an issue; connecting only the power pins on
a micro-USB connector eliminates data transfer as a defining capability.

Cortland Richmond

On 3/14/2014 12:08 PM, Dward wrote:

 The simple fact that it can, at any time, connect to a PC and download
software makes this a Computer Peripheral.  It does not matter how often it
can be done, nor how many times it is actually done, the fact that it can be
done and that it is a consumer device makes

 

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Re: [PSES] New EU Directives

[Michael Derby]

The EMC and LV Directives are 're-casts', so there should not be much in the
way of technical changes.

 

For the RTTE Directive, that is being phased out and replaced with the
Radio Equipment Directive which was published last week.

There should be plenty of changes for radio products, including:

. Which devices are in or out of scope.

. Frequency range applicable.

. Assessment procedure and use of Notified Bodies.

. Notified Body actions and responsibilities.

. Labelling and user manuals.

. Declaration of Conformity.

. Responsible parties.

. Market surveillance.

. Process for Class 2 devices.

 

..to name but a few.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Jim Hulbert [mailto:jim.hulb...@pb.com] 
Sent: 23 May 2014 18:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] New EU Directives

 

I will of course investigate on my own.  But is anything shockingly changed
in the new EMC, LVD, and RTTE Directives?  Or for most of us will it simply
mean updating our Declarations of Conformity?

 

Jim Hulbert

Pitney Bowes

 

 

  _  

 

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Re: [PSES] New EU Directives

[Michael Derby]

Hi Scott,

I think that two important points to consider for anyone re-branding a
product is this:

The new Radio Equipment Directive states:

The manufacturer, having detailed knowledge of the design and production
process, is best placed to carry out the conformity assessment procedure.
Conformity assessment should therefore remain solely the obligation of the
manufacturer. 

It then states:

Any economic operator that either places radio equipment on the market
under his own name or trade mark or modifies radio equipment in such a way
that compliance with this Directive may be affected should be considered to
be the manufacturer and should assume the obligations of the manufacturer. 


The Directive effectively also states that any importer who has concerns
about the compliance of the device they import, should get it tested.

When deemed appropriate with regard to the risks presented by radio
equipment, importers shall, to protect the health and safety of end-users,
carry out sample testing of radio equipment made available on the market,
investigate, and, if necessary, keep a register of complaints, of
non-conforming radio equipment and radio equipment recalls, and shall keep
distributors informed of any such monitoring.

Importers who consider or have reason to believe that radio equipment which
they have placed on the market is not in conformity with this Directive
shall immediately take the corrective measures necessary to bring that radio
equipment into conformity, to withdraw it or recall it, if appropriate.
Furthermore, where the radio equipment presents a risk, importers shall
immediately inform the competent national authorities of the Member  states
in which they made the radio equipment available on the market to that
effect, giving details, in particular, of the non-compliance and of any
corrective measures taken. 


Thanks,   Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 06 June 2014 16:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New EU Directives

Thanks!  What is the major impact on own brand labelers?

Regards,

Scott


On 6/6/14 5:53 am, T.Sato vef00...@nifty.ne.jp wrote:

 On Fri, 6 Jun 2014 00:49:58 +0800,
   Scott Xe scott...@gmail.com wrote:
 
 Is there any reason behind to have LVD, EMC and RTTE directives 
 updated in similar time?
 
 To align them with NLF, all the new approach directives which were not 
 aligned with NLF were/will be updated even if no other changes were 
 necessary.
 
 For some directives such as RTTED (RED), other significant changes 
 were also made.
 
 NLF itself have big impact, and I guess own brand labelers who 
 supplied completed product from OEMs may have hard time.
 
 Regards,
 Tom
 
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Re: [PSES] New EU Directives

[Michael Derby]

Hello,

Yes, the RED is just like the RTTED in that sense.

Presently:   If a device has a radio in it (such as a laptop with WiFi, or
other digital device with Bluetooth, etc.), then the RTTE Directive applies
to that device.   The RTTE Directive includes EMC and Safety, so the EMC
and Safety (LV) Directives do not apply to that device.

Similarly with the RED, it includes EMC and Safety, so the EMC Directive and
the Safety Directive will continue not to apply to radio products.

However, the EMC and Safety requirements within the RTTE and RE Directives
are equivalent to the requirements of the EMC and Safety Directives, with a
few noteworthy exceptions.   (For example, there is no minimum voltage limit
for radio equipment, so all battery powered equipment would need a safety
assessment)


Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 09 June 2014 10:07
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New EU Directives

In message 20af01cf83c0$8988ff10$9c9afd30$@acbcert.com, dated Mon, 9 Jun
2014, Michael Derby micha...@acbcert.com writes:


When deemed appropriate with regard to the risks presented by radio 
equipment, importers shall, to protect the health and safety of 
end-users,

So the RED, unlike the EMCD, includes provisions for electrical safety?
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] List of Harmonised standards for RED

[Michael Derby]

OJ for RED?

 

11:59pm on 11th June 2016 ?

 

J

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 08 June 2014 20:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] List of Harmonised standards for RED

 

David

 

It's unlikely to be any time soon.

 

The scope of the RED is different to the RTTE, so there will be products
transitioning between RTTE/RED and the EMC and LV Directives - this will
take a bit of time to coordinate.

 

The Commission is planning a workshop on the RED is late November - I don't
expect much to happen until sometime after that

 

Regards 

Charlie

 

From: itl-emc user group [mailto:itl...@itl.co.il] 
Sent: 08 June 2014 04:50
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] List of Harmonised standards for RED

 

Hi

Does anyone know of a target date for a list of harmonised standards for the
RED.

I just checked the web site and the list for RTTE still appears but no RED.

 

Regards,

David Shidlowsky | Technical Writer

Address 1 Bat-Sheva St. POB 87, LOD 71100 Israel

Tel 972-8-9186113 Fax 972-8-9153101

Mail e...@itl.co.il/dav...@itl.co.il  Web  http://www.itl.co.il/
www.itl.co.il

 

 http://app.sqm.co.il/SitePages/Questionnaire.aspx Fill out Customer
Satisfaction Survey

Global Certifications You Can Trust 

 

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Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

[Michael Derby]

Hello Dave,

 

5 GHz WLAN are indeed Class 2 and do indeed require the Alert Symbol.

 

The restriction of their use is that they are only permitted indoors in the 
band from 5.15 GHz to 5.35 GHz.

 

The Commission does provide a short list of typical Class 2 devices that are 
easy to explain.

Look which one is number 1 on the list…   J  ….

 

http://ec.europa.eu/enterprise/sectors/rtte/files/rtte-subclass2_en.pdf

 

 

Thanks,   Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Dave Heald [mailto:emcp...@gmail.com] 
Sent: 31 July 2014 18:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

 

Hi all,

  I know the 2.4 GHz band for WiFi no longer requires the Alert sign as the 
last restriction on use fell out in 2012, but I have a question on the 5GHz 
bands:

 

Specifically, if there is an EU-wide restriction on use (indoor use with power 
limits based on sub-band), is the Alert symbol still required?  

 

If it is not, what is the rationale for excluding it?  

 

 Note that I have been operating under the assumption that the Alert sign is 
required, but I haven't had to make the decision on whether or not to apply the 
Alert sign since 2011 when the 2.4GHz band still required it, so I want to 
check  be sure.

 

Thanks,

-Dave Heald

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Re: [PSES] Definition of unsafe product

[Michael Derby]

I'm certainly not a safety expert but I think that Lauren is on the right
track here.

The Harmonised Standards are really a tool to show compliance with the
standards.   But still, regardless of compliance with the standards if
your product is found to be non-compliant with the Directive, then it is a
non-compliant product.
The Directive says the product must be safe.   The harmonised standards are
the tools to help demonstrate that.
The basic situation here being that regardless of your safety test results,
if the device is unsafe, it's off the market.

However, if it was really that extreme, it would imply that the older
harmonised standard was found to be insufficient for demonstrating
compliance and therefore I would have thought it should have had an
immediate withdrawal from the Official Journal.

...unless the thing it failed was some new safety requirement or scenario
that had not been considered at all before.
Sometimes, completely new situations are realised and must be considered
anew, without actually being in a harmonised standard yet.
And as we know, just because it's not in a harmonised standard yet, doesn't
mean we shouldn't consider it as valid.

There are plenty of things which must be assessed by manufacturers
independently before they make it into harmonised standards.

So, maybe it was unsafe?


Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] 
Sent: 31 July 2014 19:09
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Definition of unsafe product

Having tracked development of the proposed Market Surveillance Regulation,
and stared for hours at NLF model language now incorporated in LVD... it is
frustrating how ambiguous the actionable criteria are for this sort of
thing. Authorities may act on Risk, but there is no risk assessment
standard referenced and no threshold of risk required. So regardless of
anything to do with standards, an authority's assessment that there is risk
could allow empounding, third party testing etc... all on your nickel. The
finding of risk is not 100% precluded by the use of harmonized standards
(though it may be lessened).  

I also find it interesting that only the EMCD has language requiring keeping
pace with the state of the art.

Regards,
Lauren 

-Original Message-
From: Scott Xe [mailto:scott...@gmail.com]
Sent: Thursday, July 31, 2014 12:22 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Definition of unsafe product

Recently we received a sales ban from an authority.  The authority took a
sample from the market and appointed a 3rd party laboratory for verification
of LVD conformity.  They found a non conformance on construction according
to the latest version of safety standard and concluded the product is
unsafe.  The requirement is new in the latest version and did not appear in
the previous version.

When our product was verified by the 3rd party test house, it complied with
previous version of safety standard but was the latest version of the safety
standard at time of testing.  The new version was issued 2 months later and
has an additional construction requirement.  The DoW of previous version of
safety standard is in 2016.  We are at loss how come they consider our
product unsafe with the latest version of the standard during this
transitional period.  Any previous experience to deal with such authority
can be shared?  It sounds ridiculous charge on our product.

Thanks and regards,

Scott

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Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

[Michael Derby]

The RE Directive is ‘into force’ for the member states to begin transitioning 
into their national law.   That has not happened yet.

Also, there are no harmonised standards or Notified Bodies for the RED, so it’s 
unusable from a practical point of view.

 

The relevant stakeholders have until 12 June 2016 to prepare and we must be 
able to use the RED by 12 June 2016.

The RTTE Directive will be repealed on 12 June 2016.

 

 

But yes, as Lauren says, under the RED the Alert Symbol will no longer be part 
of the labelling requirements.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] 
Sent: 31 July 2014 20:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

 

The RTTE is replaced, in part by the RED (Radio Equipment Directive – 
2014/53/EU) which covers the ‘use of spectrum’ topic and no longer calls for 
the alert symbol. 

 

From RED …

“Article 50 

Repeal 

Directive 1999/5/EC is repealed with effect from 13 June 2016. 

References to the repealed Directive shall be construed as references to this 
Directive and shall be read in accordance with the correlation table in Annex 
VIII. 

 

Article 51 

Entry into force 

This Directive shall enter into force on the twentieth day following that of 
its publication in the Official Journal of the European Union. [i.e. early 
June, 2014]”

 

I think the above means the RED is in transition and you may chose to follow it 
vs. the RTTED. Thus an alert symbol might not be required. 

 

 

Regards,

Lauren 

KLA-Tencor

 

From: Dave Heald [mailto:emcp...@gmail.com] 
Sent: Thursday, July 31, 2014 12:38 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

 

Hi all,

  I know the 2.4 GHz band for WiFi no longer requires the Alert sign as the 
last restriction on use fell out in 2012, but I have a question on the 5GHz 
bands:

 

Specifically, if there is an EU-wide restriction on use (indoor use with power 
limits based on sub-band), is the Alert symbol still required?  

 

If it is not, what is the rationale for excluding it?  

 

 Note that I have been operating under the assumption that the Alert sign is 
required, but I haven't had to make the decision on whether or not to apply the 
Alert sign since 2011 when the 2.4GHz band still required it, so I want to 
check  be sure.

 

Thanks,

-Dave Heald

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Re: [PSES] 802.11a (5GHz WiFi)

[Michael Derby]

Hi Mike,

 

Warning.. Not much research into this, so it's mostly from what I can
remember..

 

Commission Decision 2007/90/EC, which amends 2005/513/EC, states in Article
1 that they are for indoor use only.

This CEPT document might help to explain it:

http://www.erodocdb.dk/Docs/doc98/official/word/ECCDec0408.doc

 

Also, it's listed as a Class 2 device on the EU website:

http://ec.europa.eu/enterprise/sectors/rtte/files/rtte-subclass2_en.pdf

Scroll down to page 2 and it confirms why it is Class 2.   Indoor use only.

 

 

Thanks,   Michael.

 

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Sundstrom, Mike [mailto:mike.sundst...@garmin.com] 
Sent: 01 August 2014 15:10
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] 802.11a (5GHz WiFi)

 

Hello all,

My question is where can I find more information about the restrictions of
only using 802.11a inside in the EU?

What document is that stated in?

 

Thanks,

 

 

Michael Sundstrom

Garmin Compliance Engineer

2-2606

(913) 440-1540

 

Whatever your discipline, become a student of excellence in all things. Take
every opportunity to observe people who manifest the qualities of mastery.
These models of excellence will inspire you and guide you toward the
fulfillment of your highest potential.

-- Tony Buzan and Michael Gelb,
authors

 

 

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Re: [PSES] E-Labelling?

[Michael Derby]

Hi Mike,

 

Electronic labelling has always been unpopular with some of the European market 
surveillance groups and therefore considered forbidden.   To the point that the 
industry was given the impression that electronic CE Marking would never happen 
in Europe.

It seems that the European Commission did not agree fully with the 
interpretation because the new Radio Equipment Directive does include text 
which should open the door for electronic labelling of certain devices, such as 
devices with an integral screen, in the future.

I hope we should get more information from the European Commission on this, as 
the guidance comes in for the Radio Equipment Directive.

 

There is a suggestion that devices with an integral screen which use an 
electronic CE Mark but are not supplied with charged batteries may require a 
‘peel off’ temporary label with a CE Mark on it, so that the user can see the 
CE Mark before they charge it.

People have said to me:  “Why would that be needed for a phone etc., because it 
cannot actually transmit until it is charged anyway, by which time the user can 
see the CE Mark!”

….but, it’s important to remember that the CE Mark includes safety and EMC, so 
the user should not be plugging a device into a mains charger if they have not 
yet seen the CE Mark.   J

 

 

Thanks,   Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Mike Violette [mailto:mi...@acbcert.com] 
Sent: 01 August 2014 19:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] E-Labelling?

 

Thanks Ralph

 

Sorry for the abbreviation. Better : electronic labeling. 

Mike Violette

Washington Labs  American Certification Body

+1 240 401 1388


On Aug 1, 2014, at 2:00 PM, McDiarmid, Ralph 
ralph.mcdiar...@schneider-electric.com wrote:

Do you mean the e-mark or the E-mark?
___ 

Ralph McDiarmid  |   Schneider Electric   |  Solar Business  |   CANADA  |   
Regulatory Compliance Engineering 
Phone: +1-604-422-2622  |   Address: 3700 Gilmore Way, Burnaby, BC, V5G4M1 
e-mail:  mailto:ralph.mcdiar...@schneider-electric.com 
ralph.mcdiar...@schneider-electric.com  |   Site:Site: 
http://www.sesolar.com/  www.SEsolar.com 




From: 

Mike Violette mi...@acbcert.com 


To: 

EMC-PSTC@LISTSERV.IEEE.ORG, 


Date: 

08/01/2014 04:33 AM 


Subject: 

[PSES] E-Labelling?

 

  _  




Hi Experts,

I am looking for some guidance on E-labeling in the EU in particular and the 
world in general. 

I understand that the FCC has made some small movements in acceptance of 
e-labeling and Japan has some situation where e-labeling is ok, but solicit 
information on other markets' approaches.

Thanks,
Mike

Mike Violette
Washington Laboratories  American Certification Body
mi...@wll.com
+1 240 401 1388

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Re: [PSES] E-Labelling?

[Michael Derby]

HI Paul,

 

Good point…. Disclaimer, I only had my RTTE hat on.   J

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Paul Lovell (plovell) [mailto:plov...@cisco.com] 
Sent: 04 August 2014 11:20
To: Michael Derby; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] E-Labelling?

 

Hi Michael,

 

FYI, e-labelling is already permitted in the medical devices area and is 
covered by Regulation 207/2012.  Permission is limited and anything ending up 
with a patient has to be provided with paper, but this might give an idea of 
how it might develop for ITE, especially with internet provision.

 

Best regards,

 

Paul

 

 

 

Paul Lovell
Compliance Engineer

Cisco International Limited
 mailto:plov...@cisco.com plov...@cisco.com
Phone: +44 (0) 208 824 4843
Mobile: +44 (0) 775 843 1260

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: 04 August 2014 10:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] E-Labelling?

 

Hi Mike,

 

Electronic labelling has always been unpopular with some of the European market 
surveillance groups and therefore considered forbidden.   To the point that the 
industry was given the impression that electronic CE Marking would never happen 
in Europe.

It seems that the European Commission did not agree fully with the 
interpretation because the new Radio Equipment Directive does include text 
which should open the door for electronic labelling of certain devices, such as 
devices with an integral screen, in the future.

I hope we should get more information from the European Commission on this, as 
the guidance comes in for the Radio Equipment Directive.

 

There is a suggestion that devices with an integral screen which use an 
electronic CE Mark but are not supplied with charged batteries may require a 
‘peel off’ temporary label with a CE Mark on it, so that the user can see the 
CE Mark before they charge it.

People have said to me:  “Why would that be needed for a phone etc., because it 
cannot actually transmit until it is charged anyway, by which time the user can 
see the CE Mark!”

….but, it’s important to remember that the CE Mark includes safety and EMC, so 
the user should not be plugging a device into a mains charger if they have not 
yet seen the CE Mark.   J

 

 

Thanks,   Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Mike Violette [mailto:mi...@acbcert.com] 
Sent: 01 August 2014 19:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] E-Labelling?

 

Thanks Ralph

 

Sorry for the abbreviation. Better : electronic labeling. 

Mike Violette

Washington Labs  American Certification Body

+1 240 401 1388


On Aug 1, 2014, at 2:00 PM, McDiarmid, Ralph 
ralph.mcdiar...@schneider-electric.com wrote:

Do you mean the e-mark or the E-mark?
___ 

Ralph McDiarmid  |   Schneider Electric   |  Solar Business  |   CANADA  |   
Regulatory Compliance Engineering 
Phone: +1-604-422-2622  |   Address: 3700 Gilmore Way, Burnaby, BC, V5G4M1 
e-mail:  mailto:ralph.mcdiar...@schneider-electric.com 
ralph.mcdiar...@schneider-electric.com  |   Site:Site: 
http://www.sesolar.com/  www.SEsolar.com 


From: 

Mike Violette mi...@acbcert.com 


To: 

EMC-PSTC@LISTSERV.IEEE.ORG, 


Date: 

08/01/2014 04:33 AM 


Subject: 

[PSES] E-Labelling?

 

  _  




Hi Experts,

I am looking for some guidance on E-labeling in the EU in particular and the 
world in general. 

I understand that the FCC has made some small movements in acceptance of 
e-labeling and Japan has some situation where e-labeling is ok, but solicit 
information on other markets' approaches.

Thanks,
Mike

Mike Violette
Washington Laboratories  American Certification Body
mi...@wll.com
+1 240 401 1388

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Re: [PSES] E-Labelling?

[Michael Derby]

Thanks John.

So, the 'charged battery' issue is to allow market surveillance and customs to 
power it on?

Don't forget that the Alert Symbol was intended to alert the user to a 
restriction and I don't recall much information to the public about that.   :-)
(I guess that's why it's being removed through the RE D).

When discussing electronic CE Marking, one of the main arguments against 
electronic labelling by ADCO was that they wanted to strengthen the 'brand' of 
the CE Mark in the public eye; and removing it from the product was going in 
the wrong direction.   So, I'm not sure if there are mixed messages about 
whether it is just for customs and MSAs, or if it's for the user also?

Not disagreeing, just thinking.


Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 04 August 2014 11:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] E-Labelling?

In message 052201cfafc6$8f2907d0$ad7b1770$@acbcert.com, dated Mon, 4 Aug 
2014, Michael Derby micha...@acbcert.com writes:

There is a suggestion that devices with an integral screen which use an 
electronic CE Mark but are not supplied with charged batteries may 
require a ‘peel off’ temporary label with a CE Mark on it, so that the 
user can see the CE Mark before they charge it.

The CE mark is addressed to customs and market surveillance authorities, and it 
is they who need the stick-on label. The CE mark is not addressed to users. If 
it were, we should see Press ads telling the general public to look for the 
mark before buying products.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid 
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] European RTTE Class 1 and 2 devices.

[Michael Derby]

Hello all,

 

As we've been talking about the RTTE Class 1 and 2 devices, the lists have
been updated:

 

http://ec.europa.eu/enterprise/sectors/rtte/documents/index_en.htm#h2-5

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

Certification Resource for the Wireless Industry

Web:http://www.acbcert.com www.acbcert.com

 

e-mail: mailto:micha...@acbcert.com micha...@acbcert.com

Direct phone:(+1) 703 468 1746   (USA area code)

Mobile phone:   (+44) 7939 880829   (UK area code)

 

Corporate office phone: USA:   (+1) 703 847 4700

Corporate office fax:USA:   (+1) 703 847 6888

 


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Re: [PSES] Applicable SAR standard for a VoIP GSM Gateway

[Michael Derby]

Hi Michael,

 

Those standards look reasonable.   Sometimes it is possible that more than
one standard could apply.

 

I would recommend this TGN document for good European RF Exposure
guidance…..

 

http://www.rtteca.com/TGN%2017%20Version%203%20Update%20February%202014.pdf

 

 

Michael.

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Michael Loerzer [mailto:loerzer_mob...@globalnorm.de] 
Sent: 05 September 2014 15:58
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Applicable SAR standard for a VoIP GSM Gateway

 

Hi,

 

regarding health and safety requirements required by RTTED 1999/5/EC:

 

Is compliance with EN 50385 or EN 62311 required?

 

 

Best regards

 

Dipl.-Ing. Michael Loerzer

Managing Director
Regulatory Affairs Specialist

 

Globalnorm GmbH

Kurfürstenstr. 112

10787 Berlin

 

Phone +49 30 3229027-51

Cell +49 170 3229027

Fax +49 30 3229027-59

Mail mailto:michael.loer...@globalnorm.de
michael.loer...@globalnorm.de

 

 http://www.globalnorm.de/ » globalnorm.de

 http://www.globalnorm.de/service/newsletter.html » Jetzt anmelden zum
GLOBALNORM Product Compliance Newsletter.

 

Globalnorm GmbH, Sitz der Gesellschaft: Kurfürstenstr. 112, 10787 Berlin

Geschäftsführer: Dipl.-Ing. Michael Loerzer

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

 

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Re: [PSES] weird stuff in agency agreement form

[Michael Derby]

Hello,

 

I think Nick is correct, except that the requirement may not originate from
the Notified Body directly.

 

I was at a meeting with a Medical Directive Notified Body recently and,
chatting over coffee, he mentioned that his company now needs to make these
unannounced visits.   A roll of the eyes and a shake of the head.   A
requirement of the accreditation body.

 

I think you're correct that it comes from the breast implant issue and from
what I can tell, it is all part of the duel-factory idea.

A manufacturer has one sparkly nice factory in location A which is used on
accreditation day; and one other factory in location B which is used for the
other 364 days of the year.

With the breast implant issue, I believe, I am told, that the NB had
inspected the factory but the implants were not being manufactured at the
factory which had been inspected.

The idea is that the Notified Body must be able to turn up and check.

 

At least, that's what I was told.

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sent: 11 September 2014 23:03
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] weird stuff in agency agreement form

 

I'm not a betting man, but if I were, I'd lay a few quid on this having come
from an EU Notified Body which has a presence in the medical devices market.
It looks very like a reaction to the PIP breast implant scandal. 

Think of it in the context of the NB trying to be seen to react to the
lessons from that and it may make a bit more sense. Doesn't make it any more
enforceable though. 

Nick. 


On 11 Sep 2014, at 19:13, Brian Oconnell oconne...@tamuracorp.com wrote:




Am looking at the latest 'agency' general agreement form that all CABs make
their clients sign in blood.

A new clause states ... has the right to conduct unannounced audits at the
manufacture's premises as well as the premises of the manufacturers
component supplier and has the right to take samples. It is the obligation
of the holder of the certificate to ensure that an audit at the component
supplier's premises can be conducted.

Unless all of my suppliers have previously signed this agreement, or if we
can somehow get all of my bazillion suppliers to sign an agreement, it would
seem that the test house is attempting to enforce a 'transitive' legal
property. Do not see how this can fly in most North American jurisdictions.
Is this something peculiar to EU law?

Brian

 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646

 

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Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe

[Michael Derby]

Just to add to the conversation, I will throw in a little practicality…….

 

There are two primary compliance routes for manufacturers to use the RE 
Directive, as with the RTTE Directive.

A manufacturer can fully apply the harmonised standards.

Or, a manufacturer can consult a Notified Body to obtain an opinion when 
harmonised standards are not fully applied.

(I guess you could also add that there is the option for a quality assessment 
(Annex V of RTTE), using a Notified Body).

 

For the RE Directive:

There are no harmonised standards.

There are no Notified Bodies.

 

So, from a practical point of view, it is also impossible.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Anthony Thomson [mailto:ton...@europe.com] 
Sent: 29 October 2014 15:00
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

Hi Charlie,

 

Thanks for your assistance, but I still can't see anything preventing one 
claiming compliance to the RED. It's an EU directive which does appear to be 
currently 'in force' across Europe, though not yet 'enforceable' by law.

 

So why can't you claim compliance to the RED (assuming you do)? To coin a 
phrase... there's no law against it. Or is there?

 

See my ongoing questions below.

 

Regards,

Tony

Sent: Wednesday, October 29, 2014 at 12:59 PM
From: Charlie Blackham char...@sulisconsultants.com
To: Anthony Thomson ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORG 
EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

Tony

Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used 
for equipment within scope of RED until 13 June 2017, provided it was on the 
market before 16 June 2016.

T: Yes, I can see that Article 48 permits optionally applying the RTTED (et. 
al.), to new products, for 1 year after the RED becomes enforceable under law 
on 13 June 2016. However, I can't see how this sets the earliest date that 
compliance against the RED can be claimed, and this is what I'm trying to get 
to.

Article 49 says that RED shall be applied from 13 June 2016 (in other words, it 
is won’t be applicable until then). 

T: Does Article 49 say the RED applies from 13 June 2016? To me, it tells 
Member States to have everything in place to comply with the directive by 12 
June 2016 and start enforcement on 13 June 2016. It does not prevent companies 
complying before that date, does it? I'd have thought that companies are at 
liberty to comply with requirements before thay becomes legally mandatory and 
enforceable.

T: Article 51 says the RED enters into force 20 days after publication in the 
OJ which equates to 11 June 2014. So the RED is currently in force. Sadly 
there is no definitions of in force or into force within the directive, so 
common definitions needs to apply. So from Article 51, isn't the RED already 
'in force', though not yet enforceable under law?.

T:  So I can see that under Article 49 that there cannot be any laws in place 
to enforce the RED's application until 13 June 2016. Surely however you can 
claim conformance before then, you just cant be penalised for not doing so 
(considering the limitation of enforcement of Article 48).

 However . . . . It’s “only” a Directives. Directives have to be implemented 
into National Law, in at least one member state, before they can be used – 
that’s the part that currently stops you.

T: Isn't that what stops Member States enforcing a Directive? Surely companies 
can still optionally conform to it, after all the RED seems to have been in 
force since 11 June 2014 (albeit not enforceable until 13 June 2016 or 13 June 
2017 if you chose to apply the RTTED).

T: Where does this thing about at least one member state come from? I'd like 
a black and white reference for this. It seems to be something lots of people 
say without any solid foundation. How can an EU directive be legally 
enforceable in one EU country and not another? Isn't it 'all or nothing' (hence 
the 13 June 2016 date in the RED).

 RED is not a simple NLF alignment like 2014/30/EU and 2014/35/EU because there 
is also a change of scope and a number of items are moving into RED from 
EMC/LVD and out of RTTE into EMC/LVD.

 There are commission workshops on RED and EMCD planned for November, and 
issues around transition are on the agenda.

 

Regards

Charlie

 

From: Anthony Thomson [mailto:ton...@europe.com]
Sent: 29 October 2014 12:34
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

All,

 

I'm completely confused by this situation and some clarity really would be 
appreciated. Where in the directive does it say you that can't currently claim 
compliance to the RED (well, as of 11 June 2015 - see below).

 

I've heard

Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe

[Michael Derby]

It’s a valid concern Tony.   I imagine that ADCO in Europe are probably 
(hopefully) looking closely at any Notified Body who would issue a certificate 
for a Directive if they are not authorised to.   There are no Notified Bodies 
designated to the RE Directive.

 

I would like to think your waning confidence is in questionable Notified 
Bodies, rather than in the whole NB system.

In the same way as you might be happy with the idea of FCC TCBs, despite the 
fact that some TCBs get it wrong.

In the same way as you might be happy with the idea of test labs, despite the 
fact that some of them don’t seem to know how to test.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Anthony Thomson [mailto:ton...@europe.com] 
Sent: 30 October 2014 09:16
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

But the thread started with Nick Hooper saying that Notified Body's were 
already, and have issued opinions against the RED. This is where my interest 
lies, in finding a NB to issue an opinion against the RED in the coming weeks, 
when I stumbled across Nicks post questioning the validity of these NB opinions.

 

I though NB's were supposed to be competent and reliable. I often rely on them 
to ratify and confirm our regulatory position. Sounds pretty serious to me and 
I find my confidence in the whole NB system waning!

 

T

 

 

Sent: Thursday, October 30, 2014 at 8:52 AM
From: Michael Derby micha...@acbcert.com
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

Just to add to the conversation, I will throw in a little practicality…….

 

There are two primary compliance routes for manufacturers to use the RE 
Directive, as with the RTTE Directive.

A manufacturer can fully apply the harmonised standards.

Or, a manufacturer can consult a Notified Body to obtain an opinion when 
harmonised standards are not fully applied.

(I guess you could also add that there is the option for a quality assessment 
(Annex V of RTTE), using a Notified Body).

 

For the RE Directive:

There are no harmonised standards.

There are no Notified Bodies.

 

So, from a practical point of view, it is also impossible.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Anthony Thomson [mailto:ton...@europe.com]
Sent: 29 October 2014 15:00
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

Hi Charlie,

 

Thanks for your assistance, but I still can't see anything preventing one 
claiming compliance to the RED. It's an EU directive which does appear to be 
currently 'in force' across Europe, though not yet 'enforceable' by law.

 

So why can't you claim compliance to the RED (assuming you do)? To coin a 
phrase... there's no law against it. Or is there?

 

See my ongoing questions below.

 

Regards,

Tony

Sent: Wednesday, October 29, 2014 at 12:59 PM
From: Charlie Blackham char...@sulisconsultants.com
To: Anthony Thomson ton...@europe.com, EMC-PSTC@LISTSERV.IEEE.ORG 
EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

Tony

Article 48 says that the existing legislation (RTTE or EMC+LVD) may be used 
for equipment within scope of RED until 13 June 2017, provided it was on the 
market before 16 June 2016.

T: Yes, I can see that Article 48 permits optionally applying the RTTED (et. 
al.), to new products, for 1 year after the RED becomes enforceable under law 
on 13 June 2016. However, I can't see how this sets the earliest date that 
compliance against the RED can be claimed, and this is what I'm trying to get 
to.

Article 49 says that RED shall be applied from 13 June 2016 (in other words, it 
is won’t be applicable until then). 

T: Does Article 49 say the RED applies from 13 June 2016? To me, it tells 
Member States to have everything in place to comply with the directive by 12 
June 2016 and start enforcement on 13 June 2016. It does not prevent companies 
complying before that date, does it? I'd have thought that companies are at 
liberty to comply with requirements before thay becomes legally mandatory and 
enforceable.

T: Article 51 says the RED enters into force 20 days after publication in the 
OJ which equates to 11 June 2014. So the RED is currently in force. Sadly 
there is no definitions of in force or into force within the directive, so 
common definitions needs to apply. So from Article 51, isn't the RED already 
'in force', though not yet enforceable under law?.

T:  So I can see that under Article 49 that there cannot be any laws in place 
to enforce the RED's application until 13 June 2016. Surely however you can 
claim conformance before then, you just

Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe

[Michael Derby]

Hi John,

What would the disclaimer be in this case?

Disclaimer:   We are not a Notified Body to the RE Directive and this
document is legally invalid as a Notified Body certificate   ?

It doesn't sound like a very useful certificate.


Michael.


Michael Derby
Senior Regulatory Engineer
Director
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 30 October 2014 11:26
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you
sell wireless devices into Europe

In message
2655b21dc209421abdc4eeb95de1a...@bn1pr04mb309.namprd04.prod.outlook.com
, dated Thu, 30 Oct 2014, Hooper, Nick nick.hoo...@ul.com writes:

So a RTTE NB has no appointment (NANDO database listing) to issue a NB 
EU type examination Certificate for the RED, they are, at best, 
misleading their customers, they cannot give such a certificate.

True, of course, but they can issue a certificate with a suitable
disclaimer, so as not to mislead.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] New Radio Equipment Directive (RED) - please read if you sell wireless devices into Europe

[Michael Derby]

Yes, ETSI are working on new standards and updates to old standards.

As you say, they do have a timeline goal to work towards!

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: rpick...@rpqconsulting.com [mailto:rpick...@rpqconsulting.com] 
Sent: 30 October 2014 19:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

 

That raises a question for hopefully not only me.

 

Is, or will, ETSI be revising it's RTTE referenced standards? And if so, does 
anyone have any information as to when that will be completed? Hopefully it'll 
be completed before the RTTE to RED transition ends.

 

I look forward to your reply.

 

Best regards,

Ron Pickard

Sent from my smartphone

-- Original message--

From: John Woodgate

Date: Thu, Oct 30, 2014 4:40 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG;

Subject:Re: [PSES] New Radio Equipment Directive (RED) - please read if you 
sell wireless devices into Europe

In message , dated Thu, 30 Oct 2014, Anthony Thomson  writes:But the thread 
started with Nick Hooper saying that Notified Body's were already, and have 
issued opinions against the RED. This is where my interest lies, in finding a 
NB to issue an opinion against the RED in the coming weeks, when I stumbled 
across Nicks post questioning the validity of these NB opinions. I though 
NB's were supposed to be competent and reliable. I often rely on them to 
ratify and confirm our regulatory position. Sounds pretty serious to me and I 
find my confidence in the whole NB system waning!Misunderstanding. Due to some 
problems with below-par notified bodies in some countries, all NBs have to 
re-register for RED (and this applies to some other Directives, I think). So, 
NBs exist but they are not yet registered under the RED (and it is alleged that 
the process may have run into difficulties).The same applies to notified 
standards. There is no OJ list for the RED yet. But the existing harmonized 
standards have not been withdrawn.-- OOO - Own Opinions Only. With best wishes. 
See www.jmwa.demon.co.ukQuid faciamus nisi sit?John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex 
UK-This message 
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Re: [PSES] Brick power supplies and test errors (two topics)

[Michael Derby]

At least they were honest!Every lab has to have a first time that they
do each test, otherwise progress will never be made.
I hope I'm never in a role where I'm always doing things that I already know
how to do.   :-)
I personally do not have any trouble in a lab needing to learn new things.

That said, if the test was on the lab's scope of accreditation, they should
already have researched and proved that they know how to do it.

It does amaze me when I see test labs issue reports for a test (which is on
their accreditation scope) and they did not use the correct test equipment.
I ask them why and they tell me they don't have the correct equipment.
Hmm, I'm sure I remember that being an important aspect of gaining
accreditation.

As Dennis said, we see too many test reports, apparently accredited, where
the standard was not understood or correctly applied.

It seems the labs are under a lot of pressure to be cheaper and faster.   Is
that our fault, as consumers?
My concern is that compliance testing is viewed as an unwanted rubber-stamp
hurdle, not as the technical study and research in engineering that it
should be.   It also explains why many labs struggle to find a good engineer
who is happy to stay in the test lab.


Michael.


Michael Derby
Senior Regulatory Engineer
Director
ACB Europe


-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com] 
Sent: 17 December 2014 21:36
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

Pathos and tragedy, with a bit of comedy, in the EMC lab. Once had the sales
manager for a major lab say we have never done that test but would give you
a good deal so we could get experience...

Brian

From: Ed Price [mailto:edpr...@cox.net]
Sent: Wednesday, December 17, 2014 1:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

Ghery:

I found that business conditions have created large labs which strive to
provide one-stop compliance services, and that this concept is subject to
corruption by enthusiasm. By that, I mean that the labs often have a little
subsection which is tasked with doing nothing but expanding the range of
accreditations; these are the chaps who paper entire hallways with
certificates of accreditation, allowing you to take comfort that if you ever
needed a machine safety certificate for Kleptostan, you were already in the
right place. A certain disconnect exists between these certificate
harvesters (think marketing) and the other part of the lab (think
engineering) which actually has to do that rare and idiosyncratic test.

Ed Price
WB6WSN
Chula Vista, CA USA

From: Pettit, Ghery [mailto:ghery.pet...@intel.com]
Sent: Wednesday, December 17, 2014 10:00 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

I brought up some serious problems with accredited labs at the ASC C63
meetings in Mesa last month.  One accrediting body seems interested in
dealing with the issue, the others not so much.  It's so much fun to go into
a lab that isn't properly equipped to perform tests listed on its Scope of
Accreditation.

Ghery S. Pettit

From: Grasso, Charles [mailto:charles.gra...@echostar.com]
Sent: Wednesday, December 17, 2014 9:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

It would appear that the best efforts of lab accreditations are not living
up to expectations?
Or am I expecting too much? 

Best Regards
Charles Grasso
Compliance Engineer
Echostar Communications
(w) 303-706-5467
(c) 303-204-2974
(t) 3032042...@vtext.com
(e) charles.gra...@echostar.com
(e2) chasgra...@gmail.com

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Re: [PSES] Brick power supplies and test errors (two topics)

[Michael Derby]

Nice rant Tony.J

 

I heard on the new this week that there is already evidence (in the UK, at 
least) of a society backlash against the big technology movement.   People 
putting down their social media enabled smartphones and shunning the large 
super stores, to walk to the local food market and read a book.   Concerns over 
security of information but also over the monopoly of some of the larger 
companies, as we see in our own industry.

 

There was a 5G presentation at the TCB Council workshop in October which 
touched on this idea of the unpredictable social reaction to business advances.

 

As a certification body, I do see a lot of people still going to the little 
local EMC labs where the person doing the test is actually an EMC expert.   In 
some cases, the person doing the EMC test is an EMC engineer and also the EMC 
lab manager.   I like to see it and many of them appear to be really busy.   
So, there’s hope yet.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Anthony Thomson [mailto:ton...@europe.com] 
Sent: 18 December 2014 10:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

 

  

Michael asked if it's 'our' fault for pressuring labs to be cheaper and faster. 
I say not. I recon it's down to the size and structure most labs seem to have 
have evolved to.

 

I (now reluctantly) use a once independent, mid-sized lab that was acquired by 
a large multinational company. Over the course of a few years they now have 
Directors and Managing Directors and Executive Management who aren't even on 
this site, marketing departments, HR departments, a services organisation that 
looks after the finance and invoicing, and they and pay this fee and that 
royalty to the central group and for certificates and logo usage rights. They 
have Account Managers and Business Development Managers and Business Line 
Managers and Project Managers and Project Engineers and Department Managers and 
PA's and administrators. They even have a small handful of Test Engineers, but 
we don't hear much about them.

 

Nope, that's why labs are cutting corners, shaving the core services while the 
'dead wood' continues to accumulate.

 

It's the way of the world today it seems with the end consumer working ever 
harder to support it.

 

Rant over!

Tony

  

Sent: Thursday, December 18, 2014 at 9:52 AM
From: Michael Derby micha...@acbcert.com
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

At least they were honest! Every lab has to have a first time that they
do each test, otherwise progress will never be made.
I hope I'm never in a role where I'm always doing things that I already know
how to do. :-)
I personally do not have any trouble in a lab needing to learn new things.

That said, if the test was on the lab's scope of accreditation, they should
already have researched and proved that they know how to do it.

It does amaze me when I see test labs issue reports for a test (which is on
their accreditation scope) and they did not use the correct test equipment.
I ask them why and they tell me they don't have the correct equipment.
Hmm, I'm sure I remember that being an important aspect of gaining
accreditation.

As Dennis said, we see too many test reports, apparently accredited, where
the standard was not understood or correctly applied.

It seems the labs are under a lot of pressure to be cheaper and faster. Is
that our fault, as consumers?
My concern is that compliance testing is viewed as an unwanted rubber-stamp
hurdle, not as the technical study and research in engineering that it
should be. It also explains why many labs struggle to find a good engineer
who is happy to stay in the test lab.


Michael.


Michael Derby
Senior Regulatory Engineer
Director
ACB Europe


-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com]
Sent: 17 December 2014 21:36
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

Pathos and tragedy, with a bit of comedy, in the EMC lab. Once had the sales
manager for a major lab say we have never done that test but would give you
a good deal so we could get experience...

Brian

From: Ed Price [mailto:edpr...@cox.net]
Sent: Wednesday, December 17, 2014 1:29 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Brick power supplies and test errors (two topics)

Ghery:

I found that business conditions have created large labs which strive to
provide one-stop compliance services, and that this concept is subject to
corruption by enthusiasm. By that, I mean that the labs often have a little
subsection which is tasked with doing nothing but expanding the range of
accreditations; these are the chaps who paper entire hallways with
certificates of accreditation, allowing you to take comfort that if you ever
needed a machine safety certificate for Kleptostan, you

Re: [PSES] EMC on Industrial Cut-Off Saws

[Michael Derby]

It would be disappointing if emissions from household items were ever fully 
eliminated because it’s the only way I can explain to people what I do for a 
living.

 

“What do you do…..”

 

“Well, you know that crackling noise you get from the radio when someone is 
using a hair dryer…..”

 

If they fix that, I’ll have to start talking about SAR levels and then I won’t 
get invited to dinner any more.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 03 February 2015 15:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

Same is true of other power tools, drills, vacuum cleaners, etc.  I believe 
‎the thinking is these are only intermittent use.  





 

 - doug

Douglas Powell
http://www.linkedin.com/in/dougp01   


From: Bill Stumpf

Sent: Tuesday, February 3, 2015 8:14 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Reply To: Bill Stumpf

Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

Based on inquiries I've made to the FCC  IC regarding digitally controlled 
power tools, the FCC currently exempts these devices from Part 15 technical 
regulations.  Industry Canada compliance testing should be done to ICES-001 
requirements.

 

 

Bill

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Monday, February 02, 2015 10:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

Code of Federal Regulations (CFR) Title 47 Telecommunication Chapter 1 
Subchapter A Part 15

15.103 Exempted devices. 

(c) A digital device used exclusively as industrial, commercial, or medical 
test equipment.

 

Sounds like it would be FCC part 15 exempt providing the user stops operating 
the device upon a finding by the Commission or its representative that the 
device is causing harmful interference.

 

Don’t know about Canada yet but they usually follow the US.

 

-Dave

 

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Monday, February 02, 2015 5:12 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EMC on Industrial Cut-Off Saws

 

I am not at all familiar with this category of products so please excuse my 
ignorance which is an industrial cut-off saw with a 5hp electric motor for 
cutting steel rods, and such.  

 

Most of these basic model saws have no high frequency devices and brushless AC 
motors so they do not generate EMI. However, the more expensive models have 
Inverters (Frequency Drives) to slow start/stop the motor and act as a break.

 

We evaluated a saw from a company who says they do not require EMC testing on 
their saws even when they use the Inverter, as long as they follow the 
installation instructions from the inverter manufacturer (yea, I just about 
fell out of my chair). We tested one of these saws and failed CISPR 11 Class A 
Conducted Emissions by 50db (if was a prototype saw not on the market).  How do 
these people sleep at night?

 

So here is my question. Does the US and Canada require Emissions testing on 
Industrial Saws?  Same question for Europe. I assume EN 55011 Class A is 
mandatory in Europe on such a devices. 

 

Please confirm (sanity check). 

 

Thanks,

The Other Brian

 

 

  _  


LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you. 


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Re: [PSES] EMC on Industrial Cut-Off Saws

[Michael Derby]

Ha ha ha.

 

You know you’re in a boring job when you pretend to be a drug dealer to enhance 
your social acceptability.   J

 

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 04 February 2015 13:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

I know what you mean. I just tell people I’m a drug dealer. That they 
understand. J

 

The Other Brian

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: Wednesday, February 04, 2015 4:45 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

It would be disappointing if emissions from household items were ever fully 
eliminated because it’s the only way I can explain to people what I do for a 
living.

 

“What do you do…..”

 

“Well, you know that crackling noise you get from the radio when someone is 
using a hair dryer…..”

 

If they fix that, I’ll have to start talking about SAR levels and then I won’t 
get invited to dinner any more.

 

 

Michael.

 

 

Michael Derby

Senior Regulatory Engineer

Director

ACB Europe

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: 03 February 2015 15:22
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

Same is true of other power tools, drills, vacuum cleaners, etc.  I believe 
‎the thinking is these are only intermittent use.  

 

 

 - doug

Douglas Powell
http://www.linkedin.com/in/dougp01   


From: Bill Stumpf

Sent: Tuesday, February 3, 2015 8:14 AM

To: EMC-PSTC@LISTSERV.IEEE.ORG

Reply To: Bill Stumpf

Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

Based on inquiries I've made to the FCC  IC regarding digitally controlled 
power tools, the FCC currently exempts these devices from Part 15 technical 
regulations.  Industry Canada compliance testing should be done to ICES-001 
requirements.

 

 

Bill

 

From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] 
Sent: Monday, February 02, 2015 10:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

 

Code of Federal Regulations (CFR) Title 47 Telecommunication Chapter 1 
Subchapter A Part 15

15.103 Exempted devices. 

(c) A digital device used exclusively as industrial, commercial, or medical 
test equipment.

 

Sounds like it would be FCC part 15 exempt providing the user stops operating 
the device upon a finding by the Commission or its representative that the 
device is causing harmful interference.

 

Don’t know about Canada yet but they usually follow the US.

 

-Dave

 

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Monday, February 02, 2015 5:12 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EMC on Industrial Cut-Off Saws

 

I am not at all familiar with this category of products so please excuse my 
ignorance which is an industrial cut-off saw with a 5hp electric motor for 
cutting steel rods, and such.  

 

Most of these basic model saws have no high frequency devices and brushless AC 
motors so they do not generate EMI. However, the more expensive models have 
Inverters (Frequency Drives) to slow start/stop the motor and act as a break.

 

We evaluated a saw from a company who says they do not require EMC testing on 
their saws even when they use the Inverter, as long as they follow the 
installation instructions from the inverter manufacturer (yea, I just about 
fell out of my chair). We tested one of these saws and failed CISPR 11 Class A 
Conducted Emissions by 50db (if was a prototype saw not on the market).  How do 
these people sleep at night?

 

So here is my question. Does the US and Canada require Emissions testing on 
Industrial Saws?  Same question for Europe. I assume EN 55011 Class A is 
mandatory in Europe on such a devices. 

 

Please confirm (sanity check). 

 

Thanks,

The Other Brian

 

 

  _  


LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you. 


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Re: [PSES] EMC on Industrial Cut-Off Saws

[Michael Derby]

Correct.   It means exempt from having to go through the authorisation process.

But 15.5 still applies, which I think translates to  thou shalt not sell a 
rubbish (trash) product   and don't cause interference!

Most companies I speak to still test (such as 15.107 and 15.109) anyway, to 
give themselves confidence.
but of course the type of companies who discuss this with me might not 
represent a true demographic of all manufacturers out there.   :-)


Michael.


Michael Derby
Senior Regulatory Engineer
Director
ACB Europe


-Original Message-
From: CR [mailto:k...@earthlink.net] 
Sent: 08 February 2015 00:41
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EMC on Industrial Cut-Off Saws

On 2/3/2015 10:49 AM, Ted Eckert wrote:
 FCC KDB 772105
 https://apps.fcc.gov/oetcf/kdb/forms/FTSSearchResultPage.cfm?id=33062
 switch=Pgives more detail on what is exempt and what is not. Vacuum 
 cleaners are exempted, but the cut-off saw likely would not be. Hair 
 dryers and heat guns are given as examples of devices that are not 
 exempt.


But exempt doesn't mean they can willfully flout the noninterference rule:

quote:
/What household appliances, identified as Part 15 unintentional radiators, are 
considered exempt //*from the equipment authorization procedures*//? /(emphasis 
added)/ / Cortland/ /

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Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low Voltage Directive 2014/35/EU

[Michael Derby]

Hello all,

I don't know if this helps and maybe it's not the full answer, but I remember 
the conversation regarding colour photographs on the DoC when we were 
progressing the early drafts of the new Radio Equipment Directive.

There is an attempt to harmonise the administrative requirements between 
Directives of course, which can mean taking the requirements of one Directive 
and applying it to the others.   Assuming you do not want to 'soften' any 
Directives, you therefore end up 'toughening' the others.
I believe the Toy Safety Directive requires a good quality colour photo of the 
device on the DoC; therefore there was a proposal that all DoCs, to all 
Directives, should have a good quality colour photo on it.
This was finally rejected from the Radio Equipment Directive and EMC Directive 
as being an unnecessary requirement.
However, it was left that if you do decide to put photo on your DoC, it should 
be good quality and in colour (to align with the photo requirements of the Toy 
Safety Directive).

Therefore, it should not be mandatory to put the photo on your EMC or RE 
Directive DoCs, but it's an option if you want it.


Thanks,   Michael.



-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 17 March 2015 07:53
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low 
Voltage Directive 2014/35/EU

John,

Thanks for pointing that out. I didn't notice the MAY. I'll have to make a 
point to do that in the future.

 However, with my luck, I'm sure some country will translate this into a Must 
Have requirement in their law.

As you may know from other treads I've been participating in that we are 
currently looking at the current and future requirements of the DoC and 
Nameplate so I have to consider all possibilities.
I appreciate everyone's input. It has been most helpful.
Thanks for your input.
The Other Brian

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: Monday, March 16, 2015 4:57 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low 
Voltage Directive 2014/35/EU

In message
64D32EE8B9CBDD44963ACB076A5F6ABB026D385D@Mailbox-Tech.lecotech.local,
dated Mon, 16 Mar 2015, Kunde, Brian brian_ku...@lecotc.com writes:

“4. Object of the declaration (identification of apparatus allowing 
traceability; it may include a colour image of sufficient clarity where 
necessary for the identification of the apparatus):”



Does this mean we have to include a color picture of the product on the 
DoC?

No, it quite clearly says 'may', which gives permission.

What would be an acceptable alternative?

For most products, the other data the Directive requires is sufficient, but for 
some products it might be inconvenient or impossible to add all the marking, so 
a picture would make things clear.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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Re: [PSES] Integrating radio COSTs into other equipment

[Michael Derby]

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

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Re: [PSES] Integrating radio COSTs into other equipment

[Michael Derby]

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

-

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discussion list. To post a message to the list, send your e-mail to
emc-p...@ieee.org

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Re: [PSES] SV: [PSES] Integrating radio COSTs into other equipment

[Michael Derby]

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

-

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discussion list. To post a message to the list, send your e-mail to
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Re: [PSES] Interference Caused by Microwave Oven

[Michael Derby]

This isn't a particularly helpful contribution, but when I use my microwave
(used correctly, with the door closed), my Bluetooth speaker completely
stops working and any WiFi activity grinds to a halt.

I try to keep the kids away from the microwave when it's in use, as much as
I can.


Michael.


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 14 May 2015 23:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Interference Caused by Microwave Oven

In message 1f28.6030...@gmail.com, dated Thu, 14 May 2015, Doug Powell
doug...@gmail.com writes:

My question is this.  If the RF generated inside the oven does not stop 
prior to the opening of the RF seal on the door, which testing is 
responsible to identify this problem, EMC or the Safety testing

Not 'either/or': emission with the door open violates CISPR 11/EN 55011,
it's also a violation of the Section of IEC/EN 60335-2 (too late here to
look it up) and potentially a violation of the regulatory EMF exposure
limits as measured according to IEC 62233.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I
turn my back on the sun, it's to look for a rainbow John Woodgate, J M
Woodgate and Associates, Rayleigh, Essex UK

-

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Jim Bacher:  j.bac...@ieee.org
David Heald: dhe...@gmail.com

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Re: [PSES] SV: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

[Michael Derby]

Hello Amund,

I don't know if your question relates to the RED timing conversation below
(which I think has been fully answered by Nick); or if this is a new
question relating to the general requirements of the RTTE Directive (and
perhaps the RED in the future).

So, I will assume it's a completely new question related to labelling and
not related to RED timings.   Let's talk RTTE..

The 'Class 2' and 'Alert Sign' aspect are separate from the requirements for
using a Notified Body.

A Notified Body is used when the harmonised test standards were not
followed.
If you completely apply (and comply with) harmonised standards, you can sign
your own DoC without the need for a Notified Body.
If you do not follow (or do not comply with) the harmonised test standard
route, you must get a Notified Body opinion.
If you do use a Notified Body and they give their opinion, positive or
negative; regardless if it was voluntary or mandatory; you put their NB
number with your CE Mark on your product, user manual and packaging.   (No
actual requirement to put it on the DoC).

As a separate issue.   If your product can be used anywhere in the EU
and EFTA, etc., without restrictions, then it is Class 1 and the Alert
Symbol is not needed.
If it is not Class 1, then it becomes Class 2 and the Alert Symbol must be
added after the CE Mark on the product, user manual and packaging.

The two issues above are separate.   You do not need a Notified Body just
because it is a Class 2 device.


Looking ahead to the RED.   the concept will be the same; except..
There will be no Alert Symbol.
The CE Mark will not need to appear in the user manual.
The NB number will not be added to the labelling in the case of a Notified
Body review and type examination certificate.



I hope this helps but please feel free to ask more.


Michael.



-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 13 April 2015 03:46
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SV: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign,
right?

Declaration of Conformity with an alert sign (class 2) included. Then
should a Notified Body number be included in the DoC as well, right?

#Amund





-Opprinnelig melding-
Fra: Hooper, Nick [mailto:nick.hoo...@ul.com]
Sendt: 1. august 2014 15:20
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

I believe the intention is that the content of Article 49 Transposition of
the RED 2014/53/EU  should also be transposed [from the Directive] into each
member state's national law

In a recent meeting (July 2014) of the EU Commission TCAM group, a
clarification on this subject was requested from the EU commission,  and the
following comment was made to the meeting  - it is not a verbatim quote from
the EU TCAM Chair.  I am waiting for formal minutes of the meeting from the
EU Commission which will be circulated to  the RTTE CA membership.

Member States shall apply the provisions of the RED from 16 June 2016 (even
though certain Member States may adopt it earlier), and not before.
Therefore, the situation will not arise where some Member States would have
adopted the RED and others not.

I also understand ETSI and CISPR have (at least draft) mandates from the EU
to update the standards in light of the changes, such as receiver
performance requirements, within the new RED, I expected these updates [to
meet the requirements of the RED] will take many months.

Regards
Nick Hooper
RTTE CA Chairman
http://www.rtteca.com/

and I agree with John Woodgate -OOO - Own Opinions Only


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 31 July 2014 20:53
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 802.11a (5GHz WiFi) requires CE Alert sign, right?

In message
6ea35dc06888465d8cb4cb752f5ef...@blupr03mb119.namprd03.prod.outlook.com
, dated Thu, 31 Jul 2014, Crane, Lauren lauren.cr...@kla-tencor.com
writes:

I think the above means the RED is in transition and you may choose to 
follow it vs. the RTTED.

The RED cannot be used until at least one EU Member State has adopted it
into national law. I don't know whether this has happened yet.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EU Customs and EMC test report

[Michael Derby]

Hello,

 

As others have said, I do not think the Directive needs to be listed in the
test reports.   You test to standards and the manufacturer deals with the
Directive.

 

Probably, the person saw the incorrect Directive reference and flagged it
up.   If there had not been any reference to any Directive, it might not
have become an issue or even been noticed.

 

 

Michael.

 

 

From: Chuck McDowell [mailto:chu...@meyersound.com] 
Sent: 15 June 2015 21:03
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU Customs and EMC test report

 

Dear Compliance Professionals,

 

Does a EMC test report issued by a accredited testing laboratory need to
also reference the current EMC Directive 2004/108/EC?

 

My belief is that the EMC Directive needs to noted on the product
Declaration of Conformity, and not in the EMC test report. Is this correct?

A EU Customs official stop a shipment because the EMC Directive noted in the
EMC test report was out-of-date. I would like to remove EMC Directive dated
notations from future reports.

 

Thank you in advance for your comments,

 

Chuck McDowell

Compliance Specialist 

Meyer Sound Laboratories Inc.

2832 San Pablo Ave.

Berkeley, CA 94702-2204

Phone 510-486-1166 Ext. 270

Fax 510-486-8356

Email cmcdow...@meyersound.com mailto:cmcdow...@meyersound.com 

 

 

 



NOTICE: This email may contain confidential information. Please see
http://www.meyersound.com/confidential/ for our complete policy.   --  

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Re: [PSES] DoC on final product

[Michael Derby]

Hello Amund,

Yes, I would say that you do need to list the module's radio standards on the 
DoC of the final product.

After all, the person putting the final product on the market is effectively 
using those standards to state compliance of their new radio product.
Those standards are used to show compliance for the final product.


Thanks,


Michael.



http://acbcert.com/seminars/2015-Seminar-email/ACB-news-2015-Wireless-and-EMC-Training.html

Certification Resource for the Wireless Industry 
Web:   www.acbcert.com 
  
e-mail:micha...@acbcert.com 
Direct phone:(+1) 703 468 1746   (USA area code) 
Mobile phone:   (+44) 7939 880829   (UK area code) 
  
Corporate office phone: USA:   (+1) 703 847 4700 
Corporate office fax:USA:   (+1) 703 847 6888 





-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 01 June 2015 12:42
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] DoC on final product

A radio module (GSM/GPRS/EDGE) is tested according to a range of standards, 
which are listed in RTTE OJ. 
Then this radio module is installed into a non-radio ITE (EMC and LVD apply 
only).

Question: 
The final product is now a radio product and the DoC shall refer to RTTE 
1999/5/EC only.
When listing the different standards in the DoC, shall all the radio standards 
(from the radio module DoC) be listed?

I assume so, but like to check out if any comments.

Br
Amund

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Re: [PSES] Radio in class A product

[Michael Derby]

Hello Dieter,

 

In addition to the responses you already received (which I like), I would
ask you to check that your host ITE product is really 'ancillary equipment',
as defined in EN 301 489-1.

 

I think that as others have pointed out, your host product will most likely
continue to need to meet EN 55022 Class A, whilst you should check that the
emissions from your WiFi operation meets the emissions limits of EN 300 328
(and/or EN 301 893).

 

 

Thanks,   Michael.

 

 

 

From: Paasche, Dieter [mailto:dieter.paas...@christiedigital.com] 
Sent: 27 May 2015 16:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Radio in class A product

 

Dear members, 

 

I am adding a radio (WiFi module)  to an ITE class A product. The product is
tested under CISPR 22/24. I was told now that, because of the radio, the
standard to apply is EN 301489-1, and therefore my product has to meet the
class B of EN 55022 for emissions. 

 

My opinion is that product and radio have to be tested separately and test
the product to EN 55022/24 (without radio, or with the 2.4 GHz transmission
frequency filtered), and the radio or radio module by itself under EN
31489-1. Is that correct? Where can I find the right interpretation? 

 

 

 

Sincerely, 

 

Dieter Paasche

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Re: [PSES] New EMC Directive 2014/30/EU LV Directive 2014/35/EU

[Michael Derby]

Hi Scott,

 

Annex IV of 2014/53/EC is similar to Annex V of 1999/5/EC.

 

It’s an alternative compliance route, not necessarily a test report issue.

 

Michael.

 

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 24 August 2015 14:59
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New EMC Directive 2014/30/EU  LV Directive 2014/35/EU

 

Hi Charlie,

 

Thanks a million to your detail analysis!

 

As regards to 3. quality system in Annex IV of 2014/53/EU, is it referred to 
ISO 9001 quality system management?  I did not find any reference in current 
compliant reports of RTTED 99/5/EC.  Is it a new requirement for RED?  Would 
it  cause a higher level of compliance?

 

Scott

 

 

On 24 Aug, 2015, at 4:31 am, Charlie Blackham char...@sulisconsultants.com 
mailto:char...@sulisconsultants.com  wrote:

 

Scott

 

There are four scenarios for equipment within scope of RTTE and/or RED, and 
the various transition periods have been clarified by the European Commission:

 

1. PRODUCTS WITHIN OLD LVD/EMCD AND CONTINUE TO BE WITHIN NEW LVD/EMCD (EVEN 
AFTER APPLICABILITY OF RED)

 

-Products placed on market before 20 April 2016: old LVD/EMCD 

-Products placed on market on or after 20 April 2016: new LVD/EMCD

2. PRODUCTS WITHIN RTTED AND REMAIN WITHIN THE SCOPE OF RED

 

-Products placed on market before 13 June 2016: RTTED 

-Products placed on market between 13 June 2016 and 12 June 2017: RTTED or RED

-Products placed on market after 12 June 2017: RED

 

3. PRODUCTS WITHIN OLD/NEW LVD/EMCD BUT THEN FALL WITHIN RED (AFTER 
APPLICABILITY OF RED)-FOR EXAMPLE TELEVISION AND SOUND BROADCASTING RECEIVERS

 

-Products placed on market before 20 April 2016: old LVD/EMCD 

-Products placed on market between 20 April 2016 and 12 June 2016 : new LVD/EMCD

-Products placed on market between 13 June 2016 and 12 June 2017: RED or new 
LVD/EMCD 

-Products placed on market after 12 June 2017: RED

 

4. PRODUCTS WITHIN RTTED AND THEN OUTSIDE RED-FOR EXAMPLE TERMINAL EQUIPMENT 

-Products placed on market before 13 June 2016: RTTED 

-Products placed on market after 12 June 2016: RED is not applicable; new 
LVD/EMCD, if applicable to the product in question

 

 

The last scenario is the “nasty” one – there is a transition period written 
into RED, but not into EMC or LVD, so equipment that is currently RTTE, but 
not RED has to, in theory, comply with EMC/LVD “overnight”

 

Regards

Charlie

 

-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 22 August 2015 00:41
To: Charlie Blackham
Cc: EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG 
Subject: Re: [PSES] New EMC Directive 2014/30/EU  LV Directive 2014/35/EU

 

Hi Charlie,

 

Thanks for sharing the temporary solution.  For the products that compliant 
with current directives, are they just updated the DoC to comply with the new 
ones?

 

What about the RED replacing RTTE?  This one cannot be simply updated the DoC 
since all the receivers will fall into RED but not current RTTE.  The 
receivers have to be re-tested to the new directive.  The new directive does 
not publish the homogenised standards yet for the 3rd party laboratories to 
follow.  Thus they cannot test to the new directive as of today.

 

Regards,

 

Scott

 

 On 22 Aug, 2015, at 1:12 am, Charlie Blackham  
 mailto:char...@sulisconsultants.com char...@sulisconsultants.com wrote:

 

 Scott

 

 Test labs should test to standards.

 Manufacturers declare to compliance to Directives.

 The two beams should not cross :)

 

 You won't get anything officially, but unofficially the EU MSAs and 
 enforcement agencies should take a pragmatic stance regarding DoCs and not be 
 too concerned whether existing or new Directives are being referenced for 
 several months after the 20 April. *

 

 (* This was stated verbally by a representative of the UK Department for 
 Business Innovation and Skills at UK seminar earlier this year)

 

 Regards

 Charlie

 

 -Original Message-

 From: Scott Xe [ mailto:scott...@gmail.com mailto:scott...@gmail.com] 

 Sent: 21 August 2015 16:53

 To:  mailto:EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG

 Subject: [PSES] New EMC Directive 2014/30/EU  LV Directive 2014/35/EU

 

 Hi All,

 

 The captioned directives will be enforced on 20 April 2016 with no transition 
 period.  As of today, no accredited laboratories accept the compliance 
 verification to those directive until 20 April 2016.  They claim they cannot 
 test to those directives until 20 April 2016 as per the directive.  It is 
 impossible in the industry to prepare for any compliant products to be put on 
 the market on 20 April 2016.  Since there is no any technical changes, can we 
 just update the DoC using the compliant report of old directives.  Or any 
 other idea/original idea of these new directives to allow the compliant 
 product putting on the market in good order.

 

 Thanks and regards,

 

 Scott

 

 -

 

Re: [PSES] FCC market surveillance

[Michael Derby]

Hello Amund,

The FCC do perform market surveillance on certified products and every TCB
must also perform market surveillance on 5% of the devices they have
certified.
The TCB must report the findings of their surveillance to the FCC each year.

I think the results are not openly reported, but I suspect they would not be
confidential if you were to contact the FCC directly and insist to see the
results.

Devices which have been certified and then 'dismissed' are public on the FCC
website, so I guess that part can be seen easily.


Thanks,   Michael.


-Original Message-
From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 07 August 2015 11:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC market surveillance

Do FCC carry out any market surveillance to check out FCC approved
equipment?
If yes, do they publish their findings?

Best regards
Amund

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Re: [PSES] FCC Labelling

[Michael Derby]

Hi Ian,

 

You are almost correct.   The FCC's logo is only for devices which have been
authorised under the DoC process.

 

Devices which have verification or certification, do not show the FCC logo.

 

Of course, if there is a mixture of authorisation routes and one of them is
DoC, then the logo will appear.   For example, a device which has some
certification and also a DoC, would show the logo.

 

The topic is included in a recent 'New Proposed Rule Change' document from
the FCC for future change consideration; but right now it is only for use on
DoC authorised devices.

 

Thanks,

 

Michael.

 

 

From: McBurney, Ian [mailto:ian.mcbur...@allen-heath.com] 
Sent: 27 October 2015 11:53
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] FCC Labelling

 

Dear colleagues;

 

I know this question has been asked before but would I be correct in stating
that under the FCC labelling requirements that if a product is deemed
compliant in the Verification category for an unintentional radiator that it
is not permitted to mark the product with the FCC mark but you must apply
the statement " This device complies with Part 15 of the FCC Rules.
Operation is subject to the following two conditions: (1) this device may
not cause harmful interference, and (2) this device must accept any
interference received, including interference that may cause undesired
operation."

 

>From my understanding; in the unintentional radiator subpart only products
in the Declaration of Conformity or Certification categories can apply the
FCC mark to a product or its documentation.

 

Many thanks in advance.

 

Ian McBurney

Design & Compliance Engineer.

 

Allen & Heath Ltd.

 

 

Allen & Heath Ltd is a registered business in England and Wales, Company
number: 4163451. Any views expressed in this email are those of the
individual and not necessarily those of the company. 

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Re: [PSES] One DoCs vs multiple DoCs

[Michael Derby]

Hello Brian,

 

As the various EU Directives become recast and/or re-written, they will all
include the requirement to issue one DoC for the whole product, for all the
applicable Directives.

As you mentioned, you could have one for RoHS, EMD and Safety.

 

It is acceptable to have a dossier of multiple pages, but it should be
presented as one document with one signatory.

 

You're right that you probably see many companies who do not get this yet.
The requirement is relatively new and there are many people who do not
understand it yet.

 

 

Thanks,   Michael.

 

 

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 05 November 2015 19:51
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] One DoCs vs multiple DoCs

 

Greetings, experts.  

 

With the RoHS Directive kicking in at different times for different
Categories of products, I'm starting to see the RoHS Directive listed on
Declaration of Conformities.  However, I have also noticed many companies
generating two different DoCs; one for Safety and EMC and the other for RoHS
only. 

 

Can someone explain to me chapter and verse on the EU's position regarding
multiple DoCs?  

 

Our company's product category will soon be applicable to RoHS and we would
like to know if multiple DoCs are OK to do or not.  I've heard Not, but then
again, I see reputable companies doing it so what's the deal?

 

Thanks to all.

 

The Other Brian

 

 

  _  


LECO Corporation Notice: This communication may contain confidential
information intended for the named recipient(s) only. If you received this
by mistake, please destroy it and notify us of the error. Thank you. 


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Re: [PSES] FW: EMCTLA - White Paper - Modes of Operation for EMC Testing

[Michael Derby]

Hello,

Yes, I think taking the comments to GEL 210 would be on the agenda for this 
working idea.
ETSI too, of course.

The history of it is this

Some members had noticed a lot of EMC test reports which simply don't explain 
how the device was tested, monitored or assessed for compliance.
Imagine a multi-band smartphone or tablet on a table for radiated immunity in a 
shielded room with simply "operate as intended" in the report.
What does that mean?
Even for the most simple radio link or non-radio electronic operation, it was 
not always clear how the test lab monitored or observed the device.

"Refrigerator operated as intended during the test".   No thermometers were 
used?   Did you check it by tasting the milk?
We've seen test engineers assess music entertainment systems by listening to 
the music and making their own decision about whether they think the quality is 
ok.   I wonder if he has a sliding scale, based on the cost of the music system?

This issue was first brought to the attention of the EMCTLA by an auditor who 
regularly performs assessments for an accreditation body auditor; but the 
concerns were immediately echoed by Notified Bodies who had seen the same.   
The EMCTLA has many manufacturer members (no longer just EMC test labs), who 
had a lot of concern about this.   The EMCTLA also has a lot of compliance 
consultants as members and they are keen to do a good job for their customers.

The EMCTLA did consider creating a small internal working group to look at this 
but it's a complex issue.   The testing implications are large, which also 
means there are political and financial implications of a group of test labs 
all saying  "Let's all agree to be more thorough than the others!"

The status right now is that a couple of EMCTLA members have put together the 
draft paper, which I think is referenced here in this discussion.
I have distributed it internally to the EMCTLA members for comment and so far 
the comments are positive.

Future plans?

Well, once the document is finalised, I think it will be very important to 
speak with standards committees, Notified Body groups, test lab associations 
and manufacturer forums, etc.
Of course, if the EMCTLA members suddenly decide they don't like it, it won't 
go anywhere.   :-)

I hope this helps.   If it gets accepted in some form and finally posted on the 
EMCTLA website, I will be happy to e-mail a link to it, on this group.


Thanks,   Michael.



-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 11 September 2015 10:13
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] FW: EMCTLA - White Paper - Modes of Operation for EMC 
Testing

In message
,
dated Fri, 11 Sep 2015, "McCallum, Andy" 
writes:

>The EMC test house association has produced a white paper for 
>discussion on Modes of operation for EMC testing. Be interested to hear 
>your comments – I can provide a pdf copy on request.

Yes, please. Is EMCTLA planning to take its comments on standards to BSI
GEL210 any time soon?
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

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Re: [PSES] EU OJ today

[Michael Derby]

Thanks Charlie.

 

I think you make a good point.

 

The fact is that for the EMC Directive; using a harmonised standard on a 
presently valid OJ gives you presumption of conformity.

Of course need to do a risk assessment that nothing has been missed out by your 
device being ahead of the standards; but generally you can apply the standard 
and relax a little.

 

If you do not use harmonised standards, then you need to write yourself a 
justification of what you did and why you did it.   (See ‘note 1’ below)

(use of an EMCD Notified Body is never mandatory, of course)

 

So, if you take the argument that the arrival of the new OJ makes the old one 
void; then you could use the harmonised standard from the old EMCD OJ, which we 
could say no longer gives you immediate ‘presumption of conformity’ and write 
yourself a justification (‘note 1’) that you are doing it because the same 
standard was accidentally left out of the new OJ.

 

Job done.

 

I feel like market surveillance has got more to worry about than chasing that 
little problem around and around in circles.

 

 

Michael.

 

 

 

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 08 June 2016 18:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU OJ today

 

Scott

 

No argument with your comments, except that I would expect you’ll be a long 
time waiting for a “whoops, we got it wrong, please ignore what we published in 
the Official Journal on the 13th May, but please don’t ignore anything else we 
have published in it” – there’s no mechanism for it, all that can be done is a 
new one published.

 

The reality is that you need a way forward, and whilst HS provide a 
“presumption of conformity”, you don’t *need* a “presumption of conformity” 
before you CE mark – so whilst the OJ listing is not fully correct, the 
Directive already provides an acceptable route forward.

 

I’m sure the corrected list will be published as soon as possible, but in the 
meantime you need a way forward, and that was my suggestion.

 

Regards

Charlie

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 08 June 2016 17:58
To: Charlie Blackham
Cc: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] EU OJ today

 

Hi Charlie,

 

According to their guide, we can follow the old list if no new list is 
published for the new EMCD.  However the old list for old EMCD is not valid due 
to the 1st list for the new EMCD.  The new list is for new EMCD.  EU should 
notify the public for next step - awaiting for new one and apply the last one 
while new list is being prepared.

 

HS is the key for manufacturers to do presumption of conformity using module A 
route.

 

 

Regards,

 

Scott

 

 

On 9 Jun 2016, at 12:17 AM, Charlie Blackham  > wrote:

 

Scott

 

Remember EN 50561-1:2013 will only supersede EN55022 for equipment that is 
within its scope, i.e. PLT/PLC.

 

 

 
http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/electromagnetic-compatibility/index_en.htm
 is actually listing the OJ C 173 of 13/05/2016  as well as the previous OJ C 
014 of 16/01/2015 

 

As Harmonised Standards are not mandatory for the EMCD, I would just ignore the 
13 May edition, as it’s got some “known” errors in it, and follow the standards 
and DOCOPOCOSS listed in the 16 Jan edition.

 

Regards

Charlie

 

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 08 June 2016 13:15
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: Re: [PSES] EU OJ today

 

Is there any progress about the latest update that both EN 55022 and EN 55032 
will be replaced by EN EN 50361and EN 55013 removed?

 

Scott

 

 

On 14 May 2016, at 2:27 AM, John Allen <  
john_e_al...@blueyonder.co.uk> wrote:

 

“Someone” needs a really good “talking to”, I would think. :(

 

John E Allen

W.London, UK

 

From: Charlie Blackham [  
mailto:char...@sulisconsultants.com] 
Sent: 13 May 2016 19:11
To:   EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU OJ today

 

Martin

 

>I can't see EN 55022 or EN 55032 listed under the EMCD.
>Did I miss something?

 

No, they’re missing.

 

It has been noted and I understand that the Commission EMC consultant is aware 
and presume that he is following up with the Commission.

 

Regards

Charlie

 

From: Martin E. Cormier [  
mailto:mcorm...@matrox.com] 
Sent: 13 May 2016 18:32
To:   EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU OJ today

 

Thank you, Mr. Pickard.

But, it must be time for me to leave for the weekend: I can't see EN 55022 or 
EN 55032 listed under the EMCD.

Did I 

Re: [PSES] Bluetooth audio product

[Michael Derby]

Hello Ian,

 

Your product will now need to meet the R Directive.   No longer will it
be the EMCD and LVD.

 

You'll still need to consider your audio operation during your EMC testing
(does my audio still work when I apply EMC tests?), just as you have always
done.

But now, in addition, you will need to test that the Bluetooth link also
continues to work during the EMC tests.   The standard to look at there is
EN 301 489-17 and it calls up EN 301 489-1.

 

You will need to test the Bluetooth radio performance to an appropriate
standard too, such as EN 300 328.

 

EN 300 328, EN 301 489-17 and EN 301 489-1 all come in versions which are
harmonised standards, assuming you use the correct version numbers (Vx.x.x,
etc.) and you test correctly.   (Accredited test lab is not needed, but it
might give you confidence)

When you have fully applied harmonised standards, you are free to sign your
own DoC to the R Directive and you do not need a Notified Body.

 

 

For the FCC, you should check in case you are installing a module which is
already FCC certified, because the USA does have a modular approvals
process.

If the Bluetooth module is certified, you can install it with minimal
testing effort and no additional radio authorisation.

If the Bluetooth is not a module, or it is a module which is not certified,
then it will need to be tested and certified.

 

 

Please let me know if this has given you any answers, or just more
questions!

 

 

Michael.

 

 

Michael Derby 

Senior Regulatory Engineer 

Director 

ACB Europe 

 

Certification Resource for the Wireless Industry 

Web:<http://www.acbcert.com/> www.acbcert.com 

  

e-mail: <mailto:micha...@acbcert.com> micha...@acbcert.com 

Direct phone:(+1) 703 468 1746   (USA area code) 

Mobile phone:   (+44) 7939 880829   (UK area code) 

  

Corporate office phone: USA:   (+1) 703 847 4700 

Corporate office fax:USA:   (+1) 703 847 6888 

 

 

 

 

 

 

From: McBurney, Ian [mailto:ian.mcbur...@allen-heath.com] 
Sent: 09 February 2016 08:44
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Bluetooth audio product

 

Dear Colleagues.

 

I have an audio product that is Powered over Ethernet, has Bluetooth
capability and has various audio inputs and outputs. The product can be used
in a residential/consumer environment. I am very familiar with testing audio
products without wireless capability but this is the first product I have
encountered with Bluetooth that requires EMC and safety testing.

I believe that when a product has wireless capability that the EMC testing
is more formal. For example; am I required to use a notified body as I
assume the RED/RTTE directive will apply? Do I have to register the product
with the FCC? 

Please can someone advise me regarding the process for the EU and FCC
compliance.

 

Many thanks in advance,

 

Ian McBurney

Design & Compliance Engineer.

 

Allen & Heath Ltd.

Kernick Industrial Estate,

Penryn, Cornwall. TR10 9LU. UK

T: 01326 372070

E: ian.mcbur...@allen-heath.com <mailto:ian.mcbur...@allen-heath.com> 

 

 

Allen & Heath Ltd is a registered business in England and Wales, Company
number: 4163451. Any views expressed in this email are those of the
individual and not necessarily those of the company. 

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Re: [PSES] Prototype batch ... CE applies?

[Michael Derby]

Hello Amund,

I agree that you should be CE Marking these devices, as they are placed on the 
market for normal use.

If there is any flexibility to be found, then maybe it is in your application 
of the Directive.

For example, the typical way to comply with the Directive would be to fully 
apply the tests within the harmonised standards and go through the whole 
process that way.   That gives you your presumption of conformity.

If your “normal use by normal end users” is just as it sounds; then fully 
testing to the harmonised standards does indeed sound like the best idea.

But if you really mean that a select few people will be using the products in 
controlled environments, and the manufacturer has some knowledge or control 
over that environment; then maybe you can look at ways to meet the directive 
without doing all the testing.

After all, if one of the purposes of your trial is to keep the product within 
the hands of a trials engineer and see if the engineer can use it daily without 
it being killed by ESD, then fully complying with the ESD tests beforehand 
might not be necessary.   …if you see what I mean.

I hope this makes some sense.

 

Michael.

 

 

From: Amund Westin [mailto:am...@westin-emission.no] 
Sent: 07 March 2016 08:56
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Prototype batch ... CE applies?

 

Case:

Making the first prototype batch of equipment (covered by EMC and LVD). The 
limited numbers of items will be placed on the market for functional testing by 
normal end-users, before normal production starts.

Of course the CE applies, even for these prototype items. I cannot find any 
statement in the directive text or in the Blue Guide 2014, which gives granted 
exemption from the requirements. 

Exemption in the EMC directive for «Custom built evaluation kits destined for 
professionals to be used solely at research and development facilities for such 
purposes» does not match this actual case.

So, CE applies. Agree?

 

Best regards

Amund

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Re: [PSES] Colour of affixed CE Mark?

[Michael Derby]

Hello all,

 

Yep, it's all good.   Yellow sounds lovely.

 

You can check out section 4.5.1.4 of the EU Blue Guide, on the principles of
affixing the CE Mark.

http://ec.europa.eu/DocsRoom/documents/12661/attachments/1/translations/en/r
enditions/native

 

"The CE marking can take different forms (e.g. colour, solid/hollow) as long
as it remains visible, legible and respects its proportions."

 

 

Thanks,

 

Michael.

 

 

Michael Derby 

Senior Regulatory Engineer 

Director 

ACB Europe 

 

Certification Resource for the Wireless Industry 

Web:   www.acbcert.com <http://www.acbcert.com/>  

  

e-mail:micha...@acbcert.com <mailto:micha...@acbcert.com>  

Direct phone:(+1) 703 468 1746   (USA area code) 

Mobile phone:   (+44) 7939 880829   (UK area code) 

  

Corporate office phone: USA:   (+1) 703 847 4700 

Corporate office fax:USA:   (+1) 703 847 6888 

 

 

 

 

 

 

From: Rodney Davis [mailto:rodney.da...@mitel.com] 
Sent: 01 March 2016 17:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Colour of affixed CE Mark?

 

size , dimensions and proportionality are all that I have ever read. I have
never come across colour requirements, I suggest go with yellow! Will be
interesting if any one has a reference?

 

Rodney Davis

 

  _  

From: STEVENSON Philip <philip.steven...@uk.thalesgroup.com
<mailto:philip.steven...@uk.thalesgroup.com> >
Sent: Tuesday, March 1, 2016 11:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] Colour of affixed CE Mark? 

 

Dear Members

 

I am writing to ask if there any requirements for the affixed "CE" Mark
attached to a product must be a set colour i.e. must it be black? The
product we are currently in the progress of CE Marking is dark grey and
black markings are not clearly visible on this background, and therefore not
meeting the "visibly" requirement. The other markings on the product are
yellow. Therefore is it acceptable for the affixed "CE" mark to be yellow?  

 

I would be greatly for the members help. If you would prefer to contact
directly instead of via the listing my Email address is
philip.steven...@uk.thalesgroup.com
<mailto:philip.steven...@uk.thalesgroup.com> .

 

Regards

 

Philip Stevenson
Senior Specialist Engineer - Electronics, Advanced Weapons, Belfast

Thales

Land & Air Systems
Alanbrooke Road, Belfast, Northern Ireland, BT6 9HB

 <http://www.thalesgroup.com/uk> www.thalesgroup.com/uk

Tel: +44 (0)28 90465665
e-mail: philip.steven...@uk.thalesgroup.com
<mailto:philip.steven...@uk.thalesgroup.com> 

 



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Re: [PSES] Maximum Allowed Duty Cycle Correction Factor per FCC 15.35

[Michael Derby]

Hi Grace,

 

I think this is a mistake.   I think there is not a maximum allowed duty cycle 
of 20 dB.

 

I think this mistake comes from the fact that there is a peak limit which 
exists at 20 dB higher than the average limit.  




This is not the same as a difference in levels!   This is a difference in 
limits.

 

So, the limits say that you measure the peak; then you calculate the average 
based on the duty cycle.

And the Peak ‘limit’ is 20 dB above the average ‘limit’.

 

Some people seem to read this that the peak ‘value’ must be no more than 20 dB 
above the average ‘value’, but that is not correct.

 

The average ‘value’ must be below the average ‘limit’.

The peak ‘value’ must be below the peak ‘limit’.

The peak ‘limit’ is 20 dB higher than the average ‘limit’.

 

For example, let’s say you have a remote control at 315 MHz, FCC 15.231, such 
as a keyfob.   The average limit is 75.6 dBμV/m.

Therefore, there also exists a peak limit, of 95.6 dBμV/m.

 

Let’s say that you take the keyfob to the lab and measure it on a test site.   
You measure 90.0 dBμV/m, peak.

 

You calculate the duty cycle and find that it transmits for only 6 ms in the 
100 ms period.   Duty cycle factor is therefore:  20 log (6/100)  =  -24.4 dB.

 

So now you know your average value is:   

Peak value - duty cycle = Average

90.0 – 24.4  =  65.6 dBμV/m.

 

Peak Limit  =  95.6 dBμV/m

Peak Level  =  90.0 dBμV/m

Average Limit  =  75.6 dBμV/m

Average Level  =  65.6 dBμV/m

 

…..everyone’s happy.

 

Well, everyone except the person who thought that the average value could not 
be more than 20 dB less than the peak value.   :)

 

 

Thanks,

 

 

Michael.

 

 

 

 

From: Grace Lin [mailto:graceli...@gmail.com] 
Sent: 01 April 2016 21:32
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Maximum Allowed Duty Cycle Correction Factor per FCC 15.35

 

Dear Members,

 

Could  you please advise the standard which specified the maximum allowed duty 
cycle correction factor of 20 dB?

 

I remember seeing the requirement from a standard.  With a quick look at the 
FCC 15.35, ANSI C63.4-2014, and ANSI C63.10-2013, I couldn't locate the 20 dB 
maximum requirement.

 

Thank you very much for your time and I look forward to hearing from you.

 

Best regards,

Grace Lin 

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Re: [PSES] NFC Near Field Communication Devices

[Michael Derby]

Hello all,

 

Since sending my e-mail below, I have been corrected that actually it is
quite unlikely that the NFC will be below the Japanese 'extremely low power
limit', and therefore be careful not to just dismiss it too quickly.   Many
of these NFC devices are above that threshold and therefore do require
Japanese certification too.

 

Thanks,

 

Michael.

 

 

From: Michael Derby [mailto:micha...@acbcert.com] 
Sent: 05 May 2016 15:06
To: 'Kunde, Brian' <brian_ku...@lecotc.com>; 'EMC-PSTC@LISTSERV.IEEE.ORG'
<EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] NFC Near Field Communication Devices

 

Hi Brian,

 

Which geographical region are you interested in?

 

USA.  FCC Certification to FCC 15.225

Test lab must presently be listed with FCC, but will require a recognised
accreditation very soon.

Unlicensed transmitter, but certification is required.

 

Canada.   ISED Certification to RSS-210

Test lab must be listed with ISED.

Unlicensed transmitter, but certification is required.

 

Europe.   R Directive.   Harmonised Standards exist.

Lab accreditation is not mandatory for R testing.

Unlicensed transmitter.

 

Japan.   Most likely it is under the low power exemption limit thingy.

 

 

I hope this helps.

 

 

Michael.

 

 

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 04 May 2016 21:37
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] NFC Near Field Communication Devices

 

What can you tell a newb like me about NFC?  It operates in the ISM
frequency of 13.56Mhz. If we incorporate it into a product, does it require
testing by a certified or accredited lab?  It is globally accepted without
licenses and certifications?  

 

Thanks,

The Other Brian 

  _  


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information intended for the named recipient(s) only. If you received this
by mistake, please destroy it and notify us of the error. Thank you. 


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Re: [PSES] NFC Near Field Communication Devices

[Michael Derby]

Hi Brian,

 

Which geographical region are you interested in?

 

USA.  FCC Certification to FCC 15.225

Test lab must presently be listed with FCC, but will require a recognised
accreditation very soon.

Unlicensed transmitter, but certification is required.

 

Canada.   ISED Certification to RSS-210

Test lab must be listed with ISED.

Unlicensed transmitter, but certification is required.

 

Europe.   R Directive.   Harmonised Standards exist.

Lab accreditation is not mandatory for R testing.

Unlicensed transmitter.

 

Japan.   Most likely it is under the low power exemption limit thingy.

 

 

I hope this helps.

 

 

Michael.

 

 

 

From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: 04 May 2016 21:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] NFC Near Field Communication Devices

 

What can you tell a newb like me about NFC?  It operates in the ISM
frequency of 13.56Mhz. If we incorporate it into a product, does it require
testing by a certified or accredited lab?  It is globally accepted without
licenses and certifications?  

 

Thanks,

The Other Brian 

  _  


LECO Corporation Notice: This communication may contain confidential
information intended for the named recipient(s) only. If you received this
by mistake, please destroy it and notify us of the error. Thank you. 


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 >

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Re: [PSES] SAFETTY FEATURES controlled by ....SOFTWARE

[Michael Derby]

I guess you would get a similar answer from Volkswagen these days.   :-)


Michael.


-Original Message-
From: Brian O'Connell [mailto:oconne...@tamuracorp.com] 
Sent: 03 August 2016 18:10
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SAFETTY FEATURES controlled by SOFTWARE

Dear Hardware People on the third rock from Sol,

Software beings (self included) are idiotically clever and tend to be rather
subversive. We can devise profoundly evil schemes that can 'go around' fault
conditions in electrical components that forces our equipment to pump out
giggle watts of power while the surrounding creation melts down.

Pro-tips for future compliance engineers:
0. Never trust any software types; not even a single one among us. If your
significant other is a software engineer, learn to sleep with eyes open.
1. learn how to read code like a book (which means you will need to
understand the language's basic syntax and structural characteristics).
2. learn how to run code in an emulator that can run under fully static
clock conditions.
3. learn how to determine code coverage.
4. carry a large hammer to meetings with the s/w dev team.

Brian


From: Richard Nute [mailto:ri...@ieee.org] 
Sent: Wednesday, August 03, 2016 9:41 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SAFETTY FEATURES controlled by SOFTWARE

I have virtually no experience in software safety.  I'm a hardware guy.

I suggest simulating failures in the sensors (hardware) that gives the
software info about what state the battery is in.  And, simulating failures
of the hardware controlling the charging, discharging, and overcharging the
battery.  In this way, you have accounted for the worst-case failures of
both the hardware and the software.  

Rich


From: Bolintineanu, Constantin [mailto:cbolintine...@tycoint.com] 
Sent: Wednesday, August 03, 2016 7:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] SAFETTY FEATURES controlled by SOFTWARE


Dear Colleagues,

I would like to kindly ask those who have an extensive experience regarding
the above subject, to share their opinion about the following aspect:

Having a circuit which is charging a battery, and having it controlled and
protected  by SOFTWARE ONLY from the point of view of CHARGING ,
DISCHARGING, OVERCHARGING,

1. How do you think that SINGLE FAULT CONDITIONS shall be applied? (without
SOFTWARE working at all? Or by providing a fault on the component where the
SOFTWARE is stored? OR BOTH
2. Which conditions do you think that shall be imposed to the software
and/or to the memory in which it is stored?

Any other suggestions/observations/comments are more than welcome.

Sincerely,

Constantin Bolintineanu P.Eng.

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Re: [PSES] EU OJ today - EN55013/20 missing

[Michael Derby]

Hello,

 

You are correct that you can continue to use the EMCD and LVD until the end
of the RED transition period.

 

(See this useful document:
http://ec.europa.eu/DocsRoom/documents/11983/attachments/1/translations/en/r
enditions/native )

 

It's true that if the standards are not listed in the OJ for the new EMCD,
those standards do not offer immediate presumption of conformity.   It means
that the manufacturer must include some thought and justification in their
own records.   But, based on this situation, I think that justification
should be quite simple.

It would not mandate the use of a Notified Body for the EMCD; because
Notified Body use is never a mandatory requirement for the EMCD.

(If is an option to use an EMCD Notified Body, of course)

 

If you wish to use the RED before the standards are harmonised and published
on the RED OJ, though, that would require a Notified Body (type examination
certificate) for the RED.

 

In the absence of standards or guidance, most broadcast receiver
manufacturers seem to be sticking with the EMCD and LVD for as long as
possible.

 

 

Michael.

 

 

 

From: Wordley Chris [mailto:chris.word...@smardtv.com] 
Sent: 15 August 2016 15:08
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU OJ today - EN55013/20 missing

 

Thanks for highlighting this Ron.

 

Neither EN55013 nor EN55020 (broadcast receiver emission and immunity)
appear in the list for 2014/30/EU; they were listed in the OJ under the
previous EMC Directive for many years. 

 

Broadcast receivers now fall under the RED rather than the EMC directive,
but the OJ listing for the RED doesn't include any EMC standards at all so
appears virtually unusable currently for most products by anyone seeking a
presumption of conformity through applying harmonised standards. 

 

I believe that until June 2017, compliance with LVD/EMC directives is a
valid alternative to RED compliance. For emissions that would be no problem,
EN55032 is listed under 2014/30/EU and it covers broadcast receivers, but
the omission of EN55020 seems to mean that no presumption of conformity is
possible anymore? Since the product-specific standard isn't listed we could
apply a standard that is such as EN55024 (ITE) or EN61000-6-1 (generic), but
would that provide a presumption of conformity? Your opinions would be
appreciated...

 

Regards

Chris

 

From: Ronald Pickard [mailto:ronald.pick...@compoundphotonics.com] 
Sent: 12 August 2016 16:38
To: EMC-PSTC@LISTSERV.IEEE.ORG  
Subject: [PSES] EU OJ today

 

To all, FYI.

 

In the EU OJ today (see link below), there were six (6) harmonized standards
lists published relating to 5 directives and 1 regulation.

 

Directives: 2014/68/EU, 2014/53/EU (still very abbreviated), 2014/30/EU,
2014/34/EU, 2014/33/EU

Regulation: 765/2008

 

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C:2016:293:TOC

 

Best regards,

 

Ron Pickard
Regulatory Compliance Engineer
Compound Photonics 
D | +1 (602) 883-8039

 

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Re: [PSES] EU OJ today - EN55013/20 missing

[Michael Derby]

Hi Scott,

 

I suspect that the exclusion of EN 55013 and EN 55020 from the latest EMCD OJ 
is now an intentional thing, based on the fact that those products are no 
longer intended to be used with the EMC Directive…..  even though we know that 
they are, during this short transition period.

I suspect they did not want to have a specific EMCD OJ, just to cover the RED 
transition period.

 

You can use standards which are not in the OJ, of course, as long as you have a 
good reason for doing that.   You just need to keep some records of why you 
made that decision.

 

Therefore, if I were a manufacturer, I would use EN 55013 and EN 55020, declare 
against the EMCD, and keep records that I used those standards because they are 
the most appropriate standards for the product.

 

It’s true that formally you may not be using a standard which gives presumption 
of conformity (depending on the understanding of the person you’re talking to); 
but it should be very easy to justify that those are the correct standards to 
use.

 

Thanks,

 

Michael.

 

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 15 August 2016 18:06
To: Michael Derby <micha...@acbcert.com>; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU OJ today - EN55013/20 missing

 

Hi Michael,

 

Since the new HS list for EMCD does not include EN 55013 and EN 55020 for 
broadcast receivers, should we use the HS of 16/01/2015 until the EMC HS 
appears in RED.  Your given guidance document is no longer applicable for this 
scenario.  A new HS has been issued twice for the new EMCD as of today.

 

Regards,

 

Scott

 

 

 

 

From: Michael Derby <micha...@acbcert.com <mailto:micha...@acbcert.com> >
Reply-To: Michael Derby <micha...@acbcert.com <mailto:micha...@acbcert.com> >
Date: Monday, 15 August 2016 at 10:38 PM
To: <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> >
Subject: Re: [PSES] EU OJ today - EN55013/20 missing

 

Hello,

 

You are correct that you can continue to use the EMCD and LVD until the end of 
the RED transition period.

 

(See this useful document:   
http://ec.europa.eu/DocsRoom/documents/11983/attachments/1/translations/en/renditions/native
 )

 

It’s true that if the standards are not listed in the OJ for the new EMCD, 
those standards do not offer immediate presumption of conformity.   It means 
that the manufacturer must include some thought and justification in their own 
records.   But, based on this situation, I think that justification should be 
quite simple.

It would not mandate the use of a Notified Body for the EMCD; because Notified 
Body use is never a mandatory requirement for the EMCD.

(If is an option to use an EMCD Notified Body, of course)

 

If you wish to use the RED before the standards are harmonised and published on 
the RED OJ, though, that would require a Notified Body (type examination 
certificate) for the RED.

 

In the absence of standards or guidance, most broadcast receiver manufacturers 
seem to be sticking with the EMCD and LVD for as long as possible.

 

 

Michael.

 

 

 

From: Wordley Chris [mailto:chris.word...@smardtv.com] 
Sent: 15 August 2016 15:08
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] EU OJ today - EN55013/20 missing

 

Thanks for highlighting this Ron.

 

Neither EN55013 nor EN55020 (broadcast receiver emission and immunity) appear 
in the list for 2014/30/EU; they were listed in the OJ under the previous EMC 
Directive for many years. 

 

Broadcast receivers now fall under the RED rather than the EMC directive, but 
the OJ listing for the RED doesn’t include any EMC standards at all so appears 
virtually unusable currently for most products by anyone seeking a presumption 
of conformity through applying harmonised standards. 

 

I believe that until June 2017, compliance with LVD/EMC directives is a valid 
alternative to RED compliance. For emissions that would be no problem, EN55032 
is listed under 2014/30/EU and it covers broadcast receivers, but the omission 
of EN55020 seems to mean that no presumption of conformity is possible anymore? 
Since the product-specific standard isn’t listed we could apply a standard that 
is such as EN55024 (ITE) or EN61000-6-1 (generic), but would that provide a 
presumption of conformity? Your opinions would be appreciated…..

 

Regards

Chris

 

From: Ronald Pickard [mailto:ronald.pick...@compoundphotonics.com] 
Sent: 12 August 2016 16:38
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] EU OJ today

 

To all, FYI.

 

In the EU OJ today (see link below), there were six (6) harmonized standards 
lists published relating to 5 directives and 1 regulation.

 

Directives: 2014/68/EU, 2014/53/EU (still very abbreviated), 2014/30/EU, 
2014/34/EU, 2014/33/EU

Regulation: 765/2008

 

http://eur-lex.europa.eu/legal-content/EN/TXT/?uri=OJ:C:2016:293:TOC

 

Best regards,

Re: [PSES] Conformity assessment under RED

[Michael Derby]

Hi Scott,

 

Please don’t forget that for FM Radio Receivers, the Article 3.2 standard (EN 
303 345) is not expected to be cited on the RED OJ until September 2017; so 
those broadcast sound receivers could not be assessed without the use of a 
Notified Body.

 

For TV, it could be different because some of the standards (such as EN 303 
340) are already listed on the RED OJ.

 

Thanks,

 

Michael.

 

 

 

From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 19 February 2017 23:00
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Conformity assessment under RED

 

For TV/Radio receivers and BT/Wifi enabled units, it can use the HSs in 
RED/LVD/EMC of OJEU without the use of NB as per the interpretation of below.

 

Thanks,

 

Scott

 

 

 

On Wed, Jan 4, 2017 at 6:00 AM, Michael Derby <micha...@acbcert.com 
<mailto:micha...@acbcert.com> > 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 
<mailto:nick.willi...@conformance.co.uk> ]
Sent: 04 January 2017 12:18
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto: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?

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Re: [PSES] EN 55020

[Michael Derby]

Meanwhile; for Article 3.2 of the RED, remember that the new standard is EN
303 345.

 

http://www.etsi.org/deliver/etsi_en/303300_303399/303345/01.01.01_20/en_3033
45v010101a.pdf

 

And for the Bluetooth, of course it would be EN 300 328 V2.1.1.

 

 

Thanks,

 

Michael.

 

 

From: Larry K. Stillings [mailto:la...@complianceworldwide.com] 
Sent: 17 February 2017 21:53
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN 55020

 

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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endorsed by it.

 

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/BluetoothR ???

 

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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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:
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Attachments are not permitted but the IEEE PSES Online Communities site at
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Re: [PSES] Co-located modules

[Michael Derby]

Hi Stephen,

 

One thing to remember is that “must not be co-located” really just means “must 
not be co-located without some additional effort”

 

For example, co-locating two modules and then calculating the new combined RF 
Exposure MPE value to verify that the product still meets the requirements, 
would be acceptable.   It does not necessarily mean a C2PC is needed, for 
example.

 

I think you’re right that 20 cm is ‘good guidance’ with regard to RF Exposure.  
 But if your modules are 20.5cm apart, you might still want to consider the 
overall compliance of that final product… and a co-located MPE calculation is 
not too hard.

 

 

Thanks,

 

Michael.

 

 

 

From: Stephen Whalen [mailto:scwha...@bellsouth.net] 
Sent: 14 February 2017 23:34
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Co-located modules

 

All,

For a module that has "must not be co-located" restriction on FCC grant.  

What is the minimum separation distance allowed for another transmitter?  I 
recall 20cm but can't find where it is documented.

 

Regards,

Stephen

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 >

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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

Website:  http://www.ieee-pses.org/
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