[PSES] Hypervisor as a part of India TEC MTCTE Phase-V Scope Expansion

[Monrad Monsen]

Hi!
India Telecommunications Engineering Centre recently announced a Phase 5 scope 
expansion with a deadline 1 July 2024.  See the details below.
https://www.mtcte.tec.gov.in/filedownload?name=downloadDocument_20230623115821.pdf

This list includes Hypervisor which is "a purely software product" according to 
its essential requirement (ER) 
TEC30032201<https://www.mtcte.tec.gov.in/filedownload?name=TEC30032201.pdf>.

How is hypervisor (software) to be regulated and handled?  Obviously, software 
can't be labeled like hardware can. Often software is merely downloaded over 
the Internet.

I suspect that hypervisor (Phase 5) is like the earlier regulated "equipment 
operating in 2.4 GHz and 5 GHz" (Phase 3). The fact that a product operates in 
2.4 GHz or 5 GHz doesn't trigger a TEC certification requirement. Instead, if a 
product is otherwise in scope for TEC certification and then also happens to 
operate at 2.4 GHz or 5 GHz, then the ER for "equipment operating in 2.4 GHz 
and 5 GHz" is added to the testing regime.  For example, many laptops have WiFi 
that operates at both 2.4 GHz and 5 GHz, but a laptop does not have to have a 
TEC certification.  Is hypervisor software handled the same way? The software 
by itself or even a computer with hypervisor loaded does not trigger a TEC 
certification requirement. Instead, if the product is in a different product 
category that requires TEC certification but it also has hypervisor software 
loaded, then in the process of testing the other ER applicable to the hardware 
the product must also be tested for the hypervisor software functionality.  To 
give a more specific example, a server is not in-scope for an India MTCTE 
certification, so a server having hypervisor software loaded would still not be 
in-scope for India MTCTE certification. Correct?

Thanks.

Monrad Monsen


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Re: [PSES] [External] : Re: [PSES] What percentage of products pass first time?

[Monrad Monsen]

Hi Chaz,
I concur with Pete.  The key question is how much the development engineering 
team is willing to take input from hardware compliance experts (both EMC and 
safety).  Does the team invite EMC & safety input early in the development from 
concept to design (including design reviews), etc.?  Are development engineers 
checking on RoHS compliance for all components from the beginning as they 
select components? Are alternatives (extra decoupling cap points and shielding 
options worked into the design to be added as proved necessary in early trial 
pre-testing?  Is testing of early prototypes planned into the schedule to 
confirm that the design is going the right direction?  All of these are 
indicators that the final qualification testing will go smoothly with no 
surprises.  In contrast, if hardware compliance only considered as an 
afterthought with the dream that hardware compliance will just be a rubber 
stamp acceptance of what they have done, the development team is likely heading 
toward a rude awakening that could hugely impact the development schedule.

At an old company (not the one I work for today), the company experimented with 
a budget process that allocated funds to individual development programs and 
forced all outside teams (like EMC/Safety/RoHS, packaging, testing, sourcing, 
etc.) to “contract” for funding in support of those development programs.  Most 
development programs recognized the importance of EMC/Safety/RoHS, but one disk 
array development team decided that they did not need any EMC or safety 
development design support and instead only “contracted” for the bare essential 
final test and certification submission support.  Of course, this was against 
our advice, but they felt they knew better and could save some headcount cost 
(spend their funds and headcount elsewhere).  That disk array system had the 
claim to fame of being 24dB over the emissions limit, and fixing the problems 
caused redesign and anguish that delayed the product release by a year at great 
cost to the program (many EMC design support hours and engineering redesign 
hours).

That was the last year that this budgeting scheme was used, and senior 
management made it clear to all development teams that EMC/safety/RoHS must be 
involved early in the development process.

Hope this helps.
Monrad

From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org>
Sent: Monday, May 24, 2021 11:20 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [External] : Re: [PSES] What percentage of products pass first time?

Charles, et al, You question is rather simplistic, in my opinion.

   From my more than 25 years doing safety & regulatory consulting 
with dozens and dozens of companies both large and small, I find that the 
experience of the design team is the key to meeting the requirements early on.

   First timers (no prior experience having an outside lab test any 
of their work for compliance) has a pretty low pass rate; no matter how much 
advice is given during the design phase.

   Design teams quickly gain experience ramp up & meet compliance 
requirements on the next project or two providing the design is similar to 
their earlier experience.

   This level of competence can be confounded (made worse) if there 
are substantial changes in the design team between projects.  Newbies always 
think they understand the needs and design accordingly; unless an experienced 
team manager can ferret out the issue before testing and get them to change.

   Additional features (especially radios) complicate the issue, 
even for experienced design teams.

   To specifically answer your question, first designs from an 
inexperienced design team generally will need another pass (or more) thru the 
lab to qualify.  Experienced teams will have a high 1st time pass rate in most 
cases.

   To relate one scenario, a complex electronic research instrument 
was developed by a 3 man team of PhD physicists who struggled when going thru 
the EMC lab; they had no prior product certification experience.  I had offered 
to go to the lab with them but they thought they could handle it themselves.  
They had no concept of the needs to provide the proper isolation between major 
pieces (e.g. cables routinely pierced the chassis and made connexion well 
within the equipment).  After the 2nd failure the lab manager, a  long-time 
colleague, talked to me and said that they weren’t listening to his comments 
about needed changes to fix it.  Upon talking to them, they had dismissed him 
as just a technician (ignoring his EE training and EMC lab experience) and they 
believed that they knew better (but not good enough, as evidenced by the 
continuing failure).  So we had a ‘managerial discussion’ and I went to the EMC 
lab with them from then  on.  The baling wire fixes tried at the lab showed 
improvement when applied and led to installing proper 

Re: [PSES] [External] : [PSES] Date of withdrawal for UL 60950-1 and CSA 60950-1

[Monrad Monsen]

Hi Richard,
US and Canada has a grandfather clause. One does not have to go back and re-do 
the safety test & certifications for already released and NRTL approved 
products. The latest standard revisions must be used to qualify new product 
designs.
Monrad
From: Richard Georgerian 
Sent: Tuesday, January 26, 2021 8:49 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [External] : [PSES] Date of withdrawal for UL 60950-1 and CSA 60950-1

Greetings all,

Is there a date of withdrawal for the UL and CSA 60950-1? It appears that as 
long as the product was certified to 60950-1 before December 20, 2020, and the 
design does not change electrically or use alternate components that require a 
certification review, the product can still maintain the 60950-1 compliance. 
Any assistance and guidance would be most appreciated.

Thank-you,

...Richard Georgerian
Compliance Engineer
HID Global
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[PSES] EN55032:2015 + A11:2020

[Monrad Monsen]

Does anyone know what changed in amendment 11 to EN55032:2015?  Does this 
amendment make no technical changes to the requirements both for products and 
labs, but the amendment is strictly an update to annex ZZ addressing the 
relationship between EN55032 and the EMC Directive essential requirements?

 

The subscription service we use just provided us EN55032:2015 + A11:2020, but 
there are no change-bars in the document to highlight what areas might have 
changed.

 

Thanks.

Monrad Monsen

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[PSES] Does Hong Kong require same EMC/Safety/RoHS approvals and labeling as China?

[Monrad Monsen]

Does Hong Kong require the same EMC/Safety/RoHS approvals and labeling as 
China?  My focus is on regulation of automated data processing products like 
servers, PCs, disk arrays, switches, power distribution units (PDUs) and rack 
integrated systems.  For example, China requires that servers and PCs be 
labeled with a CCC mark for EMC & Safety and also Environment Friendly Use 
Period (EFUP) labeling for RoHS.  Is this required for Hong Kong as well?

 

Of course, Hong Kong is a Special Administrative Region under the People's 
Republic of China since 1 July 1997, but they have a "high degree of autonomy" 
in all matters except foreign and defense affairs for the subsequent 50 years.  
The products I support already have CCC & EFUP labeling and approvals so the 
topic has not come up until now when we might be importing a few 3rd party 
products into Hong Kong.

 

Thanks.

 

Monrad Monsen

 

 

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[PSES] Any Different Results in ESD Testing when Changing Brands of ESD Simulator (IEC 61000-4-2)

[Monrad Monsen]

Hi!

Does anyone have any stories that can be shared of a product getting a 
different ESD test result when changing the brand/model of ESD simulator?

 

I am a member of the US Technical Advisory Group (TAG) for CISPR/I 
international standards committee (Electromagnetic compatibility of information 
technology equipment, multimedia equipment and receivers). There is a proposal 
that SC77B begin work on changes to IEC 61000-4-2 (ESD) to improve the ESD 
waveform verification (some call this "calibration") because under today's 
rules different simulators create different levels of high frequency signal 
content which some believe is the primary reason for different test results.  
Some believe that the IEC 61000-4-2 waveform requirement fails to include any 
evaluation of the slope (dV/dt or dI/dt) of the impulse, and that uncontrolled 
parameter directly affects spectral content.  I would like to know if anyone 
has experienced any actual ESD test result consistency when using different 
Brand/model ESD simulators even though they are all calibrated simulators under 
today's rules.

 

I admit that our company uses the same brand & model ESD simulator as local 
labs, so I have never observed this issue myself.  My initial preference is to 
not add cost to testing and avoid forcing labs to buy new ESD simulators, but 
perhaps this cost is warranted if there are actual wide variations in ESD test 
results depending on the brand of ESD simulator.


Thanks.

 

Monrad Monsen | Hardware Compliance Strategist
Phone: +1.303.272.9612
Oracle Market Access & Hardware Compliance Strategy
500 Eldorado Blvd | Broomfield, CO 80021 



 

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Re: [PSES] Trusted resources for RoHS/Reach

[Monrad Monsen]

Hi Chaz,

John Woodgate and Lauren Crane provided some good links, but you may be wanting 
to do some real research on RoHS and need additional information.  For example, 
the RoHS Directive 2011/65/EU has been amended to restrict ten substances 
instead of the original six now.  Reading the links provided earlier would not 
catch that.  Also, there are some guidance documents released that would help 
you on cable labeling requirements, etc.  My list below is definitely not 
all-inclusive, but it will at least get you closer to the information you need 
in researching the requirements.

 

RoHS Directive 2011/65/EU:  
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32011L0065 

 

Delegated Directive (EU) 2015/863: 
https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1565389428384=CELEX:32015L0863
 This amendment adds the four restricted phthalates which became mandatory on 
22 July 2019.

 

Europe attempt to give a plain language update on the RoHS Directive updates: 
https://ec.europa.eu/environment/waste/rohs_eee/index_en.htm  This page has a 
link to the below link on the status of exemptions and the expirations.

https://ec.europa.eu/environment/waste/rohs_eee/adaptation_en.htm The key 
sentence on this page for me is: "A table providing an overview of Annex III 
and IV exemptions, including their validity status and submitted exemption 
requests, is available HYPERLINK 
"https://ec.europa.eu/environment/waste/rohs_eee/pdf/Exemptions%20list%20-%20validity%20and%20rolling%20plan_7Feb%2019_public.xlsx"here.;
 This gives a spreadsheet with the current expiration dates.  This spreadsheet 
is the best quick reference I have seen from the EU on the exemptions.

 

Harmonized Standards for RoHS Directive 2011/65/EU: 
https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/restriction-of-hazardous-substances_en
 

 

RoHS 2 FAQ:  https://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf  Very 
helpful!!!

 

All inclusive search for delegated directives amending the RoHS directive: 
https://eur-lex.europa.eu/search.html?textScope1=ti=ti=1565389857331_LAW_SUMMARY=false_DOM=ALL=advanced=proposal_LAW_JURE_SUMMARY=false=en=Directive%202011/65/EU_INIT=ALL_ALL_SUBDOM=ALL_ALL
  This includes amendments to descriptions of exemptions and expiration dates 
for exemptions.  126 entries to read. Sorry. Read these only as a last resort 
or you have difficulty sleeping at night.

 

Hope this helps.


Monrad

 

From: Grasso, Charles [mailto:charles.gra...@dish.com] 
Sent: Friday, August 2, 2019 2:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Trusted resources for RoHS/Reach

 

Hello experts,

 

I am (trying!) to put together a list of trusted resources that cover the 
various 
the RoHS and REACH standards in the EU. Regretfully a search on Google provides 
an
overabundance of material carrying with it all the concerns of the validity of 
the
information.

 

Would someone please point me to a rock-solid source of information?

 

Thanks!

 

Charles Grasso 

W: 303-706-5467

 

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Re: [PSES] UL Listing of Computer Keyboard

[Monrad Monsen]

Hi James, 
Please note that the OSHA Nationally Recognized Test Laboratory (NRTL) will 
verify your product to UL62368-1 standard (based on international IEC62368-1). 
The OSHA regulation mandates that employers provide a safe working environment 
for employees (and local building codes support those requirements) plus retail 
stores don’t want to be sued for selling unsafe products if someone is harmed 
or property damaged, so neither employers nor retail stores will buy or re-sell 
a product that does not have a NRTL approval. As Darren notes, NRTL labs are 
not just UL but also CSA, TUV Rheinland, TUV Sud, ETL (Intertek), Nemko, etc. A 
full listing is at the web page below:
https://www.osha.gov/dts/otpca/nrtl/nrtllist.html

Hope this helps.
Monrad 

Sent from my iPhone

> On Jun 18, 2018, at 3:03 AM, CATHERINE PEARSON 
> <0b0df63784fb-dmarc-requ...@ieee.org> wrote:
> 
> Hi James,
> 
> Is UL listing mandatory for IT accessories like keyboards? 
> No any NRTL certification will be sufficient, but that may not be the 
> question or answer !
> 
> Depending where you are selling the equipment, they may expect a certain 
> certification mark, 
> Ive gotten many approvals for the USA market  but its the customer who needs 
> to understand the requirements. 
> 
> I had explained to my customer that they can have any suitable certification 
> mark and it will meet the requirements, TUV, CSA, UL etc 
> However once they were selling the device, there customer would ask "Wheres 
> the UL mark" 
> there customer was not technical and didn't understand or care to understand 
> there were alternatives, just "Wheres the UL mark" 
> Ive also found this with the building inspectors who should know better ! 
> 
> So for that job, nothing but UL would do. 
> In answer to "some retailers use it as a minimum requirement for stocking 
> your products"
> Yes thats correct and you dont have much chance in convincing them to do 
> anything else. 
> I've been discussing this with the alternative approval bodies for a while, 
> that they need to improve the general public view of them so more people 
> understand that UL are only one of a number of options. 
> 
> Ive worked with many approval bodies, some better than others, some not, 
> but as a general rule, avoid the customer service agents and deal straight 
> with the engineer at the testing lab and the person whos dealing with the 
> approval.  
> 
> I have to mention my current experience with UL is very good, but then ive 
> found myself a number of responsive people who reply to your Emails and are 
> happy to discuss the project with you.
> 
> 10 years ago, it was a lot different ! 
> 
> Regards Darren. 
>  
> 
> 
> 
> 
>  
> 
> 
> 
> 
> 
> On Monday, 18 June 2018, 9:40, James Pawson (U3C) 
>  wrote:
> 
> 
> Hi folks,
>  
> Working with a client at the moment on a computer keyboard (hence the earlier 
> question). I’m trying to get a handle on the applicability of UL listing and 
> could do with some help.
>  
> Is UL listing mandatory for IT accessories like keyboards? My searching so 
> far suggests that the answer is “no”. However, I’ve read that some retailers 
> use it as a minimum requirement for stocking your products – does anyone have 
> any experience or knowledge of this?
>  
> Assuming that UL listing was required (for whatever reason, OHSA?) presumably 
> an analysis against IEC 62368-1 would be sufficient or are there other 
> tests/requirements?
>  
> If anyone has a link to any docs with more information I’d like to do some 
> more reading up.
>  
> Thanks in advance
> James
>  
>  
>  
>  
>  
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[PSES] Rack Integrated System compliance for Russia (EAC) and Taiwan (BSMI)

[Monrad Monsen]

I request your help to determine if we can do a process improvement for rack 
integrated systems. 

 

Term Definitions

. "Rack integrated system" = a single line entry on the shipping 
documentation for an assembly of servers, disk arrays, switches and power 
distribution units (PDUs) that are pre-installed inside of an equipment rack.

. "Shelf-product" = each server, each disk array, each switch and each 
power distribution unit (PDU)

 

Questions

1. Do you ship rack integrated systems into Taiwan without a BSMI approval at 
the rack integrated system level? Do you rely upon BSMI approvals of each 
shelf-product (BSMI for each server, each disk array, and each switch that is 
inside the rack)?  

 

2. Do you ship rack integrated systems into Russia without an EAC approval 
certificate at the rack integrated system level?  Do you rely upon EAC 
approvals at the shelf-product level (EAC for each server, each disk array, and 
each switch that is inside the rack)?  

 

3. If either of the answers above is a "Yes" (no testing done on integrated 
rack of equipment), then how is the shipping documentation done to support 
these imports?  Are the shelf-products within the rack integrated system listed 
on the packing list? 

 

Acronyms

. BSMI = Bureau of Standards, Metrology and Inspection

. EAC = Eurasian Conformity

 

Thank you.

 

Monrad Monsen

+1.303.272.9612 Office

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[PSES] EN60825-1 Date of Withdrawal

[Monrad Monsen]

When will EN60825-1:2014 become exclusive harmonized standard for safety of 
laser products in Europe?

 

In the EU published the harmonized standards listing for the Low Voltage 
Directive 2006/95/EC on 8 April 2016, the EN60825-1:2014 appeared in the 
listing alone with a date of withdrawal of 19 June 2017.  But then a new 
harmonized standards listing was published on 8 September 2017 for the recast 
Low Voltage Directive 2014/35/EU, and it lists two revisions of the EN60825-1 
(one revision dated 2007 and the other 2014).  This time, there is no date of 
withdrawal for conflicting superseded standard published for EN60825-1:2014.  
As a result, it appears that a manufacturer can continue to use either revision 
of the standard forever.

 

Am I correct that a manufacturer can choose either EN60825-1:2007 or 
EN60825-1:2014 to support compliance with the Low Voltage Directive 2014/35/EU 
. seemingly forever?  Has EU expressed any intent to eventually mandate 
transitioning to EN60825-1:2014?


Thanks.

 

Monrad Monsen

 

NOTE: All opinions expressed in this email are wholly my own and are not 
necessarily those of any company I work for.

 

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Re: [PSES] CE Marking HDMI Cables

[Monrad Monsen]

Hi Scott,

I agree with Ted. The Low Voltage Directive 2014/35/EU states that the 
“Directive shall apply to electrical equipment designed for use with a voltage 
rating of between 50 and 1000 V for alternating current and between 75 and 1500 
V for direct current” {Article 1}, so the HDMI cables are outside of the 
directive’s scope alone and only must meet the safety requirements as an 
authorized component of in-scope electrical equipment.

 

In contrast, HDMI cables are in-scope for the RoHS Directive 2011/65/EU.  Read 
the RoHS Frequently Asked Questions (FAQ) in section 5 with the responses to 
questions 5.1 to 5.3.  

http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf 

 

Hope this helps. 

 

Monrad Monsen

 

NOTE: All opinions expressed in this email are wholly my own and are not 
necessarily those of any company I work for.

 

From: Ted Eckert [mailto:07cf6ebeab9d-dmarc-requ...@ieee.org] 
Sent: Sunday, January 07, 2018 3:40 PM
To: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] CE Marking HDMI Cables

 

Hello Scott,

 

I believe that line voltage wires and cables used for electrical distribution 
within buildings fall under the Low Voltage Directive. The Construction 
Products Directive covers many of the products that form the physical structure 
of buildings. It does not cover mechanical and electrical systems. Many 
electrical products will still fall under the Low Voltage Directive. However, 
the voltage of an HDMI cable is below the lower limit of the Low Voltage 
Directive, so it would not be covered.

 

Here is the specification sheet for a Belden Cat5 Ethernet cable for use inside 
of walls. (I am not necessarily recommending Belden. I just expected them to be 
more diligent about listing compliance standards than other vendors.)

HYPERLINK 
"https://urldefense.proofpoint.com/v2/url?u=https-3A__edesk.belden.com_products_techdata_english_pdf_7960A.pdf=DwMGaQ=RoP1YumCXCgaWHvlZYR8PZh8Bv7qIrMUB65eapI_JnE=bdhQMzFxnmYEOUrCJpiaOszYW-e590kX_eWuZIISyNU=96WfaC1wxJzxaLa3I4zk9Fty6qb7WiZ8RhtjPC4e5qg=zSwxaS72qhP3a8NJvexmcEtP6w2D8TLCNqAuwd99WJw="https://edesk.belden.com/products/techdata/english/pdf/7960A.pdf

It has North American safety certifications, but nothing for Europe. Belden 
covers RoHS, WEEE, ELV, and BFR Directives, all environmentally related. Maybe 
I’m missing something, but I don’t see a declaration of any European safety 
requirements.

 

Ted Eckert

Microsoft Corporation

 

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

 

From: Scott Douglas [mailto:sdouglas...@gmail.com] 
Sent: Sunday, January 7, 2018 12:31 PM
To: Ted Eckert mailto:ted.eck...@microsoft.com"ted.eck...@microsoft.com>; HYPERLINK 
"mailto:EMC-PSTC@LISTSERV.IEEE.ORG"EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking HDMI Cables

 

Ted,

I sent the the RoHS FAQ and they agree the cables need to be RoHS. They resist 
CE Marking because the cables have UL approvals for use inside walls (read 
flammability). They claim there are "matching" safety requirements in the EU 
and these were not tested for. So they cannot apply the CE Mark. I contend that 
those "matching" EU safety requirements are not CE Marking requirements so do 
not apply.

Is anyone aware of any CE Marking requirements for cables used inside walls? 
Possibly under Construction Products or General Safety?

Thanks again for all comments.

Scott

On 1/4/2018 6:55 PM, Ted Eckert wrote:

Hello Scott,

 

There are U.S. and Canadian national differences to many safety standards that 
mandates flame resistance for cables such as this. Cables under 3.05 meter in 
length must be VW-1 or FT-1 or better in flame rating. (Longer cables are 
subject to stricter requirements.) This is why you can find UL approvals on 
cables, but not necessarily other international safety certifications for HDMI, 
USB and other data cables. The LVD would not apply to an HDMI cable sold on its 
own as it is below the lower voltage limit of the scope.

 

Generally, if the cable is bundled with a product, the cable does not need the 
CE marking. If the cable is sold on its own, the CE mark is required for RoHS. 
See pages 15 and 16 in the European Commission guidance document.

HYPERLINK 
"https://urldefense.proofpoint.com/v2/url?u=https-3A__na01.safelinks.protection.outlook.com_-3Furl-3Dhttp-253A-252F-252Fec.europa.eu-252Fenvironment-252Fwaste-252Frohs-5Feee-252Fpdf-252Ffaq.pdf-26data-3D02-257C01-257CTed.Eckert-2540microsoft.com-257C4d79f6d2f44a4851e41908d5560d925c-257C72f988bf86f141af91ab2d7cd011db47-257C1-257C1-257C636509538657872815-26sdata-3DosG1mS0ZUgv1ZiezjcV3D3hdLLoCk-252FSamQsdvaykYEo-253D-26reserved-3D0=DwMGaQ=RoP1YumCXCgaWHvlZYR8PZh8Bv7qIrMUB65eapI_JnE=bdhQMzFxnmYEOUrCJpiaOszYW-e590kX_eWuZIISyNU=96WfaC1wxJzxaLa3I4zk9Fty6qb7WiZ8RhtjPC4e5qg=upBf7dPfWE9zIA-pVwZMhoopsR2yxhVfCOsObEzTmxw="http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf

 

Ted Ecker

[PSES] DOW for ETSI EN 300 386 v1.6.1

[Monrad Monsen]

Hi,

ETSI published EN 300 386 v2.1.1 in July 2016.  In the standard's Foreword, 
they provide national transposition date of 30 September 2017 as the 
date-of-withdrawal (DOW) of any conflicting national standard (EN 300 386 
v1.6.1).  The last listing of harmonized standards for European Union's EMC 
Directive 2014/30/EU was published in the Official Journal on 12 August 2016.  
For some reason, the harmonized standards still cites EN 300 386 v1.6.1 and 
does not list EN 300 386 v2.1.1 at all. This leads to a series of questions.

 

What is the European Union authority for the actual date-of-withdrawal (DOW)?  
Is the real DOW the one listed in the EN standard, or does one need to wait for 
the Official Journal to finally publish a harmonized standard listing that 
publishes its own DOW?

 

It is my understanding that the DOW published in a standard is merely a 
suggestion, but the real official DOW must be published in the Official 
Journal.  If so, then the EN 300 386 will not change over to v2.1.1 on 30 
September 2017 after all.  Does anyone know how soon the next harmonized 
standard listing will be published in the Official Journal for the EMC 
Directive?  Does anyone know what DOW is proposed for EN 300 386 v1.6.1?

 

Thanks.

 

Monrad Monsen

 

 

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Re: [PSES] EU Blue Guide

[Monrad Monsen]

Downloads fine in Firefox ESR [52.3.0 (32 bit)] and Microsoft Internet Explorer 
11 … both open the separate Adobe Acrobat Pro XI application.  

 

Also downloads fine in Google Chrome [version 60.0.3112.101 (64 bit)] which 
opens the file within a new tab within the Chrome browser.

 

Monrad

 

From: Doug Powell [mailto:doug...@gmail.com] 
Sent: Wednesday, August 16, 2017 4:26 PM
To: EMC-PSTC@listserv.ieee.org
Subject: [PSES] EU Blue Guide

 

Is anyone else having difficulty downloading a working copy of the Blue Guide 
at HYPERLINK 
"https://urldefense.proofpoint.com/v2/url?u=http-3A__ec.europa.eu_DocsRoom_documents_18027_=DwMFaQ=RoP1YumCXCgaWHvlZYR8PQcxBKCX5YTpkKY057SbK10=kHgDg_xHpXI_PqsrbVJ2fMzpnpWfYBJz25hk0PAmX0s=GKsEE9KpnrZOM7MU4-TtpnzTH0NRM7AMnBgZig1KZ9s=_5sLKzGmHY6tulA8g_2_WRBboexyQczn0RcLMidD7VQ="http://ec.europa.eu/DocsRoom/documents/18027/
 

 

I've tried both formats to no avail.

 

thanks, Doug

 

-- 

 

Douglas E Powell

HYPERLINK "mailto:doug...@gmail.com"doug...@gmail.com
HYPERLINK 
"https://urldefense.proofpoint.com/v2/url?u=http-3A__www.linkedin.com_in_dougp01=DwMFaQ=RoP1YumCXCgaWHvlZYR8PQcxBKCX5YTpkKY057SbK10=kHgDg_xHpXI_PqsrbVJ2fMzpnpWfYBJz25hk0PAmX0s=GKsEE9KpnrZOM7MU4-TtpnzTH0NRM7AMnBgZig1KZ9s=t-1_S852o0VVp_thr1q9UW8G-6oCa9Z5rjJvDanlEmg="http://www.linkedin.com/in/dougp01

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[PSES] EMC Directive 2014/30/EU Harmonized Standards Listing and ETSI EN 300 386 v2.1.1

[Monrad Monsen]

The last EMC Directive 2014/30/EU harmonized standards listing published in the 
Official Journal of the European Union was back on 12 August 2016.  Are there 
any indications that a new harmonized standard listing will be published in the 
next few months? 

 

The harmonized standard listing only includes ETSI EN 300 386 v1.6.1 (2012).  
However, ETSI published ETSI EN 300 386 v2.1.1 (2016) in July 2016, and the 
standard states that "date of withdrawal of any conflicting National Standard 
(dow)" is 30 September 2017.  In theory, v2.1.1 does not become a harmonized 
standard until it is published in the Official Journal, and the harmonized 
standard listing could actually give a different DOW than what the standard was 
published with.  So . I am interested in Europe's plans on when they might 
publish a new harmonized standard list in the Official Journal.

 

Thanks.

 

Monrad Monsen

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Re: [PSES] How to find harmonised standard list?

[Monrad Monsen]

http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=uriserv:OJ.C_.2017.180.01.0005.01.ENG

Sent from my iPhone

> On Jun 12, 2017, at 7:49 AM, Piotr Galka  wrote:
> 
> Thanks,
> 
> I must be blind.
> In my search I was there for a while, but when I saw 2004/108/EC I thought I 
> found not current but historical information... and got back to looking for 
> the way from directive page.
> 
> Regards
> Piotr Galka
> P.S.
> This is third time I'm trying to answer.
> This time I deleted the ec.europa page view you put in your post because I 
> think it is the reason I got two times:
> 
> Your posting to the EMC-PSTC list has been rejected because it contains an
> attachment of type 'IMAGE/PNG'. The EMC-PSTC list has been configured to 
> reject
> such attachments.
> ==
> How do you do that, then you can put an image in the post?
> 
> 
> W dniu 2017-06-12 o 13:31, Charlie Blackham pisze:
>> Try 
>> http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/
>> Click onElectromagnetic compatibility (EMC)
>> Scroll down a bit
>>  
>> Regards
>> Charlie
>>  
>> Charlie Blackham
>> Sulis Consultants Ltd
>> Tel: +44 (0)7946 624317
>> Web: www.sulisconsultants.com
>> Registered in England and Wales, number 05466247
>>  
>> -Original Message-
>> From: Piotr Galka [mailto:piotr.ga...@micromade.pl] 
>> Sent: 12 June 2017 12:16
>> To: EMC-PSTC@LISTSERV.IEEE.ORG
>> Subject: [PSES] How to find harmonised standard list?
>>  
>> Hi All,
>>  
>> For example for 2014/30/EU whatever I write in search box I always and with:
>> http://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1497265372270=CELEX:32014L0030
>>  
>> From 2014/30/EU directive page there should be one small step to harmonised 
>> standards list but I can't find it.
>>  
>> Please let me know, what I am missing?
>>  
>> Regards
>> Piotr Galka
>>  
>> -
>> 
>> This message is from the IEEE Product Safety Engineering Society emc-pstc 
>> discussion list. To post a message to the list, send your e-mail to 
>> 
>>  
>> All emc-pstc postings are archived and searchable on the web at:
>> http://www.ieee-pses.org/emc-pstc.html
>>  
>> Attachments are not permitted but the IEEE PSES Online Communities site at 
>> http://product-compliance.oc.ieee.org/ can be used for graphics (in 
>> well-used formats), large files, etc.
>>  
>> Website:  http://www.ieee-pses.org/
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>> unsubscribe) List rules: http://www.ieee-pses.org/listrules.html
>>  
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>> Mike Cantwell 
>>  
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> 
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc 
> discussion list. To post a message to the list, send your e-mail to 
> 
> 
> All emc-pstc postings are archived and searchable on the web at: 
> http://www.ieee-pses.org/emc-pstc.html
> 
> Attachments are not permitted but the IEEE PSES Online Communities site at 
> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
> formats), large files, etc.
> 
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> 
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> 
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Re: [PSES] RED and "putting on the market"

[Monrad Monsen]

Hi Mike,

I urge you to read section 2 of the Blue Guide which can be downloaded at the 
below web address:

http://ec.europa.eu/DocsRoom/documents/18027 

 

Regarding your specific question …

> For the purpose of products manufactured outside of 

> the EU, is "put on the market" equivalent to being 

> physically brought into the EU?

Blue Guide section 2.3 states “A product is placed on the market when it is 
made available for the first time on the Union market.”

Therefore, the “made available” definition is important as well, so I will cite 
in my answer some sections from that definition as well. Besides, the RED 
directive requires that “radio equipment” comply with the directive both when 
made available (RED article 6) and put into service (RED article 7).

 

1.  Mere entry of a product into the EU territory does not automatically 
trigger “make available” or “put into service” definitions.  

Blue Guide section 2.2 states “Supplying a product is only considered as making 
available on the Union market, when the product is intended for end use on the 
Union market.”  For example, a server product can enter for a 
value-added-reseller (VAR) or value-added-distributor (VAD) to install it into 
a rack along with disk arrays and Ethernet switches to create an integrated 
solution that might be intended for sale to end-user customers outside of 
Europe.  The mere entry of the server into Europe does not trigger a CE mark 
requirement.  Of course, it would be important that the shipping documentation 
make the intended use clear to answer questions and avoid delays through 
customs.

 

2.  A product is “made available” when supplied for distribution, consumption 
or use within the European Union market. This is true even if donated free of 
charge.  In fact, it is true even if the product is merely loaned but product 
ownership is not transferred to the end user.

Blue Guide section 2.2 states: “A product is made available on the market when 
supplied for distribution, consumption or use on the Union market in the course 
of a commercial activity, whether in return for payment or free of charge.”

Also, section 2.2 states: “Thus, a transfer of a product is considered to have 
taken place, for instance, in the circumstances of sale, loan, hire, leasing 
and gift. Transfer of ownership implies that the product is intended to be 
placed at the disposal of another legal or natural person.”

 

3.  The trigger of “made available” and “placed on the market” can occur even 
before the product physically reaches the market territory – triggered by the 
advertizing campaigns, etc.

Blue Guide section 2.2 states: “Such supply includes any offer for 
distribution, consumption or use on the Union market which could result in 
actual supply (e.g. an invitation to purchase, advertising campaigns).”

Also, section 2.3 states: “Products offered for sale online by sellers based 
outside the EU are considered to be placed on the Union market if sales are 
specifically targeted at EU consumers or other end-users.”

 

4.  One may not create a huge stock-pile of products within a warehouse in 
Europe before a standard’s implementation deadline (like RED on 12 June 2017) 
and then trickle sales to end user European customers after the deadline.

Blue Guide section 2.5 states: “Putting into service takes place at the moment 
of first use within the Union by the end user for the purposes for which it was 
intended.”  This occurs when the product (per serial number) is placed in 
possession of the end user customer and the customer actually puts the product 
into service.  On the date that the product is put into service and use, the 
product must meet the European Union rules in effect on that date.

 

Hope this helps.

Monrad

DISCLAIMER:  Everything written in my email are my own opinions and are not 
necessarily those of any company for which I work.

From: Mike Sherman - Original Message - [mailto:msherma...@comcast.net] 
Sent: Thursday, February 02, 2017 9:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED and "putting on the market"

 

It is my understanding that products that are not RED compliant but are RTTE 
compliant can be "put on the market" through June 12, 2017.

 

For the purpose of products manufactured outside of the EU, is "put on the 
market" equivalent to being physically brought into the EU?

 

I'm asking this because it is evident that a number of the harmonized standards 
necessary for conformity assessment to the RED will not be published by June 
13, 2017, and Notified Bodies might not be able to handle the surge of that 
alternate path, so one obvious tactic for existing products would be to stock 
up RTTE compliant products within the EU until the RED requirements as detailed 
in the harmonized standards become more clear.

 

Mike Sherman

Graco Inc.

-


This message is from the IEEE Product Safety Engineering 

Re: [PSES] Latest OJEU

[Monrad Monsen]

Hi Kris,
I understand your point, but please look at the European Union web page I 
pointed everyone to for the Radio Equipment Directive 2014/53/EU.  This page is 
for "Radio Equipment" (see the title), it provides the link to the RED itself, 
and it provides the latest listing of harmonized standards.  Yes, these 
harmonized standards are applicable to the R as well.  And yes, I am 
confident that the harmonized standards will be significantly revised (many TTE 
only related standards removed) once the R Directive 1999/5/EC expires.  
But this page provides the latest from Europe for Radio Equipment and the RED.

Hope this helps.
Monrad Monsen

-Original Message-
From: Carpentier Kristiaan [mailto:kristiaan.carpent...@technicolor.com] 
Sent: Friday, April 29, 2016 11:56 AM
To: Monrad Monsen; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] Latest OJEU

Hi Monrad,

There are no Harmonised standards listed yet for RED, only for R  
See text: < Summary list of titles and references harmonised standards under 
Directive 1999/5/EC for R & TTE and the Mutual Recognition of their Conformity 
>.

All Harmonised radio standards for RED are in revision stage for inclusion of 
receiver parameters.

Best regards
Kris Carpentier, 

-Original Message-
From: Monrad Monsen [mailto:monrad.mon...@oracle.com]
Sent: vrijdag 29 april 2016 19:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Latest OJEU

To make things easy, below are the links to the latest harmonized standards 
listings in the OJEU.

LVD:  
http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/low-voltage/index_en.htm
 

EMC: 
http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/electromagnetic-compatibility/index_en.htm
 

RED: 
http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/rtte/index_en.htm
 

Hope this helps everyone.

Monrad Monsen

-Original Message-
From: Scott Xe [mailto:scott...@gmail.com]
Sent: Friday, April 29, 2016 12:29 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Latest OJEU

For both new LVD & EMCD, follow the latest list of old LVD & EMCD as per EU 
guidance.  However RED should have a new list to be issued within the 
transitional period or any new guidance in near future.  The accredited 
laboratories may encounter challenge to do RED test in coming one year.

Regards,

Scott

> On 11 Apr 2016, at 6:41 PM, ce-test, qualified testing bv - Gert Gremmen 
> <g.grem...@cetest.nl> wrote:
> 
> These have not been published yet, but it is to be expected that the 
> same lists will apply, though probably an updated list will be 
> published under 2014/30/EC.
> Same for LVD.
> Same for RED.
> 
> 
> Regards,
> 
> Ing. Gert Gremmen
> Approvals manager
> --
> --
> 
> 
> + ce marking of electrical/electronic equipment Independent 
> + Consultancy Services Compliance Testing and Design for CE marking
>   according to EC-directives:
>  - Electro Magnetic Compatibility 2004/108/EC
>  - Electrical Safety 2006/95/EC
>  - Medical Devices 93/42/EC
>  - Radio & Telecommunication Terminal Equipment 99/5/EC
> + Improvement of Product Quality and Reliability testing Education
> 
> Web:www.cetest.nl (English) 
> Phone :  +31 10 415 24 26
> ---
> This e-mail and any attachments thereto may contain information that 
> is confidential and/or protected by intellectual property rights and 
> are intended for the sole use of the recipient(s) named above.
> Any use of the information contained herein (including, but not 
> limited to, total or partial reproduction, communication or 
> distribution in any form) by persons other than the designated
> recipient(s) is prohibited. If you have received this e-mail in error, 
> please notify the sender either by telephone or by e-mail and delete 
> the material from any computer.
> Thank you for your co-operation.
> 
> From: McBurney, Ian [mailto:ian.mcbur...@allen-heath.com]
> Sent: Monday 11 April 2016 11:09
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] Latest OJEU
> 
> Dear colleagues
> 
> With the implementation of the new EMC & LVD directives this month, does 
> anyone know where I can access the latest OJEU to check which standards are 
> listed as acceptable for declaring conformity with the new directives.
> 
> 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
> 
> 
> Allen & Heath Ltd is a registered business in England and Wale

Re: [PSES] Latest OJEU

[Monrad Monsen]

To make things easy, below are the links to the latest harmonized standards 
listings in the OJEU.

LVD:  
http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/low-voltage/index_en.htm
 

EMC: 
http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/electromagnetic-compatibility/index_en.htm
 

RED: 
http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/rtte/index_en.htm
 

Hope this helps everyone.

Monrad Monsen

-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: Friday, April 29, 2016 12:29 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Latest OJEU

For both new LVD & EMCD, follow the latest list of old LVD & EMCD as per EU 
guidance.  However RED should have a new list to be issued within the 
transitional period or any new guidance in near future.  The accredited 
laboratories may encounter challenge to do RED test in coming one year.

Regards,

Scott

> On 11 Apr 2016, at 6:41 PM, ce-test, qualified testing bv - Gert Gremmen 
> <g.grem...@cetest.nl> wrote:
> 
> These have not been published yet, but it is to be expected that the 
> same lists will apply, though probably an updated list will be 
> published under 2014/30/EC.
> Same for LVD.
> Same for RED.
> 
> 
> Regards,
> 
> Ing. Gert Gremmen
> Approvals manager
> --
> --
> 
> 
> + ce marking of electrical/electronic equipment Independent 
> + Consultancy Services Compliance Testing and Design for CE marking
>   according to EC-directives:
>  - Electro Magnetic Compatibility 2004/108/EC
>  - Electrical Safety 2006/95/EC
>  - Medical Devices 93/42/EC
>  - Radio & Telecommunication Terminal Equipment 99/5/EC
> + Improvement of Product Quality and Reliability testing Education
> 
> Web:www.cetest.nl (English) 
> Phone :  +31 10 415 24 26
> ---
> This e-mail and any attachments thereto may contain information that 
> is confidential and/or protected by intellectual property rights and 
> are intended for the sole use of the recipient(s) named above.
> Any use of the information contained herein (including, but not 
> limited to, total or partial reproduction, communication or 
> distribution in any form) by persons other than the designated
> recipient(s) is prohibited. If you have received this e-mail in error, 
> please notify the sender either by telephone or by e-mail and delete 
> the material from any computer.
> Thank you for your co-operation.
> 
> From: McBurney, Ian [mailto:ian.mcbur...@allen-heath.com]
> Sent: Monday 11 April 2016 11:09
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] Latest OJEU
> 
> Dear colleagues
> 
> With the implementation of the new EMC & LVD directives this month, does 
> anyone know where I can access the latest OJEU to check which standards are 
> listed as acceptable for declaring conformity with the new directives.
> 
> 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
> 
> 
> 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. 
> -
> 
> This message is from the IEEE Product Safety Engineering Society 
> emc-pstc discussion list. To post a message to the list, send your 
> e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and 
> searchable on the web at: http://www.ieee-pses.org/emc-pstc.html
> Attachments are not permitted but the IEEE PSES Online Communities site at 
> http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
> formats), large files, etc.
> Website: http://www.ieee-pses.org/
> Instructions: http://www.ieee-pses.org/list.html (including how to 
> unsubscribe) List rules: http://www.ieee-pses.org/listrules.html
> For help, send mail to the list administrators:
> Scott Douglas <sdoug...@ieee.org>
> Mike Cantwell <mcantw...@ieee.org>
> For policy questions, send mail to:
> Jim Bacher <j.bac...@ieee.org>
> David Heald <dhe...@gmail.com>
> 
> -
> 
> This message is from the IEEE Product Safety Engineering Society 
> emc-pstc discussion list. To post a message to the list, send your 
> e-mail to <emc-p...@ieee.org>

Re: [PSES] RF Common Mode Immunity Test Question

[Monrad Monsen]

Hi Gert & John,
Gert gave some interesting examples of radiated immunity failures 
(analogue measurement systems like thermocouples), but none of them 
apply to computers (the products I usually work on). Also, Gert 
mentioned some power supply design mistakes that have caused EFT 
failures in the past. As mentioned, it is rare that computer 
manufacturers design new power supplies as they go from CPU generation 
to CPU generation, so there is really no need to redo the power related 
immunity testing (especially benign EFT testing) for such changes 
unrelated to the power supply.  Hence, this testing is a waste of time 
and money ... adding cost to the product development which is ultimately 
passed to the customer.


John & others would point out that ... "In Europe, no testing is 
mandatory."  However, there is an expectation that some analysis be 
documented for why a test was not run.  It is not until a regulator 
audits that one would know if the explanation is "good enough".  Rather 
than writing a doctoral thesis on why a test does not apply to the next 
generation product, most resign themselves to running the uninteresting 
test to "complete the record".   Besides, South Korea does not give any 
wiggle room for engineering judgment, so the test must be run for them 
anyway.


The problem with government regulation is that politicians and 
bureaucrats are not engineers.  They certainly do not want to take the 
time to analyze each product's design and create a product specific 
regulation.  Instead, regulators tend to lump all products together and 
create a one-size-fits-all regulation for what is required to get their 
approval.  They also treat all manufacturers as equal ignoring a 
manufacturer's design & performance history.  As a result, government 
regulations are inherently wasteful and should only be applied when 
there are customer safety issues or excessive interference potential 
neighbors.


John mentions the horror stories of 6dB differences in measured results 
that are supposed to be solved by measurement uncertainty and 
improvements on the non-conducting tables.  However, the FCC limits 
(similar limits were later adopted internationally) were set with a 
margin to account for measurement issues.  Years later today, most 
communications are digital with error correction that which causes TV 
reception to be crisp and other communications to be more fault 
tolerant.   As there are no interference complaints, then there is no 
need to add extra site calibration days to a lab's accreditation 
requirements or lab equipment costs.  These costs get passed on to 
manufacturers who must then pass them ultimately to their customers.


I note that even while some in the standards community are adding cost 
in their efforts to systematically remove variation in measurements, no 
one is then passing on the benefits of this improved measurement system 
to manufacturers & their customers by accordingly raising the allowed 
emissions limits.  Wonder why???


Monrad
Note:  All opinions expressed in this e-mail are my own and are not 
necessarily those of any company I work for or have worked for.




-

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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Re: [PSES] RF Common Mode Immunity Test Question

[Monrad Monsen]

Interesting discussion regarding pros & cons on government regulations.

The companies I have worked for took it seriously that they wanted their 
products to be reliable to maintain a good name with customers.  We did 
ESD, voltage dips & interrupts, and shock & vibration testing on our 
products long before Europe came up with immunity requirements.  Had 
studies been done on typical surges seen at customer sites along with 
developing surge test equipment, we would have done surge testing as 
well even without a regulatory requirement.


What did regulation add? We now have radiated immunity testing at 3V/m, 
but I have never seen a product fail this testing at this low level.  
Instead, this testing is an overhead cost to products that may have 
small changes that would not be impacted by this particular test.  In 
actuality, our company chooses to add radiated immunity test 
requirements at 12V/m level at spot frequencies in wireless bands.  
Again, why do we do this?  Do ensure our products do well at customer 
sites and to maintain our corporate reputation.  However, it is best to 
allow the manufacturer/designer to focus efforts and cost to areas that 
benefit the customer the most ... so costs can be controlled for the 
customer (the customer ultimately pays for development work done on the 
product).


Hate to say it in this discussion list, but most reliability is gained 
by having good functional testing of the code and Beta testing.  We have 
to be careful about how much EMC testing is mandated.  Today, the 
standards committees are going beyond the original intent (reduce 
interference by mandating emissions limits) and now are trying to become 
too scientific about the exact measurement uncertainty and careful 
characterization of the nonconductive table, etc.  All of this is 
occurring even though the number of FCC interference complaints per year 
has dropped to almost non-existent.   Also, I never see any electrical 
fast transient (EFT) failures at the European mandated levels.  We 
already re-use the many of the same power supply designs and filter 
designs for many generations of products. In our case, the EFT test is a 
waste of time for most product releases, but we have to complete the 
record because of a regulatory burden (not just Europe, but now for 
South Korea).   My point is ... don't add unnecessary test cost burden.  
Let the manufacturer focus development and test time on what is of value 
to the customer.


I happen to be involved in the international standards committees 
because the main thing we want is consistency so the same product can be 
sold worldwide.  The ultimate goal should be one standard, one test, one 
mark, and worldwide acceptance.  Personally, I would prefer that FCC 
drop all use of ANSI standards and strictly adopt the international 
emissions standard.  I certainly don't want FCC to add immunity 
requirements.


Please remember that customers are smarter than some in government give 
them credit for.  They know that they get what they pay for. If they 
purchase from a solid known brand, they may pay more but they will get a 
reliable product that will last them for years to come.  However, no one 
in India would want to pay double the price for a printer compared to 
the price the same printer is offered in USA ... but India's government 
that almost mandates in-country testing forces this kind of higher 
pricing in their country. Regulation strikes again.


Research -- yes.
Regulation -- no. (Exceptions may be for a valid safety concern for 
customer or excessive interference potential neighbors.)


Monrad
Note:  All opinions expressed in this e-mail are my own and are not 
necessarily those of any company I work for or have worked for.


On 9/15/2015 1:32 PM, Rodney Davis wrote:


How many big companies survive if their only market is USA.  Pretty 
safe to say almost all major players have a European, and other 
regions of export and hence though not specifically requiring 55024 
most product sold I think would be safe to say meet immunity.



Too expensive to have a fully approved variant and a second variant 
 approved for NA.





*From:* dward 
*Sent:* Tuesday, September 15, 2015 2:37 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] RF Common Mode Immunity Test Question

As a US citizen my premise on any government involvement is to make it 
as impossible or as hard for them to regulate anything as can be. This 
includes EMC, immunity or any other thing.  Too many fall under the 
idea that personal safety outweighs personal freedom.  That may work 
in a socialist type environment, but not in here.


Dennis Ward

This communication and its attachements contain information from 
PCTEST Engineering Laboratory, Inc., and is intended for the exclusive 
use of the recipient(s) named above.  It may contain information that 
is 

[PSES] Job Opening for EMC Compliance Engineer at Oracle (Bay Area in California)

[Monrad Monsen]

Hello!
Oracle has posted a job opening for an EMC Compliance Engineer - 
150017QP.  Today's preference is for candidates that are able to commute 
to Menlo Park and Santa Clara area in California.


You can view the details of the job posting at the below web site.  
Enter "150017QP" into the requisition number search field.

https://oracle.taleo.net/careersection/2/jobsearch.ftl?lang=en

Thanks.
--
<http://www.oracle.com> Monrad Monsen | Hardware Technical Compliance 
Strategist
Phone: +13032729612 <tel:+13032729612> | Fax: +13032724867 
<fax:+13032724867>

Oracle HW Technical Compliance Engineering
500 Eldorado Blvd | Broomfield, CO 80021
<http://www.oracle.com/commitment> Oracle is committed to developing 
practices and products that help protect the environment


-

This message is from the IEEE Product Safety Engineering Society emc-pstc discussion 
list. To post a message to the list, send your e-mail to <emc-p...@ieee.org>

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Re: [PSES] 2014/35/EU Requirement for Postal Address

[Monrad Monsen]

Hi Jim,
Regarding the importer name  address labeling, please note that the 
Blue Guide clarifies this in section 3.4 stating or where not possible 
because of the size or physical characteristics of the product or 
because the packaging would need to be opened.  Assuming the 3rd party 
(re-seller, distributor or OEM partner) does not open the box and just 
sells the product as is, the importer name can just apply a label on the 
packaging or within the accompanying documentation.

http://ec.europa.eu/DocsRoom/documents/11502

Disclaimer:  Everything expressed in this e-mail is strictly my own 
opinions and not necessarily those of any company I work for.


Monrad Monsen
http://www.oracle.com
On 8/20/2015 8:51 AM, Jim Hulbert wrote:


To add to the difficulty – the _Importer_ name and address also needs 
to be on the equipment.   So you may need multiple new labels if the 
“manufacturer” and “importer” are different.  Carefully read the 
definitions of each.  The manufacturer isn’t necessarily the actual 
manufacturer, but could the party who’s name/brand appears on the 
product.  The importer is the party who places equipment from outside 
the EU onto the EU market.


*Jim Hulbert*

*From:* peter_kelle...@dell.com [mailto:peter_kelle...@dell.com]
*Sent:* Thursday, August 20, 2015 6:58 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] 2014/35/EU Requirement for Postal Address

*Dell - Internal Use - Confidential *

Nice try!

Take a look at Sec 3.1/page 29 of the new Blue Guide( Version 1.1):

Not possible applies in the context of  the “size or physical 
characteristics of the products”


Also Footnote 85 is relevant.

By the way, this requirement predates 2014/35/EU.

If your product is in the scope of the RoHS Directive (2011/65/EU), 
the name and address on the product requirement has been there for 
several years.


Regards

Peter.

*From:* kevin.mccandl...@schneider-electric.com 
mailto:kevin.mccandl...@schneider-electric.com 
[mailto:kevin.mccandl...@schneider-electric.com]

*Sent:* 19 August 2015 23:27
*To:* EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] 2014/35/EU Requirement for Postal Address

Hello Experts,

I am looking for some clarification/understanding of the new postal 
address requirement in the LVD 2014/35/EU.


Article 6 section 6 states:  Manufacturers shall indicate on the 
electrical equipment their name, registered trade name or registered 
trade mark and the *postal address* at which they can be contracted 
or, where that is not possible, on its packaging or in a document 
accompanying the electrical equipment. This is a new requirement and 
is causing a panic if we have to change 100’s of product labels and 
/or placards.


It has been my view that the postal address on the DoC is the “single 
point at which the manufacturer can be contacted.”


Also, the new LVD reads as if there may be multiple addresses required 
on the product or packaging by the time the product gets to the 
end-user (manufacturer, importer and possibly others).


Here’s my shameless attempt to find a loop-hole…who determines what 
satisfies the “or, where that is not possible,” clause?


What if the current labeling cannot grow? Or our product management 
group refuses to allow the aesthetics of the product to get cluttered 
with another label (closer to the truth)?


If the postal address can be shipped with the product, either in an 
installation instruction or on the DoC, this would be a much more 
palatable option as opposed to label changes.


Any words of wisdom (relating to this topic) would be greatly appreciated.

Best regards,

___

*Kevin McCandless*  | *Schneider Electric*  | *Partner Business *  | 
*Regulatory Engineer - Hardware*



*** Please consider the environment before printing this e-mail

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Attachments are not permitted but the IEEE PSES Online Communities 
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Re: [PSES] EMC requirements for Korea

[Monrad Monsen]

Hi Rob,
You really have to clarify in your question the types of products you 
plan to sell in South Korea and the location from where you are applying.


For information technology products developed in USA, the process for 
obtaining Korea MSIP approval is relatively easy.  Most accredited USA 
test labs are listed as Conformity Assessment Bodies (CABs) with South 
Korea under the Asia Pacific Economic Cooperation (APEC) Mutual 
Recognition Arrangement for Conformity Assessment of Telecommunications 
Equipment (APEC Tel MRA) signed 8 May 1998.  As a result, we just test 
the product once within USA and the report is accepted in South Korea.  
Of course, the Korea standard KN22 (Emissions) and KN24 (Immunity) needs 
to be cited in the report and the Korea grid power must be used 
(220VAC/60Hz).  They do require extensive pictures of components within 
the application, and you must work through a lab within South Korea to 
process the application and obtain the needed Korea MSIP approval.


I don't know if Europe has an existing MRA with South Korea.  If not, 
then you may need to ship a sample to South Korea for testing.   That 
would be painful.


Some in this thread expanded the discussion to Japan VCCI.  That process 
is also very easy for information technology equipment due to the 
US-Japan MRA so US test labs can receive VCCI registration numbers and 
then issue test reports acceptable for VCCI approvals. The approval 
process is automated online and near instantaneous.


Brian Ceresney indicates that the process may be more difficult for 
industrial battery chargers in both countries.


Hope this helps.

Disclaimer:  All opinions expressed are completely my own and are not 
necessarily those of any company for which I work.


Monrad Monsen
On 8/20/2015 9:19 AM, Robert Dunkerley wrote:


Hi,

Has anyone had experience of the EMC requirements for selling goods to 
South Korea?


There is conflicting information online on what is actually required.  
I always thought if you had CE and FCC covered, that would pretty much 
cover you for most of the world?


Thanks

Rob.


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Re: [PSES] EMC and Data Center

[Monrad Monsen]

Hi Eugene,
I'll take a stab at answering your questions.
 Should I test just one rack of a type on the turn table for RE?
 How many racks should be tested together for CE? Or just one?
I test the worst-case maximum configuration that can be mounted in a 
single 19-inch rack.  FCC would refer to this as a composite system 
[47CFR15.31(k) in 
http://www.gpo.gov/fdsys/pkg/CFR-2014-title47-vol1/pdf/CFR-2014-title47-vol1-sec15-31.pdf]. 
While FCC talks about composite systems having separate enclosures 
connected by wire, I do not believe one needs to extend that to 
everything in an IS shop (or everything in the world) that is connected 
by wire.  Hence, I stop at a more reasonable place of a single 19-inch 
rack.  Generally, a single rack would have a couple of servers, couple 
of disk arrays, a couple of Ethernet and/or Fibre Channel switches, and 
the rest of the rack filled with disk arrays.


 What standards are to be applicable for this situation? FCC?
 Bellcore GR-1089? Both? More?
Only FCC has the force of law, so this is the only one that is 
mandatory.   However, your e-mail indicates that you intend to sell to 
telephone companies in USA, and some telephone company customers will 
only buy products that are NEBS compliant (GR-1089).  NEBS would be a 
marketing requirement, not a regulatory requirement. Please note that 
you can sell non-NEBS verified products to telephone companies (even 
ATT and Verizon) if they plan to use it in their IS shop away from 
their telecommunications network control facilities, but you will be a 
step ahead of the competition if you did go ahead and get NEBS for those 
customers.


Be forewarned that you need to check on a lab's accreditation to confirm 
they can test for NEBS, and some telephone companies also require the 
Verizon accreditation for the test labs with Verizon's extra 
requirements.  Complying with NEBS will add cost to your products both 
in the testing and in the design.  Again, this is a marketing decision.


Ed Price adds an interesting discussion about treating the entire data 
center as a single product.  I don't think this is practical from from a 
sales perspective because it would require doing on-site emissions 
testing every time the data center changes (installs extra equipment).


Hope this helps.

Monrad Monsen
Disclaimer:  Everything expressed in this e-mail are strictly my own 
opinions and are not necessarily those of any employer I work for.

http://www.oracle.com
On 5/14/2015 1:42 AM, Ed Price wrote:


*I’m not an expert on this, but here’s a starter. Shouldn’t a data 
center be within an RF shielded enclosure, with power and signal ports 
bandwidth limited by filters and couplers? (Wouldn’t the data I/O be 
fiberoptic?) A moderate enclosure should give you 80dB isolation from 
the environment, and physical isolation will add to that. You could 
consider the whole enclosure as one device.*


**

*For RE, standing just outside the enclosure, I doubt you could even 
prove the data center internal systems were working. I’ll let others 
add/correct this, but to me, a data center looks like a factory in a 
box, with its own dedicated power feed (not shared by residential or 
light industrial users) and can be treated as Part 18 ISM.*


**

*I don’t know what your client expects of you, but I think they should 
be concerned with self-compatibility of the various subsystems 
installed within that shielded volume. Will each rack of processors or 
routers have its own UPS? What interactions will happen with multiple 
UPS’s connected in parallel, and what will be the RE environment among 
those racks? And if this equipment is all USA origin, what further 
assurances of RS can the vendors provide?*


**

*/Ed Price
/**WB6WSN
**Chula Vista, CA USA**//*

**

*From:*Eugene Peyzner [mailto:epeyz...@sbcglobal.net]
*Sent:* Wednesday, May 13, 2015 8:56 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] EMC and Data Center

Dear experts,

Could you please share your knowledge about a philosophical or logical 
approach to EMC testing of a data center.  To simplify my question 
let’s talk about just EMI testing for USA.


Adata center contains computer systems and associated components, such 
as telecommunications 
https://en.wikipedia.org/wiki/Telecommunication and storage systems 
https://en.wikipedia.org/wiki/Computer_data_storage, air 
conditioning, fire suppression and various security devices. Servers 
are mounted in19 inch rack 
https://en.wikipedia.org/wiki/19_inch_rack cabinets. Some equipment 
such as mainframe computers 
https://en.wikipedia.org/wiki/Mainframe_computer and storage 
https://en.wikipedia.org/wiki/Computer_storage devices are often as 
big as the racks themselves, and are placed alongside them.


Should I test just one rack of a type on the turn table for RE? How 
many racks should be tested together for CE? Or just one?


What standards are to be applicable for this situation? FCC? Bellcore 
GR-1089? Both? More?


Thank you

Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low Voltage Directive 2014/35/EU

[Monrad Monsen]

Hi Charlie,
You made an interesting statement.  You said I don’t have it formally, 
but you can’t legally declare compliance with something that is not in 
force at the time you sign it. You made a mistake by including the 
statement is in force.  We do have a formal published Europa statement 
in both the EMC Directive 2014/30/EU and the Low Voltage Directive 
2014/35/EU that: This directive *_shall_* enter into force on the 
twentieth day following that of its publication in the Official Journal 
of the European Union. (Emphasis on shall is mine.)  Both were 
published in the Official Journal on 29 March 2014, so both are in force 
as of 18 April 2014.  Europe wisely gave manufacturers two years to 
transition to the new directives, so products may continue to be sold in 
Europe with CE marks that only comply with the old directives until 20 
April 2016, but on 20 April 2016 the new directives become mandatory.


As we have seen on this chat group, you are not alone in your view. Some 
people I highly respect (that group includes you) share your view.  They 
believe that Europe will only allow products having a DOC listing only 
the old directives until 11:59pm, 19 April 2016; then someone from each 
company must immediately sign new DOCs to maintain the product CE marks 
at precisely midnight (or 12:00am) on 20 April 2016 (Wednesday).  What 
is not clear is which time zone should be used for signing this DOC, or 
if one must keep re-signing a DOC again each hour of the European time 
zones.  I make this point because USA manufacturers may be eight hours 
behind Europe and miss a whole day of imports and sales in Europe if we 
were to just use the date  time of the manufacturer's time zone (the 
one signing the DOC).  Because this is so unreasonable, one person 
stated on this PSES chat that they had a private conversation with an 
unnamed official that said that UK won't enforce the Europe laws (the 
new directives) for the first year to provide an unofficial transition 
period ... but that same official would not put that into writing. 
Instead, I believe it makes more sense for Europe to implement what is 
actually written in the directives which already provides a reasonable 
two year transition period between the new directives going into force 
(18 April 2014) and the old directives being repealed (20 April 2016).


Let me open up an additional debate issue.  For the transition, I 
recommend declaring to both the old and the new directives.  These 
directives are compatible (no conflicts), so your product can comply 
with both.  I suggest DOC wording similar to what is listed below:

- - - - - - - - - - -
This product complies with the requirements of the European Union 
directives listed below:

 2014/35/EU (2006/95/EC)  Low Voltage Directive
 2014/30/EU (2004/108/EC) EMC Directive
 2011/65/EU (2002/95/EC)  Restriction of Hazardous Substances (RoHS) 
Directive

- - - - - - - - - - -

I have heard some say that one may not cite both old  new directives on 
the same DOC, but I have never seen anything official from Europa that 
prohibits this.


Thanks.
Monrad
http://www.oracle.com
On 3/24/2015 7:44 AM, Charlie Blackham wrote:


Monrad

I should have just put the *shall apply from 20 April 2016*into bold, 
and not just the Annex.


 Please provide an official European Union (EU) document that confirms 
that Declarations against these new Directives cannot be issued until 
20 April 2016 as they have no legal standing until then.


I don’t have it formally, but you can’t legally declare compliance 
with something that is not in force at the time you sign it and 
http://ec.europa.eu/growth/sectors/electrical-engineering/directives/index_en.htm 
states


*New LVD Directive 2014/35/EU*

As of 20 April 2016, Directive 2006/95/EC will be repealed by the new 
LVD Directive 2014/35/EU. This directive is aligned to the New 
Legislative Framework policy. Nevertheless, Directive 2014/35/EU will 
keep the same scope and safety objectives as Directive 2006/95/EC.


And

*New EMC Directive (2014/30/EU)*

In February 2014, the European Parliament and Council issued a new EMC 
Directive  aligned to the New Legislative Framework. This new 
Directive will be applicable from 20 April 2016.


The new Directives have an article on “repeal” of the old directive – 
a similar clause is contained in 2011/65/EU which came into force in a 
“planned way” on 2^nd January 2013


Additionally, Lists of Harmonised Standards will not be published 
until close to the date in April, and whilst they’re not mandatory, 
without them there can be no “presumption of conformity”


The main changes are to economic operators in the supply chain, and 
not to manufacturers, unless their products fall into scope of the 
Radio Equipment Directive and so move out of scope of EMC/LVD a little 
bit late in June 2016.


Regards

Charlie

*From:*Monrad Monsen [mailto:monrad.mon...@oracle.com]
*Sent:* 23 March 2015 22:31
*To:* Charlie Blackham
*Cc

Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low Voltage Directive 2014/35/EU

[Monrad Monsen]

Hi John,
Where is it written that Directives aren't valid until ALL member 
states have implemented them?


_*ENTER INTO FORCE*_
I note that both the Low Voltage Directive and the EMC Directive clearly 
states:  This directive _*shall*_ enter into force on the twentieth day 
following that of its publication in the Official Journal of the 
European Union. (Emphasis on shall is mine.)  See the citations below:


 * Article 45 of the EMC Directive 2014/30/EU that was published in the
   Official Journal on 29 March 2014.  Accordingly, the EMC Directive
   2014/30/EU entered into force on 18 April 2014. Please also note
   that Article 45 does not list Article 15 (EU declaration of
   conformity) as one of the articles that has a delayed application.
 * Article 28 of the Low Voltage Directive 2014/35/EU that was
   published in the Official Journal on 29 March 2014. Accordingly, the
   Low Voltage Directive 2014/35/EU entered into force on 18 April
   2014.  Please also note that Article 28 does not list Article 15 (EU
   declaration of conformity) as one of the articles that has a delayed
   application.

http://www.oracle.com As written, it appears that the new directives 
are entered into force and can be used on declarations of conformity 
(DOCs).


_*REPEAL*_
Similarly, both directives state the older directives (2004/108/EC and 
2006/95/EC) are repealed with effect from 20 April 2016, without 
prejudice to the obligations of the Member States relating to the time 
limits for transposition into national law and the dates of application 
set out in the new directives (2014/30/EU and 2014/35/EU).  As a 
result, any products that still relies on the old directives for CE 
compliance may not be imported and sold after 20 April 2016.


Fortunately, both new directives do state that any references to the 
repealed Directive shall be construed as references to this [new] 
Directive and shall be read in accordance with the correlation table 
given in the new Directive.  As a result, as long as the product still 
complies with the new directive and just has documentation making 
outdated references to the old directive.


So ... if you are correct that EU directives are aren't valid until ALL 
member states have implemented them, I would like to know the official 
document that contradicts the EU directives themselves.


Thanks.
Monrad

On 3/2/2015 12:50 PM, John Woodgate wrote:
In message 000f424e.486384b410ff5...@rpqconsulting.com, dated Mon, 2 
Mar 2015, Ron Pickard (RPQ) rpick...@rpqconsulting.com writes:


As I believe as Mr. Woodgate pointed out earlier, these new 
directives have no legal standing until at least one member state 
enacts them into their own legal system. To my knowledge, that hasn't 
happened yet. Anyone have any info on this?


There has been a new ruling on this from the Commission. One 
implementation is NOT ENOUGH: the Directives aren't valid until ALL 
member states have implemented them.


I suppose this is because a member state could find a serious 
objection to implementation, which would put everything back in the 
melting pot.



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Re: [PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low Voltage Directive 2014/35/EU

[Monrad Monsen]

Hi Charlie,
Please note that Annex I for both Directives lists the essential 
requirements.  Annex I makes no mention of declarations of conformity 
(DOCs).  Again, the article addressing DOCs in each directive has not 
been identified with a delayed application.  Also, there is no essential 
requirement in the old directives that are contradicted in the new 
directives.  Hence, a product declared compliant to the new directives 
is automatically compliant with the old soon-to-be-repealed directives.


By the way, updates to the essential requirements are minor and actually 
provide more information.


 * EMC Directive 2014/30/EU Annex I reduces the description of fixed
   installation requirements to the first sentence of what was in the
   old Directive 2004/108/EC Annex I section 2:  A fixed installation
   shall be installed applying good engineering practices and
   respecting the information on the intended use of its components,
   with a view to meeting the essential requirements set out in point
   1.  The old Directive 2004/108/EC Annex I section 2 also adds
   Those good engineering practices shall be documented and the
   documentation shall be held by the person(s) responsible at the
   disposal of the relevant national authorities for inspection
   purposes for as long as the fixed installation is in operation. 
   This is really not appropriate to be listed as an EMC essential

   requirement.  The new EMC Directive 2014/30/EU correctly moves this
   statement to the last paragraph of Article 19 section 1 because
   Article 19 is a whole article discussing the requirements unique to
   fixed installations.  Please note that other electrical equipment
   that are not fixed installations also have records retention
   requirements, and those records retention requirements were never
   listed in the essential requirements.
 * Low Voltage Directive 2014/30/EU Annex I removes from the essential
   requirements one requirement that was in the old Directive
   2006/95/EC Annex I section 1(c):  The brand name or the trade mark
   should be clearly printed on the electrical equipment or, where that
   is not possible, on the packaging. However, the new Low Voltage
   Directive 2014/30/EU still addresses this requirement but places
   this requirement in Article 6 section 6:  Manufacturers shall
   indicate on the electrical equipment their name, registered trade
   name or registered trade mark and the postal address at which they
   can be contracted or, where that is not possible, on its packaging
   or in a document accompanying the electrical equipment.


Again, if you comply with the new directives of 2014, then you also 
comply with the old soon-to-be-repealed directives.


Please provide an official European Union (EU) document that confirms 
that Declarations against these new Directives cannot be issued until 
20 April 2016 as they have no legal standing until then.


Monrad
Note:  All opinions written above are my own and are not necessarily 
those of any company I work for.

http://www.oracle.com
On 3/23/2015 3:50 PM, Charlie Blackham wrote:


Monrad

These directives cannot be used at the moment – the relevant detail is 
at the end of the quoted articles (with my bold text)


/2014/30/EU Article 46 /

*Entry into force and application *

This Directive shall enter into force on the twentieth day following 
that of its publication in the /Official Journal of the European 
Union/.EN 29.3.2014 Official Journal of the European Union L 96/95


Article 1, Article 2, points (1) to (8) of Article 3(1), Article 3(2), 
Article 5(2) and (3), Article 6, Article 13, Article 19(3) *and Annex 
I shall apply from 20 April 2016.*


//

2014/35/EU /Article 28 /

*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/.


Article 1, the second paragraph of Article 3, Article 5, Article 13(2) 
and (3) *and Annexes I, V and VI shall apply from 20 April 2016*.


Declarations against these new Directives cannot be issued until 20 
April 2016 as they have no legal standing until then


Regards

Charlie

*From:*Monrad Monsen [mailto:monrad.mon...@oracle.com]
*Sent:* 23 March 2015 21:25
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] Harmonised Standards for EMC Directive 
2014/30/EU and Low Voltage Directive 2014/35/EU


Hi John,
Where is it written that Directives aren't valid until ALL member 
states have implemented them?


*_ENTER INTO FORCE_*
I note that both the Low Voltage Directive and the EMC Directive 
clearly states:  This directive *_shall_* enter into force on the 
twentieth day following that of its publication in the Official 
Journal of the European Union. (Emphasis on shall is mine.)  See 
the citations below:


  * Article 45 of the EMC Directive 2014/30/EU that was published in
the Official Journal on 29 March 2014. Accordingly, the EMC
Directive 2014/30/EU entered

[PSES] Harmonised Standards for EMC Directive 2014/30/EU and Low Voltage Directive 2014/35/EU

[Monrad Monsen]

Does anyone have a link to the latest list of harmonized standards for 
the EMC Directive 2014/30/EU and Low Voltage Directive 2014/35/EU?


The Europa web page I use to find the link for the latest listing of 
harmonized standards does not even list the latest revision directives. 
(http://www.newapproach.org/Directives/DirectiveList.asp)  While the 
earlier revision directives are not repealed until 20 April 2016, these 
new directives published in 2014 have already entered into force and 
application.


The latest harmonized standard listings I can find are below:

 * 16 May 2014 for Low Voltage Directive 2006/95/EC:
   
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=uriserv:OJ.C_.2014.149.01.0033.01.ENG
   (Does not list EN62368-1 which was published August 2014.)
 * 16 January 2015 for EMC Directive 2004/108/EC:
   
http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=uriserv:OJ.C_.2015.014.01.0001.01.ENG


Thanks.

http://www.oracle.com Monrad Monsen | Worldwide Compliance Officer
Phone: +13032729612 tel:+13032729612 | Fax: +13032724867 
fax:+13032724867

Oracle Compliance Engineering
500 Eldorado Blvd | Broomfield, CO 80021
http://www.oracle.com/commitment Oracle is committed to developing 
practices and products that help protect the environment




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Re: [PSES] Made in labelling in the EU

[Monrad Monsen]

Interesting.  I am concerned about adding more country of origin (COO) 
laws and rules that apply only to a certain geography.  There are too 
many ways that such COO laws will conflict.  One of the difficulties 
already is that each component will have a COO marked plus the fully 
assembled system will have a COO.  However, it might not be clear which 
COO marking is for the component and which is for the fully assembled 
system.


Even worse, a computer might be assembled with power supply, fans and 
motherboard in one country ... but then receive the customization for an 
individual customer of a specific speed CPU, memory DIMMs and hard disk 
drive at another country before being shipped to the final customer.  I 
am not a COO subject matter expert, but I am told that the COO could 
change from the first country to the second country (that added the CPU, 
DIMMs  HDD) if the value of the product changed more than 40% 
(requirement of some customer countries) or the capability of the 
product changed (certainly the product couldn't function without a 
CPU).  Hence, what used to be the COO from the first country would then 
be updated with a new COO at the 2nd country.  Stretching this 
hypothetical example further, this computer could be shipped to a 
value-added reseller that adds software, cards and other features to 
make the computer's purpose more focused on medical or telecom uses 
which may change the system's COO yet again.


I like the ISO graphical symbol for COO that is suggested in this chain 
of discussion.

https://www.iso.org/obp/ui/#iec:grs:60417:0:6049

However, I am concerned that this graphical symbol will be seen 
everywhere on the product and the customer really won't know any more 
information than if COO was not on the product in the first place.  I 
agree with Brian that COO really doesn't matter for the safety of our 
customers.  Instead, they need to know the brand name manufacturer and 
contact information since that brand name manufacturer takes 
responsibility for the design and safety/EMC compliance of the product.


Monrad

Note: /The statements and opinions expressed here are my own and do not 
necessarily represent those of any company I work for/.


On 10/3/2014 12:42 PM, Mike Sherman - Original Message - wrote:

Good summary of what I know is here:
http://www.lexology.com/library/detail.aspx?g=ff7bd38f-0f81-4e5f-94c7-a16d3d05368d


*From: *Scott Xe scott...@gmail.com
*To: *EMC-PSTC EMC-PSTC@LISTSERV.IEEE.ORG
*Sent: *Friday, October 3, 2014 11:27:33 AM
*Subject: *[PSES] Made in labelling in the EU

I have learnt that EP is working on a new law of origin marking 
proposed by consumer product safety and market surveillance and going 
to be in force next year.  There should not be no direct relationship 
with product safety but may improve the traceability of products. 
 Does anyone know when the new law become available?


Thanks and regards,

Scott



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Jim Bacher:  j.bac...@ieee.org
David Heald: dhe...@gmail.com

Re: [PSES] RF immunity from mobile phones

[Monrad Monsen]

Hi John,
You can be the last word on the efficiency of the CISPR standards 
development procedures.  As I am a pusher for action, I generally make 
optimistic estimates in hopes that others will join me in the urgency 
resulting in faster action.  There is a move to take out the 
controversial portions of the standard so the rest of CISPR35 can easily 
pass. (Even the current failed CISPR35/FDIS passed CENELEC which 
resulted in EN50635.)  The controversial portions will be addressed in 
the working group to be voted on later in some form as future amendments.


Monrad

Note: /The statements and opinions expressed here are my own and do not 
necessarily represent those of any company I work for/.

http://www.oracle.com
On 10/3/2014 1:04 AM, John Woodgate wrote:
In message 542dd9be.2090...@oracle.com, dated Thu, 2 Oct 2014, 
Monrad Monsen monrad.mon...@oracle.com writes:


CISPR and CISPR/I is meeting in Frankfurt during the week of October 
20th, and they will figure out a path forward to get CISPR35 approved 
quickly (I'm guessing 6 months)


That would mean scrapping all the voting procedures. CISPR 35 is now a 
New Work item and must go through the CD, CDV and FDIS stages with 
normal timings. It's not sensible to imagine that a 
highly-controversial standard can be processed far more quickly than a 
bland one.



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Re: [PSES] RF immunity from mobile phones

[Monrad Monsen]

Hi Amund,
The Europe the GSM frequencies for Europe are 900 MHz and 1800MHz bands.

The test requirement you are looking for has been incorporated into 
CISPR35 drafts will eventually be adopted into EN55035.  The 
CISPR35/FDIS includes a requirement for spot testing both 900 MHz and 
1800 MHz.  CISPR35 did not get approved in the most recent vote, but the 
issues raised did not impact these spot frequencies.  Instead, there are 
some debates about the levels required for radiated immunity at these 
spot frequencies for equipment marketed for use in telecommunications 
centers or central offices (30 V/m).  As long as the PC monitor does not 
have a network function that is intended for use in this environment, 
then the manufacturer can decide what protection distance the product 
must be immune to radiated immunity frequencies with 3 V/m for 3 meter 
protection distance being the easiest level to achieve.  The harsh 30 
V/m level is for the protection distance of 20 centimeters.  Personally, 
I encourage use of the half meter protection distance which requires 
being immune to 12 V/m.   All of this will be made clear when the 
CISPR35 is finally passes and the standard is published.  If desired, 
you can get a look at the proposed radiated immunity requirements by 
looking at Europe's non-harmonized standard EN50635 today.


CISPR and CISPR/I is meeting in Frankfurt during the week of October 
20th, and they will figure out a path forward to get CISPR35 approved 
quickly (I'm guessing 6 months).  Europe will likely publish EN55035 
about 3-6 months after that.  The bottom line is that the immunity test 
requirements you are looking for are coming soon


Monrad

Note: /The statements and opinions expressed here are my own and do not 
necessarily represent those of any company I work for/.

http://www.oracle.com
On 9/30/2014 5:41 AM, Amund Westin wrote:

Concerning CE marking of PC monitors ... shall they be immune to GSM mobile 
phones?
I can't find any GSM mobile phones test requirements under EU harmonised 
standards. I recall there was a standard (ENV50204) a long time ago, under the 
Generic standards. That one is not with us anymore.

Have I missed a point?

#Amund





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Re: [PSES] Failure of Radiated emission

[Monrad Monsen]

Hi Chaz,
Regarding variability between tests and test sites, you wrote:
 there is one technique (that has fallen out of favor) that can help 
to ameliorate
 some of these concerns and that is cable maximization. Cable 
maximization IS time
 consuming frustrating at times but it will minimize your risks at a 
3rd part location.
I agree.  Especially as one is designing a product, it is important to 
really get to know the product's emissions performance and weaknesses by 
taking some time to manipulate cables.  However, this is only done as a 
part of engineering experimentation.  The final qualification of the 
product to create a test report that can be used for agencies must be 
performed according to the standards.  There are so many rules about 
bundling excess cable at specific heights and draping cables to specific 
heights that there is very little cable manipulation that could be 
possibly be done and still comply with the setup requirements, so the 
standards no longer call for cable manipulation to be done.  The good 
news is that this speeds up the test.


CISPR32 says: The arrangement for formal measurement shall be 
representative of a typical arrangement of the EUT, local AE and 
associated cabling.  Both CISPR32 and ANSI C63.4 give some very 
specific test configuration arrangement requirements with figures.  To 
setup a product correctly (especially a tabletop product) one must have 
a measuring stick or measuring tape on hand.


Have fun!

Monrad

Note: /The statements and opinions expressed here are my own and do not 
necessarily represent those of any company I work for/.


On 9/25/2014 9:54 AM, Grasso, Charles wrote:

Apologies for the late response on this but the concerns raised (market 
surveillance, test methodologies and standards
interpretation) go right to the heart of the compliance engineering function - 
and has been this way for about 30 years!

Kris - the standards piece seems to be pretty well laid out, however you asked 
a key question at the end of your original
email that raised my interest!

You asked:  So to me it looks sufficient to test a typical set-up, do your best to 
not make it best case and describe everything in the report . This statement 
embraces the issue of consistent and accurate  emissions testing because
with that  your concerns of failing due to a 3rd party test would be much 
reduced.

However due to the very nature of the systems level of the test, the 
variabilities  between sites,  measurement
uncertainty (which by itself acknowledges the variability in our test 
equipment!) and manufacturing variances makes
consistent testing challenging.   However there is one technique (that has 
fallen out of favor) that can help
to ameliorate some of these concerns and that is cable maximization.   Cable 
maximization  IS time consuming
frustrating at times but it will minimize your risks at a 3rd part location.


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


-Original Message-
From: Carpentier Kristiaan [mailto:kristiaan.carpent...@technicolor.com]
Sent: Friday, September 05, 2014 8:36 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Failure of Radiated emission

Hi group,

A ITE product is tested to EN55022 Radiated emission with a well defined setup 
(cables, traffic, etc...) trying to find the worst case emissions and it passes.
I think finding the real worst case emission for all frequencies with one and 
the same set-up is in practice not possible in practice.

That same product is retested by a customer or in case of market surveillance 
campaigns, then it is most likely not tested with the same set-up and results 
may fail.
Would this be an issue or is it acceptable that it is retested with the same 
set-up as the initial testing? I refer to CISPR22, clause 8.4 that states that 
the operational conditions of the EUT shall be determined acc. to typical 
use.The operat mode and rationale shall be stated in the report.

So to me it looks sufficient to test a typical set-up, do your best to not make 
it best case and describe everything in the report.

Any other thoughts?

Best regards,
Kris Carpentier

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Re: [PSES] Failure of Radiated emission

[Monrad Monsen]

Hi John,
You wrote such a provision cannot be included in a standard.

Actually, it is in the standard!  In CISPR22:2008, section 9.5.1 (under 
9.5 EUT arrangement) says in the text.


   In case of dispute, tests shall be carried out as originally
   performed.


Europe replaced the sentence with the below information in 
EN55022:2010.  In EN55022:2010 section 9.5.1 (under 9.5 EUT 
arrangement), it says:


   Where this standard gives options for testing particular
   requirements with a choice of test methods, compliance can be shown
   against any of the test methods using the appropriate limit.

   NOTE   In any situation where the equipment is re-tested, the
   test method originally chosen should be used in order to seek
   consistency of the results.


Then both CISPR32:2012 and EN55032:2012 section 10 (Compliance with 
this publication) states:


   Where this publication gives options for testing particular
   requirements with a choice of test
   methods, compliance can be shown against any of the test methods
   using the appropriate
   limit. In any situation where it is necessary to re-test the
   equipment to show compliance with
   this publication, the test method originally chosen shall be used in
   order to guarantee
   consistency of the results, unless it is agreed by the manufacturer
   to do otherwise.


It is clear that a re-test for any situation should be done using the 
EUT arrangement originally chosen assuming the arrangement choice is 
allowed by the emissions standards. Certainly, market surveillance would 
count as an example situation for a re-test, and to do otherwise would 
violate the emissions standards.


Have fun!

Monrad
http://www.oracle.com
On 9/5/2014 2:50 PM, John Woodgate wrote:
In message 
e7baf06cd71c4cc59654ac9ac55e6...@bn1pr0201mb0819.namprd02.prod.outlook.c
om, dated Fri, 5 Sep 2014, Carpentier Kristiaan 
kristiaan.carpent...@technicolor.com writes:


In which document can I find the provision that market surveillance 
testing is done, in case of dispute, in the way the manufacturer did it?


As I explained, such a provision cannot be included in a standard. It 
is extremely difficult to track down where provisions like this are 
documented. I already have one similar query in with the British 
authorities at present and I don't want to seem tiresome by adding 
another query in quick succession.


If I find the source I will let you know.



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Re: [PSES] Crossed-out wheeled bin symbol

[Monrad Monsen]

Hi Scott,
If you look at the Recast WEEE directive 2012/19/EU annex IX, you will 
see that the crossed-out wheeled bin symbol does not have a black bar 
below the symbol.
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:197:0038:0071:EN:PDF 



Note:  If you look at the WEEE directive in a PDF provided by Europa, 
you will see that they put a small thin horizontal line at the end of 
the main directive and at the end of each annex.   For annex IX, the 
crossed-out wheeled bin symbol is at the end of the annex, but the 
symbol uses bold lines.  The later small thin horizontal line marking 
the end of the annex should not be confused as being a part of the 
crossed-out wheeled bin symbol.


Monrad

Note: /The statements and opinions expressed here are my own and do not 
necessarily represent those of any company I work for/.

http://www.oracle.com
On 9/12/2014 9:52 AM, Scott Xe wrote:

Dear All,

I have learnt that in near future, the black bar below the crossed-out 
wheeled bin symbol will be removed similar to the one used in battery 
directive.  Have anyone heard the same?


Thanks and regards,

Scott

On 12 Sep, 2014, at 10:56 pm, Denis Ryskamp denis_rysk...@trimble.com 
mailto:denis_rysk...@trimble.com wrote:



*Gary:*
**
*Needed:*
*1)**A unique identification of the producer*(Brand name, 
registration number,…..)**

*2)**The crossed-out wheeled bin in accordance with Directive*
*3)**Put on market after 13 august 2005 shall be identified by at 
least one of the following:*
*/a)/**/Date of manufacture/put on market, in uncoded text per ISO 
8601 or other coded text, for which the code shall be made available 
for treatment facilities./*
*b)**/Additional mark used in conjunction with the crossed-out 
wheeled bin (underline) The directive has the dimensional 
proportions. Height of the bin itself is 4mm minimum./*
*The crossed out wheeled bin symbol to be displayed in a visible, 
legible and indelible form on the product itself, near Producer ID, 
except for in exceptional cases where this is not possible because of 
the size or function of the product. If the symbol cannot be applied 
to the product due to product size or function, then the marking 
shall be printed on the packaging, in the instructions for use, and 
in the warranty.*
 The directive has the dimensional proportions. Height of the bin 
itself is 4mm minimum.

*From:*Gary McInturff [mailto:gary.mcintu...@esterline.com]
*Sent:*Friday, September 12, 2014 10:30 AM
*To:*EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:*[PSES] Visible - legible
Does anyone have a standards definition of visible – legible? In this 
particular instance it’s for the WEEE symbol for an ITE product. I 
don’t see a reference to the definition here. Anybody else? Is it a 
fixed height say 4mm, or is there some reference to readable from 1 
meter (another non-definition because readable isn’t defined),

*Gary McInturff*
*Reliability/Compliance Engineer*
**
**
**
*Esterline Interface Technologies*

/Featuring/
/ADVANCED INPUT, GAMESMAN,/
/and LRE MEDICAL products/
600 W. Wilbur Avenue
Coeur d’Alene, ID  83815-9496
Toll Free: 800-444-5923 X1XXX
Tel: (208) 635-8
Fax: (208) 635-8
www.esterline.com/interfacetechnologies 
http://www.esterline.com/interfacetechnologies

/Technology, Innovation, Performance…/
Information in or attached to this e-mail message may be subject to 
export control restrictions of the International Traffic in Arms 
Regulations (ITAR) (22 CFR pts. 120-130) or the Export Administration 
Regulations (EAR) (15 CFR pts. 730-774).  Before exporting this 
information outside the United States or releasing it to a foreign 
person in the United States, you need to determine whether a license 
under the EAR or the ITAR is required to do so.  If you have any 
questions about this obligation, please contact me.

//

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This message is from 

Re: [PSES] Failure of Radiated emission

[Monrad Monsen]

Hi John,
EN55032:2012 is the latest word on the intent of the emissions 
standards.  The presumption of conformity is only maintained for after 5 
March 2017 if they use EN55032:2012.  Evidently, the debate and intent 
of the standards bodies was to give freedom to the manufacturer but not 
to other parties.  Specifically, I note that the quoted statement in 
EN55032:2012 section 10 gives freedom to the manufacturer to use another 
test method or configuration, but all other parties (including EU member 
state governments) would be bound to the shall statement to use the 
test method originally chosen ... unless it is agreed by the 
manufacturer to do otherwise.


One never knows what a government official will do, and rarely is it 
worth the expense for a corporation to appeal through the courts. 
However, they should run their market surveillance tests according to 
the standards.


Have fun!

Monrad

Note: /The statements and opinions expressed here are my own and do not 
necessarily represent those of any company I work for/.

http://www.oracle.com
On 9/24/2014 11:45 AM, John Woodgate wrote:
In message 5422fdfd.2070...@oracle.com, dated Wed, 24 Sep 2014, 
Monrad Monsen monrad.mon...@oracle.com writes:



You wrote such a provision cannot be included in a standard.

Actually, it is in the standard!  In CISPR22:2008, section 9.5.1 
(under 9.5 EUT arrangement) says in the text.

In case of dispute, tests shall be carried out as originally performed.


I know, but that was not legally acceptable in Europe, hence the 'work 
around' that you have quoted in the 2010 edition. 'Should' means 'not 
mandatory', so the surveillance authorities are not bound by it. And 
even the 2010 edition wording is not without allegations of being 
'regulatory'.


I am therefore very surprised that EN 55032 has the 'shall' word. I 
quite agree that it is completely sensible, but that doesn't count for 
much in certain circles.



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Re: [PSES] EN55032 and the Digital Television/Monitor Reference Test Pattern of ITU-R BT.1729

[monrad monsen]

Hi!
Unfortunately, Tom Sato's software does not fully comply with ITU-R 
BT.1729.  The big discrepancy is listed below:
 ** ZONE 12 MOVING BAR:  Page 6 of the standard states that Zone 12 
contains a bar which moves horizontally from left to right and then 
starts again from the left. This is used for checking audio-video 
synchronization and to establish that the channel is active. The bar 
travels horizontally across its zone in 1 s. The audio sync signal is 
given when the bar passes the centreline.  (Page 6 or PDF page 8) There 
is more description to the zone 12 in the standard, but the above quote 
is sufficient to show that Tom's bar does not conform.  Zone 12 is the 
second row from the bottom in the circle portion of the screen.  (Page 3 
or PDF page 5)


The ITU-R BT.1729 standard is at the address below.
http://www.itu.int/dms_pubrec/itu-r/rec/bt/R-REC-BT.1729-0-200504-I!!PDF-E.pdf

I like Tom's application because it works on Java enabled web browsers, 
but Tom has no intention of fixing the Zone 12 moving bar.   As a 
result, I am not able to use his application.  I note that there is also 
nothing in the standard that allows use of a bouncing ball, but I like 
the feature and one could argue that this might catch some problems 
missed without it.


Does anyone have a software recommendation that fully implements the 
ITU-R BT.1729 as is required for CISPR32 / EN55032 emissions testing?


Monrad

On 6/6/2014 1:08 PM, Ted Eckert wrote:

Here is the link to Tom Sato's site.
http://homepage3.nifty.com/tsato/scrolling-h/colorbar.html


This email message and attachments may contain confidential and proprietary 
information.  Any unauthorized use is prohibited.  If you are not the intended 
recipient, please contact the sender by reply email and destroy all copies of 
the original message and attachments.

-Original Message-
From: Brian Oconnell [mailto:oconne...@tamuracorp.com]
Sent: Friday, June 6, 2014 12:02 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN55032 and the Digital Television/Monitor Reference Test 
Pattern of ITU-R BT.1729

Mr. Tom Sato has some of the bouncing ball stuff source published on his web 
site.

And have seen other sites with 1729 stuff.

Brian


From: monrad monsen [mailto:monrad.mon...@oracle.com]
Sent: Friday, June 06, 2014 10:33 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EN55032 and the Digital Television/Monitor Reference Test 
Pattern of ITU-R BT.1729

Hi!
For EN55032:2012, stand alone monitors must be emissions tested with a standard 
television colour bar signal according to ITU-R BT 1729 with an additional small moving 
element.  This signal is defined in  ITU-R BT.1729 which gives a digital television 
reference test pattern.  Does anyone have a source for a software routine that puts out 
the reference test pattern?

Ideally, I would like the reference test pattern software with compiled 
executable files to support testing with each of the major operating systems 
like Windows, Solaris,  and Linux.

Thanks.

Monrad Monsen

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-

This message is from the IEEE Product Safety Engineering Society

[PSES] EN55032 and the Digital Television/Monitor Reference Test Pattern of ITU-R BT.1729

[monrad monsen]

Hi!
For EN55032:2012, stand alone monitors must be emissions tested with a 
standard television colour bar signal according to ITU-R BT 1729 with 
an additional small moving element.  This signal is defined in ITU-R 
BT.1729 
http://www.itu.int/dms_pubrec/itu-r/rec/bt/R-REC-BT.1729-0-200504-I%21%21PDF-E.pdfwhich 
gives a digital television reference test pattern.  Does anyone have a 
source for a software routine that puts out the reference test pattern?


Ideally, I would like the reference test pattern software with compiled 
executable files to support testing with each of the major operating 
systems like Windows, Solaris,  and Linux.


Thanks.

Monrad Monsen


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Re: [PSES] CISPR 32, colour bar with moving element (ITU-R BT.1729)

[monrad monsen]

Hi Tom,
I just found your posting of the ITU-R BT.1729 colour bar test pattern.  
This is great!


Does this fully implement the ITU-R BT.1729 colour bar test pattern?
 ** BOUNCING BALL:  I couldn't find anything in the standard that 
mentions a bouncing ball, but I like the feature and one could argue 
that this might catch some problems missed without it.
 ** ZONE 12 MOVING BAR:  Page 6 of the standard states that Zone 12 
contains a bar which moves horizontally from
left to right and then starts again from the left. This is used for 
checking audio-video synchronization and to establish that the channel 
is active. The bar travels horizontally across its zone in 1 s. The 
audio sync signal is given when the bar passes the centreline. There is 
more description to the zone 12 in the standard, but the above quote is 
sufficient to say that I don't see anything moving in zone 12 of your 
application.


Do you have plans to fix the zone 12?

I am definitely looking for something I can use to test monitors for 
CISPR32 using the ITU-R BT.1729 colour bar test pattern.


For all, the ITU-R BT.1729 standard is available online for free at:
http://www.itu.int/dms_pubrec/itu-r/rec/bt/R-REC-BT.1729-0-200504-I!!PDF-E.pdf 



Thanks.

Monrad
http://www.oracle.com
On 4/5/2014 1:51 AM, T.Sato wrote:

Hello,

We used to use scrolling-Hs test pattern for CISPR 22 and ANSI C63.4,
but CISPR 32 requires ITU-R BT.1729 colour bar with small moving element
for computer displays and similar devices.

Now, I made web pages which will display the test pattern on web browsers.

If you are interested, please try it, at:

http://homepage3.nifty.com/tsato/scrolling-h/colorbar.html

Regards,
Tom




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[PSES] Language Translations for EU Declarations of Conformity (DOCs)

[Monrad Monsen]

RoHS Directive 2011/65/EU, Article 13 (EU Declaration of Conformity) 
section 2 states:  The EU declaration of conformity ... shall be 
translated into the language or languages required by the Member State 
on the market of which the product is placed or made available.


This raises some questions:
1.  What languages are required by the member states for translating 
declarations of conformity (DOCs)?


2.  Would English suffice for a DOC?  I would hope that any one language 
within the community would be acceptable for the DOC, and English would 
be the easiest language for American companies to use.


3.  If a member state does want a DOC in a language other than English, 
would they the English version immediately and then allow the 
manufacturer time to translate the DOC like a period of two months?


RoHS Directive 2011/65/EU becomes mandatory on 1 January 2013, so these 
questions are urgent.


Monrad Monsen
+1.303.272.9612

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Re: [PSES] Testing EUT

[Monrad Monsen]

For non-native speakers, please note that the Anthony Thomson statement 
about exorcise and John Woodgate's subsequent comment is purely a joke 
and not to be considered a real answer.


Please do not use Exercision / Exercition at all in your writing for 
English.  It won't be understood.  The words Exercise / Exercising / 
Exercised should be used based on the tense in which the sentence is 
written.


Examples include the below:
We used a PC running DataDriver software (Revision 4.0) to exercise the EUT.
We exercised the EUT using a PC running DataDriver software (Revision 4.0).
DataDriver software (Revision 4.0) running on a support PC exercised all 
modes of the EUT throughout the testing.


Alternate forms using synonyms would be:
The support PC running DataDriver software (Revision 4.0) ran the EUT 
through continuous write/read/compare routines throughout testing.


Please note that I give a lot of leeway for English grammar and spelling 
errors when reviewing reports.  Some mistakes are made by native English 
speakers.  We know what you are trying to express in your reports, so a 
grammar mistake is ignored as long as you do provide the critical 
information (margin from the emissions limits, how was the product setup 
and run during testing, date of test, etc.).


Hope this helps.

Monrad



On 11/1/2012 4:00 AM, John Woodgate wrote:
In message 20121101090042.6...@gmx.com, dated Thu, 1 Nov 2012, 
Anthony Thomson ton...@europe.com writes:


If it is passing, or the test result is yet unknown, you will 
“exercise” the EUT. If it is not passing, then you will need to 
“exorcise” the EUT.


By cutting out any EXOR gates?


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Re: [PSES] CE Marking of Power Cables

[Monrad Monsen]

Patricia,
Great comment!  However, I notice that RoHS 1 (Directive 2002/95/EC) 
does state in article 3 (definitions) paragraph (a) that 'EEE' means 
... equipment for the ... transfer ... of such currents and fields ... 
and designed for use with a voltage rating not exceeding 1000 volts for 
alternating current and 1500 volts for direct current.  Therefore, it 
appears that power cables and electrical communications cables were in 
scope for RoHS 1, but RoHS 1 was not a CE marking directive and did not 
require DOCs.  Instead, RoHS 1 only required that the cables comply with 
not using the hazardous substances in homogenous materials in excess of 
the limits.  The problem is that RoHS 2 now requires CE marking, 
manufacturer name  address, and a DOC.  As a result, the due date seems 
to be 3 January 2013.  (Article 26)


My understanding is that optical fibre cables would be out-of-scope 
(exempt).


Note:  All opinions given in this e-mail are purely my own and do not 
necessarily reflect the positions of any company I work for.


Monrad

On 8/22/2012 4:06 PM, Knudsen, Patricia wrote:


Cables have a transition period for compliance to RoHS recast until 
July 2019, per article 2.2:


“2. Without prejudice to Article 4(3) and 4(4), Member States shall 
provide that EEE that was outside the scope of Directive 2002/95/EC, 
but which would not comply with this Directive, may nevertheless 
continue to be made available on the market until 22 July 2019.”


The U.S. Department of Commerce has a pretty decent FAQ for RoHS Recast:

http://www.ita.doc.gov/td/standards/Markets/Western%20Europe/European%20Union/Webpage%20RoHS%20II%20FAQ%20final.pdf

Patty Knudsen

Product Safety Engineering
17095 Via del Campo

San Diego, CA  92127
858-485-3748

Teradata Labs
patricia.knud...@teradata.com
mailto:patricia.knud...@teradata.com%0bteradata.com 
http://www.teradata.com/


The information contained in this message is private and confidential, 
is the property of Teradata Corporation, and is solely for the use of 
its intended recipient.  If you are not the person to whom this e-mail 
is addressed, or if it has been sent to you in error, please notify 
the sender immediately.  If you are not the intended recipient, please 
note that permission to use, copy, disclose, alter or distribute this 
message, and any attachments, is expressly denied.


Please consider the environment before printing.

*From:*Monrad Monsen [mailto:monrad.mon...@oracle.com]
*Sent:* Tuesday, August 21, 2012 4:50 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] CE Marking of Power Cables

Must power cables imported and sold in Europe have a CE mark and 
manufacturer's name  address starting 3 January 2013 in accordance 
with the recast RoHS Directive 2011/65/EU?  Similarly, must the power 
cable have its own declaration of conformity (DOC)?


It appears that AC power cables shipped in separate boxes would meet 
the definition of EEE in article 3 definition (1) as the AC power 
cable is /equipment for the ... transfer ... of such currents and 
fields and designed for use with a voltage rating not exceeding 1 000 
volts for alternating current/.


For companies that sell worldwide, many ship the power cables alone in 
their own boxes separate from the system products since their products 
are sold worldwide and the correct power cable must be selected for 
each order as applicable for each customer's country.  Usually, the 
power cable is imported in the same shipment as the system, but there 
are other times when the power cable is imported alone either to 
replace a damaged power cable (field replacement unit) or sold to 
support moving a product already in Europe to change plug types 
(different plugs used for moves to other countries within Europe or to 
different power distribution units). Hence, it would appear that power 
cables would need to comply with the European rules individually for 
compliance instead of depending on the system product (like a server) 
for the CE marking.


As a result, it appears that power cables will now require a CE mark, 
be labeled with the manufacturer's name  address, and have its own 
DOC by 3 January 2013.


Note:  All opinions given in this e-mail are purely my own and do not 
necessarily reflect the positions of any company I work for.


Thanks.

Monrad Monsen
+1.303.272.9612



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[PSES] CE Marking of Power Cables

[Monrad Monsen]

Must power cables imported and sold in Europe have a CE mark and 
manufacturer's name  address starting 3 January 2013 in accordance with 
the recast RoHS Directive 2011/65/EU?  Similarly, must the power cable 
have its own declaration of conformity (DOC)?


It appears that AC power cables shipped in separate boxes would meet the 
definition of EEE in article 3 definition (1) as the AC power cable is 
/equipment for the ... transfer ... of such currents and fields and 
designed for use with a voltage rating not exceeding 1 000 volts for 
alternating current/.


For companies that sell worldwide, many ship the power cables alone in 
their own boxes separate from the system products since their products 
are sold worldwide and the correct power cable must be selected for each 
order as applicable for each customer's country.  Usually, the power 
cable is imported in the same shipment as the system, but there are 
other times when the power cable is imported alone either to replace a 
damaged power cable (field replacement unit) or sold to support moving a 
product already in Europe to change plug types (different plugs used for 
moves to other countries within Europe or to different power 
distribution units). Hence, it would appear that power cables would need 
to comply with the European rules individually for compliance instead of 
depending on the system product (like a server) for the CE marking.


As a result, it appears that power cables will now require a CE mark, be 
labeled with the manufacturer's name  address, and have its own DOC by 
3 January 2013.


Note:  All opinions given in this e-mail are purely my own and do not 
necessarily reflect the positions of any company I work for.


Thanks.

Monrad Monsen
+1.303.272.9612


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Re: [PSES] Original Signed Reports Versus Digital Scanned Reports for EMC Technical Files

[Monrad Monsen]

We really don't want to keep the original signed paper even for 10 
years.  As you mention, agencies accept our PDF scanned version 
reports.  Is there any requirement to have original signed paper version 
reports at all once they are scanned to PDF?


Monrad Monsen

On 7/9/2012 5:54 PM, doug...@gmail.com wrote:

Monrad,

I am not aware of any need to save hard copy reports, especially after 
enough time has elapsed. Document retention in the EU for liability 
directive is still 10 years (you might double check that).


Otherwise, I have been doing electronic submittals (of safety reports) 
to my certifiers for more than 10 years. I see no need to subsequently 
print these simply for archival purposes.


Doug

Douglas E Powell
Compliance Engineering and Consulting
http://www.linkedin.com/in/dougp01

*From: * Monrad Monsen monrad.mon...@oracle.com
*Date: *Mon, 9 Jul 2012 17:31:55 -0600
*To: *EMC-PSTC@LISTSERV.IEEE.ORG
*ReplyTo: * Monrad Monsen monrad.mon...@oracle.com
*Subject: *[PSES] Original Signed Reports Versus Digital Scanned 
Reports for EMC Technical Files


We have EMC lab currently files and saves the original signature 
documents for every test report.  However, we retain the electronic 
scan copy version of the reports which are backed up and have disaster 
recovery procedures in place for off-site storage.  We would like to 
stop saving the paper copies and just rely on the electronic scanned 
copy reports.


If we have a scanned electronic copy of the test reports, is there any 
need to have the original signed paper version?  Are there any 
countries or agencies that require us to have the original signed 
paper versions on hand?


Thanks.

Monrad Monsen
+1.303.272.9612 Office

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[PSES] Original Signed Reports Versus Digital Scanned Reports for EMC Technical Files

[Monrad Monsen]

We have EMC lab currently files and saves the original signature 
documents for every test report.  However, we retain the electronic scan 
copy version of the reports which are backed up and have disaster 
recovery procedures in place for off-site storage.  We would like to 
stop saving the paper copies and just rely on the electronic scanned 
copy reports.


If we have a scanned electronic copy of the test reports, is there any 
need to have the original signed paper version?  Are there any countries 
or agencies that require us to have the original signed paper versions 
on hand?


Thanks.

Monrad Monsen
+1.303.272.9612 Office


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Re: [PSES] EMC Standard Listings with /AC in the suffix

[Monrad Monsen]

You are right.  The AC:2011 is a corrigendum.  There appear to be a 
couple of standards that have corrigendums for information technology 
equipment (ITE) family standards.  However, do the manufacturers 
Declarations of Conformity (DOC) need to list the corrigendum?   
Specifically, would the DOC need to list the below listings?

EN55022:2010 + AC:2011
EN60950-1:2006+A11:2009+A1:2010+A12:2011+AC:2011

Also, I notice that there is no date of cessation of presumption of 
conformity of superseded standard in the listing of harmonized 
standards.  Does this mean that both corrigendums are immediately mandatory?


Thanks.

Monrad


On 4/28/2012 8:01 AM, Helge Knudsen wrote:


Hi Rich,

This is just a corrigendum.

You may get it for free if you make a search on the internet, search 
for EN55022:2010/AC:2011.


Best regards

Helge Knudsen

Denmark

*From:*emc-p...@ieee.org [mailto:emc-p...@ieee.org] *On Behalf Of 
*Jones, Richard (Richard)

*Sent:* 28. april 2012 13:08
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* EMC Standard Listings with /AC in the suffix

Hi Everyone

I was looking at the implementation date for EN55022:2010 and noticed 
that there was another line added underneath showing


EN55022:2010/AC:2011 (new)

Is this some sort of amendment, I see there are a number of standards 
with /AC on them . There is no implementation date either


I'm sure there is an obvious answer, but I can't see it yet!

Rich

If it is an amendment what does it contain? Not that I'm cynical Jbut 
I've seen some which you pay serious


money for and they're nothing more than a cover sheet!

*From:*Helge Knudsen [mailto:hknud...@mail.tele.dk]
*Sent:* Wednesday, April 11, 2012 12:59 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] New RTTE and EMC listings

Hi all,

The text should have been:

New lists of harmonized standards cited under the RTTE and the EMC 
directives was issued today 11^th April 2012.


Br

Helge Knudsen

*From:*emc-p...@ieee.org mailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org] *On Behalf Of *Helge Knudsen

*Sent:* 11. april 2012 18:11
*To:* EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* New RTTE EMC listings

Hi all,

New lists of harmonized standards cited under the RTTE EMC directives 
was issued today 11^th April 2012.


See

http://eur-lex.europa.eu/JOHtml.do?uri=OJ%3AC%3A2012%3A104%3ASOM%3AEN%3AHTML

Best regards

Helge Knudsen

Denmark

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Re: [PSES] EMC Standard Listings with /AC in the suffix

[Monrad Monsen]

Do the manufacturers Declarations of Conformity (DOC) need to list the 
corrigendum?


On 4/29/2012 11:38 PM, Steve Leitner wrote:


A corrigendum is typically published to correct an error that was 
inadvertently introduced either in drafting or in printing and which 
could lead to incorrect or unsafe application of a standard.  
Corrigenda are not published to correct errors that would have no 
bearing on application of the standard.


So you could say that it is immediately mandatory.

Steve Leitner

*From:*emc-p...@ieee.org [mailto:emc-p...@ieee.org] *On Behalf Of 
*Monrad Monsen

*Sent:* Sunday, April 29, 2012 9:50 PM
*To:* Helge Knudsen
*Cc:* 'Jones, Richard (Richard)'; EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: EMC Standard Listings with /AC in the suffix

You are right.  The AC:2011 is a corrigendum.  There appear to be a 
couple of standards that have corrigendums for information technology 
equipment (ITE) family standards.  However, do the manufacturers 
Declarations of Conformity (DOC) need to list the corrigendum?   
Specifically, would the DOC need to list the below listings?

EN55022:2010 + AC:2011
EN60950-1:2006+A11:2009+A1:2010+A12:2011+AC:2011

Also, I notice that there is no date of cessation of presumption of 
conformity of superseded standard in the listing of harmonized 
standards.  Does this mean that both corrigendums are immediately 
mandatory?


Thanks.

Monrad


On 4/28/2012 8:01 AM, Helge Knudsen wrote:

Hi Rich,

This is just a corrigendum.

You may get it for free if you make a search on the internet, search 
for EN55022:2010/AC:2011.


Best regards

Helge Knudsen

Denmark

*From:*emc-p...@ieee.org mailto:emc-p...@ieee.org 
[mailto:emc-p...@ieee.org] *On Behalf Of *Jones, Richard (Richard)

*Sent:* 28. april 2012 13:08
*To:* EMC-PSTC@LISTSERV.IEEE.ORG mailto:EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* EMC Standard Listings with /AC in the suffix

Hi Everyone

I was looking at the implementation date for EN55022:2010 and noticed 
that there was another line added underneath showing


EN55022:2010/AC:2011 (new)

Is this some sort of amendment, I see there are a number of standards 
with /AC on them . There is no implementation date either


I'm sure there is an obvious answer, but I can't see it yet!

Rich

If it is an amendment what does it contain? Not that I'm cynical Jbut 
I've seen some which you pay serious


money for and they're nothing more than a cover sheet!



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

[Monrad Monsen]

John,
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 by supposing that changed standards
 (as distinct from legislation) are mandatory -- they aren't.
You are correct that Compliance with a 'harmonised standard' is not 
compulsory. (EMC Directive 2004/108/EC, Article 6, section 1).  
However, compliance of equipment with the relevant harmonised standards 
... shall raise a presumption ... of conformity with the essential 
requirements  (EMC Directive 2004/108/EC, Article 6, section 2)  
Otherwise, a manufacturer would have to use (and pay for) a notified 
body to learn about our product and make up their own rules which will 
generally adopt the harmonized standards if they can be applied to the 
product.  For products for which there are specific family standards 
developed like information technology equipment (ITE), the harmonized 
standards are effectively compulsory.


Since my experience is with ITE products, I have not actually worked 
through a notified body.  Are you implying that a notified body would 
freely support a product not updating to comply with new revisions of 
the harmonized standards?  Would a notified body make a blanket finding 
for a company's whole portfolio of ITE products?  Or would a company 
have to pay a fee to the notified body to effectively exempt each and 
every individual product from the new revision harmonized standard?


Personally, I would much prefer if new harmonized standards were only 
applied to new product introductions that start European sales after the 
standard is publish.  That is how it is handled in many countries like 
USA, Canada, and Japan.  However, that is not how the European Union 
rules are written ... unless a notified body will exempt the already 
released products.


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.


Thanks.

Monrad

On 3/6/2012 6:54 AM, John Cotman wrote:


The D of C is supported by a Technical File.  The TF is where you 
document all the changes made during the life of the product.  In the 
event of any enforcement interest, or to deal with matters such as a 
recall, the information in the TF should identify the batch or serial 
or production dates that are relevant to the point at issue.


What matters is that there is a valid D of C at the date of supply (or 
date put into service, depending on the directive(s) involved), and 
that the TF contains the evidence to support it.  If that has all been 
done properly, you don't have to worry about looking backwards if 
you update a D of C.


You have also complicated the issue by supposing that changed 
standards (as distinct from legislation) are mandatory -- they aren't.


John C



*From:*Monrad Monsen [mailto:monrad.mon...@oracle.com]
*Sent:* 06 March 2012 00:10
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] Identifying Apparatus in Europe Declarations of 
Conformity (DOCs)


Disclaimer:  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.


QUESTION:  How should a company apply the below identification of 
apparatus requirement when a change is needed to a product line to 
comply with a new European regulatory requirement like a new standard 
revision or an expiration of RoHS exemption?  Is it enough if all 
products built on or after the date of DOC signature comply with the 
standards listed on the DOC, or must the DOC clearly identify which 
products (including which of the products built in the past) comply?


REQUIREMENT:  As I read Europe's requirements, Europe requires that a 
declaration of conformity (DOC) identifies the the apparatus to which 
it refers and that identification should be in terms of type, batch, 
serial number or any other identification allowing for the 
identification of the apparatus. (Quotes are from EMC Directive 
2004/108/EC annex IV section 2 coupled with article 9 paragraph 1.)


EXAMPLES OF CHANGES:
   1.  SAFETY:  Some products had to have power supply changes to 
upgrade from the product from EN60590-1 1st Edition to the new 
EN60950-1 2nd Edition that became mandatory on 1 December 2010.
2.  EMC:  Some products may have had to a change to comply with 
the new 1-3GHz emissions limits that were 4dB tighter than FCC's 
emissions limits for that same range.  (Also, Europe had some 
measurement setup differences.)  This became mandatory 1 October 2011.
3.  RoHS:  Some products that comply with RoHS today using 
exemptions 7(c)-III [lead in dielectric ceramic capacitors] or 11(b) 
[lead

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

[Monrad Monsen]

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 by supposing that changed 

standards

(as distinct from legislation) are ?mandatory? ? they aren?t.
You are correct that Compliance with a 'harmonised standard' is not 
compulsory. (EMC Directive 2004/108/EC, Article 6, section 1).  
However, compliance of equipment with the relevant harmonised 
standards ... shall raise a presumption ... of conformity with the 
essential requirements  (EMC Directive 2004/108/EC, Article 6, 
section 2)


All OK so far.

Otherwise, a manufacturer would have to use (and pay for) a notified 
body to learn about our product and make up their own rules which 
will generally adopt the harmonized standards if they can be applied 
to the product.


There is no requirement to involve a Notified Body. A manufacturer is 
free to justify any course of action which he believes results in 
compliance with the Directive.


For products for which there are specific family standards developed 
like information technology equipment (ITE), the harmonized standards 
are effectively compulsory.


You may consider that so, but in this forum we deal with a wide range 
of special cases. For a desktop PC, it may be *unnecessary and 
impracticably costly* to consider any route

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

[Monrad Monsen]

Brian,
I'm not sure what you are asking.  In EMC emissions compliance, then 
they do have a rule that 80% confidence that 80% of the products comply 
based on EN55022.  However, if you had to make a change to achieve that 
compliance, then you should identify which products have this change to 
comply.  In contrast, for safety and RoHS, either you built the product 
to comply or you didn't.  If the product had to change, then you should 
identify which products have the change.  Hence, I suggested three 
different methods to identify the applicable products within a model 
number product line:


 * A serial number break-in (the first serial number product starting
   the series of products that always has the change)
 * A date-of-manufacture (DOM) when all units built on that day forward
   have the change
 * A part number if you changed the system part number upon
   implementing the change

What I am suggesting is not sufficient is for a company to just list a 
model number if some of the model number line in the past did not have 
the needed change to make the product comply.  Somehow, the manufacturer 
should identify what products the declaration of conformity (DOC) and 
its listed standards applies to.


Would you give more specifics or suggest a scenario for what you are 
asking?  Other than the 80-80 rule to determine compliance, statistics 
is not involved.


Disclaimer:  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 3/6/2012 9:59 AM, Brian Oconnell wrote:

Is there a statistical basis for the requirement to delineate individual 
compliant units? That is, is this a recurring problem that has been identified?

Brian

-Original Message-
From:emc-p...@ieee.org  [mailto:emc-p...@ieee.org]On Behalf Of Monrad Monsen
Sent: Monday, March 05, 2012 4:10 PM
To:emc-p...@ieee.org
Subject: Identifying Apparatus in Europe Declarations of Conformity (DOCs)

...

In contrast, I tend to believe that the DOC should identify the product that it 
applies to.  If a change was necessary, then somehow the DOC should 
differentiate which portion of the product line complies with the standards 
listed on the DOC, and the date of DOC signature is not enough to make that 
differentiation.  On that basis, I am proposing that the DOC clearly identify 
the portion products the DOC applies to by use a serial number break-in, a date 
of manufacture when the change was implemented, or the specific part numbers 
(if the part number changed with the change of the product).

Am I being too strict?

Of course, if a model number was built compliant with the latest standards from the 
beginning (no changes needed), then the model number alone would be enough to identify 
the apparatus that the DOC refers to.

Thanks.

Monrad Monsen




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

[Monrad Monsen]

Brian,
You wrote:
 I don't see where having the serial number on the DOC tells
 anyone how many are in the field even if you put a range of
 serial numbers.
Please note that my proposal was for a serial number break-in which is 
the first product serial number that implemented the needed change to 
the product that makes the product comply with any new standards that 
you list on the declaration of conformity (DOC).  If your DOC lists 
standards that you had to make changes to your model number product to 
comply with, then you should identify which portion of that model number 
product build complies.  Perhaps you do this by giving a 
date-of-manufacture when the factory started building products with the 
change (all products built from that date and later comply), by giving a 
serial number break-in for the first unit that had the change so all 
later serial numbers also have the change, or by changing the part 
number to identify products having the change.


 companies and manufacturers who follow the rules face
 additional burden because those who cheat cannot be stopped.
This is always true.  However, the purpose of the declaration of 
conformity (DOC) is to inform both the regulators and customers what 
standards the product complies with.  If you had to make a change to the 
product in order to comply with a new revision to the standards, then it 
seems reasonable that you need to identify the products to which your 
DOC applies.  This is not a matter of catching cheats, but it is a 
matter of giving a clear declaration of what product complies with the 
standards listed on the DOC.


However, I am interested in what official source you cite to say that a 
company does not need to identify the apparatus to which it refers and 
that identification should be in terms of type, batch, serial number or 
any other identification allowing for the identification of the 
apparatus. (Quotes are from EMC Directive 2004/108/EC annex IV section 
2 coupled with article 9 paragraph 1.)  I am always in favor of reducing 
my work load as long as I comply with the law.


Disclaimer:  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 3/6/2012 11:21 AM, Kunde, Brian wrote:

If authorities need to know anything, all they have to do is contact the 
manufacturer and ask. My name and phone number is on every DOC we issue.

I don't see where having the serial number on the DOC tells anyone how many are 
in the field even if you put a range of serial numbers. If you are 
manufacturing a 10,000 piece production run but a non-compliance occurs halfway 
through the run, the information on the DOC will not tell you anything. The 
non-compliance maybe on the first one or last one built. It may occur only on 
that run or on all runs. The only way to know is to have the manufacturer 
determine it.

Logically, the current trend to add serial numbers and color pictures (LVD 
recast) on the DOCs will serve little purpose other to overburden the 
manufacturer who has to keep the DOCs on file for 10 years. If the DOC is 
shipped with the product it has a part number and documentation control and you 
have to keep changing the DOC to reflex product runs and serial numbers it will 
cost a company a fortune to handle the never ending river of change notices.

Again, companies and manufacturers who follow the rules face additional burden 
because those who cheat cannot be stopped.

If you read what the Directives want now, they want a Director level person (or 
higher) sitting at the end of each product line, inspecting every unit, 
printing out the DOC, writing in the Model and Serial Number, signing it, 
making a copy of it, put the copy in the box with the product and the original 
in a giant file cabinet.

Just my opinion.

The Other Brian




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

[Monrad Monsen]

Disclaimer:  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.


QUESTION:  How should a company apply the below identification of 
apparatus requirement when a change is needed to a product line to 
comply with a new European regulatory requirement like a new standard 
revision or an expiration of RoHS exemption?  Is it enough if all 
products built on or after the date of DOC signature comply with the 
standards listed on the DOC, or must the DOC clearly identify which 
products (including which of the products built in the past) comply?


REQUIREMENT:  As I read Europe's requirements, Europe requires that a 
declaration of conformity (DOC) identifies the the apparatus to which 
it refers and that identification should be in terms of type, batch, 
serial number or any other identification allowing for the 
identification of the apparatus. (Quotes are from EMC Directive 
2004/108/EC annex IV section 2 coupled with article 9 paragraph 1.)


EXAMPLES OF CHANGES:
   1.  SAFETY:  Some products had to have power supply changes to 
upgrade from the product from EN60590-1 1st Edition to the new EN60950-1 
2nd Edition that became mandatory on 1 December 2010.
2.  EMC:  Some products may have had to a change to comply with the 
new 1-3GHz emissions limits that were 4dB tighter than FCC's emissions 
limits for that same range.  (Also, Europe had some measurement setup 
differences.)  This became mandatory 1 October 2011.
3.  RoHS:  Some products that comply with RoHS today using 
exemptions 7(c)-III [lead in dielectric ceramic capacitors] or 11(b) 
[lead in press-fit connectors] must have a hardware change to stop using 
these exemptions that expire on 1 January 2013.


I am having a discussion with a person that believes that as long as the 
change is implemented in the factory early enough to sell off any 
products prior to the due date of a changed requirement, then a company 
could sign a DOC at that point without for that product without 
differentiating which products pass.  His point is that the DOC applies 
to any new product that would go through customs or would be sold to a 
customer.  Regarding products already within Europe, the customer should 
either look at an older DOC that was signed and effective at the time 
the product was bought or the customer should ask the manufacturer.  No 
customer should assume that a DOC signed later applies to a product 
built and bought earlier.


In contrast, I tend to believe that the DOC should identify the product 
that it applies to.  If a change was necessary, then somehow the DOC 
should differentiate which portion of the product line complies with the 
standards listed on the DOC, and the date of DOC signature is not enough 
to make that differentiation.  On that basis, I am proposing that the 
DOC clearly identify the portion products the DOC applies to by use a 
serial number break-in, a date of manufacture when the change was 
implemented, or the specific part numbers (if the part number changed 
with the change of the product).


Am I being too strict?

Of course, if a model number was built compliant with the latest 
standards from the beginning (no changes needed), then the model number 
alone would be enough to identify the apparatus that the DOC refers to.


Thanks.

Monrad Monsen


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EN50279 Category A

[Monrad Monsen]

What is EN50279 Category A?  Supposedly it has something to do with
ElectroMagnetic emissions.  

Does this standard cover the same frequency range as EN55022 (CISPR22)?  

Is it tougher or easier than EN55022?

What type of products is it focused on?  Home residential vs. business
products?  Desktop vs floor standing large racks of equipment?

What are the other Categories besides Category A?

Thanks.

-- 


Monrad L. Monsen
Compliance Program Manager
Storage Group
Sun Microsystems
monrad.mon...@sun.com
303.272.9612 Office

  


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RE: Another Cancer Scare?

[Monrad Monsen]

This has been an interesting discussion.  There is definitely a lot of
interest in this subject. 

Our EMC chapter in Denver heard a talk on this subject from an EMC Society
Distinguished Lecturer (Dr. Michel Ianoz) on July 26, 2004.  This presentation
addressed the subject of Biological and Health Effects of Electromagnetic
Fields in a very organized and detailed manner using three approaches:
  * Calculation and measurement (engineers)
  * Biological effects (biologists and engineers)
  * Effects on health (medical doctors and statisticians)

I was impressed with the variety of approaches that have been used to study
the topic.  He concluded that more studies needed to be done, but basically
the health risk is at such a low level that it is difficult to evaluate.  This
contrasts greatly from the clear health risks of heavy smoking.  But we should
be concerned when we see that moss growth and other biological organisms are
affected when exposed to electromagnetic energy.  Certainly, the power limits
and restrictions used today greatly reduce this concern.  I have no problems
using cell phones next to my ear for short calls, but I prefer to use an ear
bud or the speaker phone function for longer calls to keep the phone farther
from my brain.

By going to our chapter web site, you can see the record of the meeting
(http://www.ewh.ieee.org/r5/denver/rock
mountainemc/archive/2004/July/index.html) and the actual slides he presented
(http://www.ewh.ieee.org/r5/denver/rock
mountainemc/archive/2004/July/bioeffect.pdf).

Enjoy!

Monrad Monsen
Chairman, Rocky Mountain Chapter of EMC Society (RMCEMC) of IEEE

-- 


Monrad L. Monsen
Compliance Program Manager
Storage Group
Sun Microsystems
monrad.mon...@sun.com
303.272.9612 Office

  


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DOC Requirement for Year CE Mark is Affixed

[Monrad Monsen]

The Low Voltage Directive 2006/95/EC states in annex III that a declaration of
conformity (DOC) must contain the following elements: ... the last two digits
of the year in which the CE marking was affixed.  I note that a like
statement is not listed for the EMC Directive.  

I interpret this requirement as listing the year in which the CE mark was
first affixed to this model number product.  If true, then the signature date
on the DOC would not be adequate because a company may make a later change to
a DOC and re-issue the DOC long after the first CE mark was affixed to this
product line.

I looked through the DOCs of others in our industry, and I do not see this
being followed anywhere.  What are your interpretations of this requirement?

My interpretation is that the last two digits of the year statement is
merely a minimum of two digits, but it allows for using a four digit year. 
Most people avoid using two digit years after the year 2000 crunch, so I'd
prefer to use a four digit year.  

You can view the low voltage directive by going to
http://ec.europa.eu/enterprise/electr_equipment/lv/direct/text.htm;
http://ec.europa.eu/enterprise/electr_equipment/lv/direct/text.htm  and
clicking on the language version of choice (en for English, etc.).  Again,
the requirement is found in annex III.

Thanks. 
-- 


Monrad L. Monsen
Compliance Program Manager
Storage Group
Sun Microsystems
monrad.mon...@sun.com
303.272.9612 Office

  


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Re: The New EMC Directive and the D of C

[Monrad Monsen]

You are correct that the EMC Directive 2004/108/EC states that products placed
on the market before 7/20/2009 can continue to do so under Directive
89/336/EEC.  However, I still recommend option #2 since your DOC and signature
will be dated after the old Directive 89/336/EEC was repealed 7/20/2007.



Monrad L. Monsen
Compliance Program Manager
Storage Group
Sun Microsystems
monrad.mon...@sun.com
303.272.9612 Office


White, Ian wrote: 

Can l have your views on the following please.
 
As l understand it all new Electronic products should now have their
Declaration of Conformities to the new EMC Directive 2004/108/EC, but products
already on the market can still quote the old Directive in their D of C's
 
It is a common practice for company's to take anther manufactures 
product and
put their company logo on  - badge engineer it basically. 
 
In the past they issued a D of C in their name, based on the other
manufacturers D of C. 
 
During this change over period if a company wishes to badge engineer a
product, but the D of C is to the old Directive what should they do :
 
1) Write a D of C to the old Directive under the argument that product 
is in
the market already anyway - if only with a different name
2) Ask the supplier manufacturer for an updated D of C. There a small
differences between the two Directives.
 
Thanks for your help
 
Ian White
 
 
 
 
 
 
 
 
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Re: EN (SPECIFIC )STANDARDS VS THE ~ EQUIVALENT IEC STANDARDS

[Monrad Monsen]

Whoops!  Good points made by Adam Rudd  Tom Sato.  They give valid support
for using the EN version standards in contrast to the IEC versions.  

I have the BS EN 55024:1998  CISPR 24:1997 incorporating Amendments Nos. 1 and
2.  This BSI version does not have an Endorsement Notice, but I assume that
what your standard refers to as an Endorsement Notice is the same as what
BSI calls the Foreword, and the foreword does state that Annex ZA has been
added by CENELEC and is normative.

I note that Annex ZA does specify which international standards have been
modified by common modification through the annotation of (mod). 
Therefore, in answer to Reginald Henry's original question regarding if these
 specific standards below are one to one with the IEC Standard, the only
Information Technology Equipment (ITE) related standards listed that have the
(mod) marking are IEC61000-4-3 (radiated RF field immunity test) and CISPR22
(RF disturbance characteristics or RF emissions).  For these tests, it is
important to use the EN61000-4-3 and EN55022.  Of course, EN55022 is already
listed in the Official Journal as is EN55024, so EN55022 should not be a
surprise to anyone.  However, I'm going to have to order EN61000-4-3.

Thanks.



Monrad L. Monsen
Compliance Program Manager
Storage Group
Sun Microsystems
monrad.mon...@sun.com
303.272.9612 Office

  




Rudd, Adam wrote: 

Monrad,

My copy, SS-EN 55024, has an Endorsement Notice on page 3 which lists 
the
modifications CENELEC made to IEC CISPR 24 for the EN 55024 publication.

 

Additionally, it notes that CENELEC added Annex ZA.  Annex ZA is found 
on
page 5.  It lists the normative references and shows the correlation between
European and International standards which has this following note…

 

“NOTE: When an international publication has been modified by common
modifications, indicated by (mod), the relevant EN/HD applies.”

 

Does your copy have these sections?

Best Regards, 

Adam Rudd 
Electrical Engineer (EMC) 
NCR Corporation, RHSS 
Duluth, GA 
(770) 495-2825





From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Monrad 
Monsen
Sent: Tuesday, May 13, 2008 1:36 PM
To: John Woodgate
Cc: emc-p...@ieee.org
Subject: Re: EN (SPECIFIC )STANDARDS VS THE ~ EQUIVALENT IEC STANDARDS

 

John,
I don't know what version of EN55024 you are looking at, but 
EN55024:1998
only references the IEC standards for each immunity test.  For example, Table
1 for enclosure port immunity lists the standard IEC 61000-4-2 for
Electrostatic Discharge.  In fact, all of the standards listed in the section
2 Normative References are IEC standards ... not EN standards.  This did not
change with amendments A1:2001 and A2:2003.

To Doug Kramer's point, it would be unwise to look for the EN61000-4-2
standard when EN55024 specifies use of the IEC61000-4-2 standard.

Monrad L. Monsen
Compliance Program Manager
Storage Group
Sun Microsystems
monrad.mon...@sun.com
303.272.9612 Office


John Woodgate wrote: 

In message 
79b6babf7ce2914591e1c45c7ed086fa01d...@chiefwiggum.nceelabs.org
mailto:79b6babf7ce2914591e1c45c7ed086fa01d...@chiefwiggum.nceelabs.org ,
dated Thu, 8 May 2008, Doug Kramer dkra...@nceelabs.com
mailto:dkra...@nceelabs.com  writes: 




If EN 55024 calls out testing to IEC 61000-4-4, use of EN61000-4-4 
(what's
the date on that?) would not be the correct approach. 


I don't think there is any such case. All references in all EN Product 
and
Generic standards are to the EN 61000-4-x. 


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Re: EN (SPECIFIC )STANDARDS VS THE ~ EQUIVALENT IEC STANDARDS

[Monrad Monsen]

John,
I don't know what version of EN55024 you are looking at, but EN55024:1998 only
references the IEC standards for each immunity test.  For example, Table 1 for
enclosure port immunity lists the standard IEC 61000-4-2 for Electrostatic
Discharge.  In fact, all of the standards listed in the section 2 Normative
References are IEC standards ... not EN standards.  This did not change with
amendments A1:2001 and A2:2003.

To Doug Kramer's point, it would be unwise to look for the EN61000-4-2
standard when EN55024 specifies use of the IEC61000-4-2 standard.



Monrad L. Monsen
Compliance Program Manager
Storage Group
Sun Microsystems
monrad.mon...@sun.com
303.272.9612 Office


John Woodgate wrote: 

In message 
79b6babf7ce2914591e1c45c7ed086fa01d...@chiefwiggum.nceelabs.org
mailto:79b6babf7ce2914591e1c45c7ed086fa01d...@chiefwiggum.nceelabs.org ,
dated Thu, 8 May 2008, Doug Kramer dkra...@nceelabs.com
mailto:dkra...@nceelabs.com  writes: 



If EN 55024 calls out testing to IEC 61000-4-4, use of 
EN61000-4-4 (what's
the date on that?) would not be the correct approach. 



I don't think there is any such case. All references in all EN Product 
and
Generic standards are to the EN 61000-4-x. 


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