Re: [PSES] Regulatory requirements and internal use
Curt, I presume your comment that the product ‘designed and built in China which has regulatory approvals’ means that you have broad safety and EMC certifications rather than specific certs (e.g. China only). The addition of the radio complicates the issues considerably. Even though you claim restricted use of the radio this invokes the radio rules country by country; it is not important whether or not the product is used internally to your company – radio waves are not bound by property lines or walls. These requirements are driven by local regulators and are additional to the usual safety and EMC evaluations and certifications done for equipment. Dave outlined the North American requirements in his note below. The European Radio Equipment Directive (RED) applies since you have a radio in the product, it also additionally invokes the entire set of Euro standards for Safety, EMC and RoHS requirements in order to show compliance to the RED. This means that you must apply all of these technical requirements and have a Technical File showing compliance in order to apply the CE marking. This same approach would probably be followed by most other countries which have adopted the Euro approach for product certification including marking to show compliance. Look at the power supply for your laptop as an example. Get competent help in determining these required radio licensing for operation safety and certification requirements for each country in which you plan to operate your product. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 <mailto:p.perk...@ieee.org> p.perk...@ieee.org From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Thursday, November 2, 2017 10:00 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Regulatory requirements and internal use If the device is used in the US workplace then OSHA rules would still apply which would require a NRTL certification if applicable and equivalent in Canada. Adding the radio may impact the existing NRTL certification of the device if there is one. If the radio/device is only low power/low voltage with no safety hazards then perhaps only FCC requirements would apply in the US. Other countries will be country specific. -Dave From: mcnam025 University of Minnesota [mailto:mcnam...@umn.edu] Sent: Thursday, November 02, 2017 11:28 AM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] Regulatory requirements and internal use I have been asked to comment on the following: -- we have a device designed and built in China which has regulatory approvals -- we want to add a low power radio to this device (chip down or certified module are options) -- the end device is only for use within our corporation. This includes franchises which may be in the US or other countries. -- the device is not used near the body, and the device does not contain cellular capability. What regulatory requirements do we need to meet? The device is not offered for sale to the public. However, the franchise owner pays for the device, and the device is placed in a public area. I would like to add my gratitude for the excellent advise the list has provided in the past. Curt - 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 mailto: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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org> > Mike Cantwell mailto:mcantw...@ieee.org> > For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org> > David Heald mailto: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 mailto: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 Commu
Re: [PSES] Regulatory requirements and internal use
If the device is used in the US workplace then OSHA rules would still apply which would require a NRTL certification if applicable and equivalent in Canada. Adding the radio may impact the existing NRTL certification of the device if there is one. If the radio/device is only low power/low voltage with no safety hazards then perhaps only FCC requirements would apply in the US. Other countries will be country specific. -Dave From: mcnam025 University of Minnesota [mailto:mcnam...@umn.edu] Sent: Thursday, November 02, 2017 11:28 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Regulatory requirements and internal use I have been asked to comment on the following: -- we have a device designed and built in China which has regulatory approvals -- we want to add a low power radio to this device (chip down or certified module are options) -- the end device is only for use within our corporation. This includes franchises which may be in the US or other countries. -- the device is not used near the body, and the device does not contain cellular capability. What regulatory requirements do we need to meet? The device is not offered for sale to the public. However, the franchise owner pays for the device, and the device is placed in a public area. I would like to add my gratitude for the excellent advise the list has provided in the past. Curt - 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 mailto: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)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
[PSES] Regulatory requirements and internal use
I have been asked to comment on the following: -- we have a device designed and built in China which has regulatory approvals -- we want to add a low power radio to this device (chip down or certified module are options) -- the end device is only for use within our corporation. This includes franchises which may be in the US or other countries. -- the device is not used near the body, and the device does not contain cellular capability. What regulatory requirements do we need to meet? The device is not offered for sale to the public. However, the franchise owner pays for the device, and the device is placed in a public area. I would like to add my gratitude for the excellent advise the list has provided in the past. Curt - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas Mike Cantwell For policy questions, send mail to: Jim Bacher: David Heald:
