Vic, Brian,
I was most interested in your posting below. I had a publication from DTI
(Dep of Trade & Industry)
in the uk that was quite clear that the way to compliance to the EU directives
was to design to
EU standards. Here we seem to have a system integrator who has discovered a
way to do just that for
EMC and is in trouble. In the US they could have the same situation with the
new DoC (Declaration of
Conformance). These new directives seem to be leading the way to non
compliance.
Regards Ian.
In message "BOUNCE [email protected]: Non-member submission from [Brian
Jones <emc@bria", you write:
" Ladies & Gentlemen,
I thought that you may be interested in the outcome of a meetiig between a
well-known PC
manufacturer and the European Commission, DGIII (Elena Santiago) concerning the
legalities
of System Integration
1. An integrator of a "Core PC" (motherboard, power supply, case & drives -
6.4.2 pare. 4 of
the EMC Directive Guidelines) need only follow the Conformity Assessment
Guidelines (10.1 or
10.2 of the Directive, 8.1 or 8.2 of the Guidelines). This
entails using CE Marked modules, following module instructions exactly,
providing a
Declaration of Conformity, and providing a CE Marking on the product. If
he/she does this, then
the resultant product NEED NOT BE TESTED. Further, if an enforcement
organization later tests the
product and it fails the emissions limits, the System integrator will still be
considered in compliance!
The enforcer is then supposed to turn his/her sights on the module suppliers
for not
providing sufficient instructions, and leave the System Integrator alone.
Accordingly, if the
System Integrators under prosecution in the UK followed the Guidelines but did
not test, they
should not be prosecuted.
2. EMC auditing of production is not mandatory. Even though EN55022, in
describing the 80/80
rule, indicates that auditing is mandatory, the European Commission views this
as not a standards
issue and beyond the scope of CENELEC to specify. They also consider this
requirement in conflict
with their guidelines and are taking steps to have CENELEC remove this wording
from EN55022.
3. We also brought up an issue regarding the use of prototypes for evaluation
and demonstration,
and of development units for customers to use to simultaneously prepare new
designs. Ms. Santiago
agreed to bring the matter up with the horizontal National Authorities.
The above will obviously have a major impact on all PC manufacturers and
system integrators!
Perhaps someone within this newsgroup is able to confirm (or otherwise) this
ground-shift."
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