Hello Jon, (and group) The item you discuss here is very actual in our continent too, my reaction may not supply a full answer to your questions, but i think it is interesting for all of us. If you want to copy this message to the newsgroups and people you speak about, you have my permission.
Although i live in the Netherlands and ALL my clients can self certify, this is not a procedure getting you out of the risk area if your product is SOLD. Although there is no punishment defined in ce-marking without testing, there is something like product liability. The problem is that any client of you may apply the product in any situation YOU are not aware of. If any emission related accident occurs, you as a seller may be held responsible (sued). This is even more important in the US then in Europe. If you did test however and have test reports, you did what you legally had to do. It's up to your client now to prove that your product exceeded the emission specs as tested. If you don't test, it will be you who should prove that the sold item did not exceed acceptable limits. So, if it's not the law that bites, it may be your customer. Or the competition. ANY time a product is sold you should test a sample, otherwise forget the sales. Technically, one should have a lot of experience in EMC-testing to KNOW how to make a processor design -as you call it- quiet. Interference occur -acc to Murphy- always on a frequency YOU have not the possibility to check for, AND that your client relies on to open/close his garage with a remote control gadget. Anyhow, I started answer after your statement about the ce-mark. Because on your side of the ocean the self certification route is seen as more easy to comply then the FCC certification routes. On the contrary, i believe EMC testing in Europe is more severe now: In addition to the US a microcontroller like yours should comply too for immunity, this means - continue to perform it's job (at reduced accuracy) when radiated at 3V/m 80 MHz - 1000 MHz - continue to perform it's job (at reduced accuracy) when current injected into all cables at 3V over 150 Ohm from 150 kHz - 80 MHz. (both AM modulated 1khz 80%) - resist to fast transient pulses in burst mode 1 or 2 kV pulses ; pulse rise/with 5/50 nS on all cables - resist surge discharges on the mains connection ( and telecom ) 1 or 2 kV 1.2 /50 uS comb. wave - resist ESD discharges, both air discharge and contact discharge at 8/4 kV - voltage variations in interruptions on the mains according to the generic standard EN 50082-1:1997 , which applies for ITE equipment. These requirements are valid too if you make only ONE micro controller even for HOME use They are true for kits too. (for KIDS too :o) ). Its my opinion that within a few years, the American market will somehow copy the European set-up. Hope this gives you something to think about. Regards, Ing. Gert Gremmen == CE-test, qualified testing, Consultancy, Compliance tests for EMC and Electrical Safety 15 Great EMC-design tips available ! Visit our site : http://www.cetest.nl The Dutch Electronics Directory http://www.cetest.nl/electronics.htm == -----Oorspronkelijk bericht----- Van: Jon Bertrand [SMTP:[email protected]] Verzonden: vrijdag 20 februari 1998 17:13 Aan: [email protected] Onderwerp: FCC Questions. Hello Everyone, A lot of "budding midnight designers" ask these questions on the microcontroller newsgroups so I thought I'd ask them here - and learn something :) (If I've missed some FAQ that covers this please let me know.) 1) Say I'm building some microcontroller based widget in my home business that runs model trains (or whatever). It's not an intential transmitter, its typically used in the home. And I want to sell them. Do I need some FCC approval. Specifically do I need to: 1.a) Spend money having someone test emissions. 1.b) File some paperwork with the FCC. 2) If I don't have the money for testing - but I really do know how to keep my microcontroller quiet (i.e I know loop area, di/dt, and maybe even have done lots of other 'approved' products) - and a little in-home testing shows it doesn't bother the rabbit ears or show-up on the AM or FM radio. Would I be in violation of some law if I just sold the darn thing. 2.a) Would I be in violation if it really was quiet to CISPR (i.e. would have passed). (i.e. is there now a CE mark like compliance that lets me self declare and assert who's responsible). 3) How does the FCC verify that I don't pollute the EM band - do they random sample train widgets or wait for someone to complain. Thanks, Jon Bertrand [email protected]
