******************** ARCHIVED 8 APRIL 2002 at request of martin rowe says is out of date and would like to take his email address off of it ****************************** **************
Electronic Directives FAQ
The electronic directives are applicable to several boat components and accessories. In addition, many of the questions and comments in the FAQ (frequently asked questions) apply to the Recreational Craft Directive as well.
The electronics field is much more "into" the internet than the boat builders. They have created the internet newsgroup sci.engr.electrical.compliance to deal with the issue of electrical compliance with standards. This approach would have / could be an excellent way for boat builders to address their concerns about the Recreational Craft Directive, except, many boat builders are not yet online.
A Mr. Bill Lyons at IEEE has with the assistance of several other people (listed at the bottom of this page) used the newsgroup and additional information to create a FAQ (Frequently Asked Questions) file that is posted on the sci.engr.electrical.compliance newsgroup. The FAQ is updated in the newsgroup about once a month. It is also posted on the net at http://world.std.com/~techbook/compliance_faq.html. http://world.std.com/~techbook/compliance_faq.html. We suggest you read it on the newsgroup or their web post to get the "official version". We have noticed their web site is not updated as fast as the newsgroup site. Since some of you have trouble accessing the newsgroup and their web site seems busy at times, we reproduced his 15 June 1997 edition below.
Supersedes: <email@example.com> # Last Posted: Thu, 15 May 97 15:18:39 GMT # URL: http://world.std.com/~techbook/compliance_faq.html Textfile: http://www.lyons.demon.co.uk/seecfaq1.txt FAQ: SOURCES OF EMC AND SAFETY COMPLIANCE INFORMATION - PART 1 First posted: April 17, 1996 Fifteenth issue: June 15, 1997 # CONTENTS - PART 1 (THIS PART) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 1.1 Introduction 1.2 Journals devoted wholly or mainly to EMC and safety compliance 1.3 Conferences and Exhibitions 1.4 Listservers 1.5 WWW Sites 1.5.1 Non-commercial 1.5.2 Commercial Web sites carrying useful EMC/safety information 1.6 Standards Organizations 1.7 Specifications for Safety and EMC Compliance 1.8 Books and Guides 1.9 CE Mark 1.10 Australia and New Zealand 1.11 Official & Quasi-official Advice CONTENTS - PART 2 ~~~~~~~~~~~~~~~~~ 2.1 The sci.engr.electrical.compliance newsgroup 2.1.1 Background and History 2.1.2 Charter and Rationale 2.1.3 Guidelines 2.2 European Voltage Harmonisation 2.3 Commonly-asked Questions and Answers about the EMC Directive 2.4 The Low Voltage Directive (LVD) Acknowledgments 1.1 INTRODUCTION ~~~~~~~~~~~~ Welcome to sci.engr.electrical.compliance (s.e.e.c). This is the FAQ for the sci.engr.electrical.compliance newsgroup. It supersedes the "Pre-FAQ: Sources of EMC & Safety Compliance Information" which was posted to sci.physics.electromag monthly from January 15, 1996 until April 4, 1996 pending the establishment of the s.e.e.c newsgroup. Since some newsreaders have difficulty with articles approaching or exceeding approx 64k in length, this FAQ has now been divided into two parts. This is Part 1. This FAQ was created by, and is currently maintained by, Bill Lyons <Bill@lyons.demon.co uk> or <firstname.lastname@example.org>, who welcomes suggestions for additions or amendments. It will be posted to s.e.e.c approximately monthly, with pointers in the following related newsgroups: sci.electronics.misc sci.electronics.design sci.engr.electrical.sys-protection sci.physics.electromag alt.engineering.electrical and the following mailing lists: email@example.com firstname.lastname@example.org The latest issue of this FAQ is archived at: http://world.std.com/~techbook/compliance_faq.html PLEASE ADVISE CORRECTIONS OF ANY ERRORS YOU MAY DETECT, OR SUGGESTIONS OF ADDITIONAL USEFUL INFORMATION, AS INDICATED AT THE END OF THIS FAQ. N.B. A hash mark (#) in the right-hand margin indicates new or modified information since the previous issue. 1.2 Journals devoted wholly or mainly to EMC and safety compliance ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ (Additionally many, perhaps most, electrical/electronic journals include articles, sections or features on EMC/compliance) NB: L = UK pounds APPROVAL - "The engineering guide to European quality, standards and regulations" 6 issues per year - UK L39, EU L48, RoW L55 p.a. M & M Business Communications Ltd Lime Tree House, Lime Tree Walk, Sevenoaks, Kent TN13 1YH, UK Adrian McLeod, Editor Tel: +44 (0)1732 746 616 Fax: +44 (0)1732 746 617 email: email@example.com URL: http://www.cix.co.uk/~approval Subscriptions/advertising: +44 (0)1732 746 616 COMPLIANCE ENGINEERING "The magazine for international regulatory compliance" Bimonthly, no charge to qualified persons One Tech Drive, Suite 215, Andover, MA 01810, USA email: firstname.lastname@example.org URL: http://www.ce-mag.com Phone: +1 (508) 681-6600 Fax: +1 (508) 681-6637 Subscriptions: on-line (see email address and URL above) or Phone: +1 (508) 681-6627 (Kelly-Ann Riley) Constance Brown, Publisher (email email@example.com) 508-681-6642 Mark Jurgen, Assistant Editor (email firstname.lastname@example.org) Editorial Board, Bill Fiske, Dag Bjorklof, Roland Gubisch, Ph.D., Spencer Hutchens, Robert Martin, Paul Scicchitano, Don Sherratt Production, Lisa Holovnia Advertising Managers, Mike Costa, Mike Mintzer, Carolyn Belanger Standards and Publications, Patricia LeBlanc COMPLIANCE ENGINEERING, EUROPEAN EDITION No charge to qualified persons Unit 10, Mansfield Park, Cranleigh, Surrey GU6 8PY, UK Phone: +44 (0)1483 488 408 Fax: +44 (0)1483 488 447 EMC ENGINEERING EUROPE Published 6 times per year Miller Freeman plc, Miller Freeman House 30 Calderwood Street, London SE18 6QH, UK Phone: +44 (0)181 855 7777 Fax: +44 (0)181 854 8814 email: email@example.com URL: http://www.dotelectronics.co.uk/ THE EUROPEAN EMC JOURNAL Published 6 times per year (bimonthly from mid-February) UK: no charge to qualified persons Europe/Rest of World: L50 per year (6 issues) incl post/packing Nutwood UK Ltd, Mansel Court, Mansel Gamage, Hereford HR4 7LE, UK email: firstname.lastname@example.org URL: http://www.emc-journal.co.uk/ Alan E Hutley, Publisher Dave Fynn, News & Features Editor Phone: +44 (0)1981 590481 Fax: +44 (0)1981 590223 Malcolm A Burchall, Technical Editor Phone: +44 (0)1628 778446 Fax: +44 (0)1828 788294 IEEE ELECTROMAGNETIC COMPATIBILITY SOCIETY NEWSLETTER Quarterly: no charge to IEEE EMC society members. The Institute of Electrical and Electronics Engineers, Inc. 445 Hoes Lane, PO Box 1331, Piscataway, NJ 08855-1331, USA Phone: +1 908 981-0060 Fax: +1 908 981-9667 Telex: 833-233 email: email@example.com IEEE TRANSACTIONS ON ELECTROMAGNETIC COMPATIBILITY The Institute of Electrical and Electronics Engineers, Inc. 445 Hoes Lane, PO Box 1331, Piscataway, NJ 08855-1331, USA Phone: +1 908 981-0060 Fax: +1 908 981-9667 Telex: 833-233 email: firstname.lastname@example.org Motohisa Kanda, Editor (NIST) INTERFERENCE TECHNOLOGY ENGINEER'S MASTER (ITEM) MAGAZINE Published twice annually as ITEM and ITEM Update No charge to qualified persons Robert D Goldblum, Editor R & B Enterprises, 20 Clipper Road, West Conshohocken, PA 19428-2721 Phone: +1 610 825-1960 Fax: +1 610 825-1684 email: email@example.com INTERNATIONAL PRODUCT SAFETY NEWS (ISSN 1040-7529) "The Newsletter Devoted to Product Safety Compliance" Published six times a year Product Safety International (PSI) PO Box 1561-PFAQ, Middletown, CT 06457-8061, USA Phone: +1 860 344-1651 Fax: +1 860 346-9066 email: firstname.lastname@example.org URL: http://www.safetylink.com "The Safety Link is the Internet's most comprehensive collection of (electrical) product safety and standards links" Arthur E Michael, Editor SAFETY AND EMC NEWSLETTER Published bimonthly. L120/$208 p.a. ERA Technology Ltd Cleeve Road, Leatherhead, Surrey KT22 7SA, UK Phone: +44 1372 367014 (publication sales) +44 1372 367000 (switchboard) Fax: +44 1372 377927 Natalie Wood, Editor 1.3 Conferences and Exhibitions ~~~~~~~~~~~~~~~~~~~~~~~~~~~ N.B. CD-ROMs, formerly listed here, are now included in Paul Bennett's "FAQ: Safety and EMC Compliance - Books and Guides" (see section 1.8) EMC YORK '97 # CE Marking and EMC Conference and Exhibition # University of York Heslington York YO1 5DD UK # Monday 14 July 1997 # # Chris Marshman, York EMC Services Ltd, Department of Electronics # Tel: +44 1904 434 440 # Fax: +44 1904 434 434 # email: email@example.com # URL: http://www.emcnet.com/uoy/ # # # 1997 IEEE INTERNATIONAL SYMPOSIUM ON ELECTROMAGNETIC COMPATIBILITY Austin Convention Center Austin Texas USA August 18-22, 1997 URL: http://www.emctest.com/ieee97 Technical Papers & Program: Edwin L Bronaugh, EdB EMC Consultants Tel: +1 512 258 6687 Fax: +1 512 258 6982 Exhibits: Mark J Prchlik, EMC Test Systems, L.P. Tel: +1 512 835 4684 ext 741 Fax: +1 512 835 4729 firstname.lastname@example.org Registration: All About Meetings, 1650 S Pacific Coast Highway, Ste 209 Redondo Beach, CA 90277, USA Tel: +1 310 316 5153 (questions only - no telephone registrations) Fax: +1 310 316 0713 10TH INTERNATIONAL CONFERENCE ON ELECTROMAGNETIC COMPATIBILITY University of Warwick, UK September 1-3, 1997 L Hudson, IEE, Savoy Place, London WC2R 0BL, UK Tel: +44 171 240 1871 Fax: +44 171 497 3633 # Further information about this event is available at: # URL: http://www.iee.org.uk/LSboard/Conf/EMC97/ # # The "call-for-papers" deadline has now passed and a provisional programme # will be added to the WWW pages shortly. # 19TH ANNUAL EOS/ESD SYMPOSIUM Santa Clara Convention Center CA USA September 23-25, 1997 Koen Verhaege Tel: +1 609 734 2344 Fax: +1 609 734 2565 email: email@example.com EURO-EMC 1997 Sandown Park Exhibition Centre UK October 7-9, 1997 Reed Exhibition Companies Tel: +44 181 910 7883 URL: http://www.nepcon.co.uk/euroemc/ 1998 IEEE INTERNATIONAL SYMPOSIUM ON ELECTROMAGNETIC COMPATIBILITY Denver Colorado USA R Barry Wallen +1 303 682 6600 firstname.lastname@example.org 1.4 Listservers ~~~~~~~~~~~ EMC-PSTC EMC-PSTC Regulatory E-Mail Grapevine Hosted by the IEEE, the EMC-PSTC is an informal group of people interested in Product Safety regulations and standards world-wide, networked electronically by mailing list. Its purpose is to provide a forum for the sharing of public, but possibly obscure Product Safety or Regulatory Compliance information, or related information with limited natural distribution. All mail sent to the Internet address will be immediately echoed to everyone on the list by an automated list server. for subscription info send email to: email@example.com containing in the body of the message only the words: info emc-pstc (no subject header needed) Information on EMC-PSTC is also available at URL http://uc.com/compliance_engineering/pstc_db.htm TREG: Telecom Regulatory E-Mail Grapevine (TREG) TREG is an informal group of people interested in telecommunications regulations and standards world-wide, networked electronically by mailing list. Its purpose is to provide a forum for the sharing of public, but esoteric or possibly obscure telecom compliance information, or related information with limited natural distribution. Members need only send contributions to: firstname.lastname@example.org All mail sent to this Internet address will be immediately echoed to everyone on the TREG list by an automated list server. SUBSCRIBING OR UNSUBSCRIBING - Send an Internet e-mail request with the phrase "subscribe treg" or "unsubscribe treg" in it to: email@example.com BILLBOARD: Billboard is a telecom newsletter published by Bill von Alven of the FCC. Bill is head of the United States of America's Federal Communications Commission CFR Title 47 Part 68 telecommunications registration section and publishes an informative industry newsletter on a monthly basis. To subscribe send: subscribe billboard to: firstname.lastname@example.org CONFORMITY A Monthly Newsletter for Electronic Products Compiled by Jon Curtis, Director of Engineering of Curtis- Straus LLC, CONFORMITY is: "A free monthly newsletter summarizing the regulatory issues that cross my desk. Since I also distribute treg and wish treg to remain absolutely non-commercial, I have set up a separate emailing list for my newsletter." If you want to get the newsletter via email, you should send: subscribe Conformity to: email@example.com E-SAFETY Electrical Safety Email List Rene Schmit <firstname.lastname@example.org> writes: I have just installed an email list for discussions about electrical safety (see charter below). ------- e-safety Email List Charter ------- The purpose of this email list is the discussion of topics related to product safety in general and electrical safety in particular. Possible discussions include standard interpretations, product design guidelines, product certification, product marking and legal aspects. Typical members of this list are product design and safety engineers, test house engineers and standardisation commitee members. Newcomers as well as experts are welcome to participate in the discussions. This list will initially be unmoderated, but this could change in the event of an unacceptably high noise/signal ratio. The number of subscribers is unlimited, a splitting of the list is however possible. For example, a separate list for household appliances and information equipment might be possible. How to subscribe: Send email to: email@example.com Subject: None Message: subscribe e-safety In return, you will receive your subscription confirmation How to write a letter to the 'list': Send a simple email to the following address firstname.lastname@example.org 1.5.1 WWW Sites - Non-commercial ~~~~~~~~~~~~~~~~~~~~~~~~~~ STANDARDS ORGANISATIONS: # ANSI http://www.ansi.org/docs/home.html # BSI http://www.bsi.org.uk # ETSI http://www.etsi.fr # IEC http://www.iec.ch # ISO http://www.iso.ch # ITU-T http://www.itu.ch # # AEDC - The Australian Electronics Development Centre's EMC homepage: http://www.aedc.com.au/emc Approval: http://www.cix.co.uk/~approval "The engineering guide to European quality, standards and regulations" Includes DTI (UK) guidance notes on the EMC Directive and the LVD, and a list of EMC standards at http://www.cix.co.uk/~approval/emcstan.htm Compliance Engineering: http://www.ce-mag.com Defence Research Agency, UK (aerospace EMC) http://dspace.dial.pipex.com/town/plaza/gs66/index_fr.htm # The European EMC Journal http://www.emc-journal.co.uk/ A draft version of the new "Commission Guidelines" for EMC can be found at http://www.emc-journal.co.uk/newguide.html WARNING! read with great caution: contains numerous errors ~~~~~~~ European Organisation for Testing and Certification (EOTC): http://www.eotc.be/ email: email@example.com Federal Communication Commission (FCC), USA: http://www.fcc.gov/oet/info/rules FCC rules and regulations on-line (downloadable free) A list of EMC test labs on file with the FCC is available at URL: http://www.fcc.gov/oet/info/database/testsite/ IEEE Electromagnetic Compatibility Society: http://www.emclab.umr.edu/ieee_emc/ Jet Propulsion Laboratory http://emlib.jpl.nasa.gov Low Voltage Directive - full text: http://www.safetylink.com/lvd.asc National Electronics Technology Centre (NETC), Forbairt, Dublin, Ireland http://www.netc.ie/ National Physical Laboratory, UK (RF/MW news, incl. antenna calibration) http://www.npl.co.uk/npl/cetm/rfmwnews National Weights and Measures Laboratory, UK: http://www.dti.gov.uk/nwml Northeast Product Safety Society, Inc: http://www.safetylink.com/npss.html PQ-Chat (Electrotek PQ-net): http://www.electrotek.com Regulatory Compliance Information Center (RCIC): http://www.rcic.com/ Rudi Logghe <firstname.lastname@example.org> maintains an interesting EMC page covering Standards and Directives, Consultancy, Universities and Manufacturers at: http://www.club.innet.be/~year2138/emc.htm Safety Link: http://www.safetylink.com "The Safety Link is the Internet's most comprehensive collection of (electrical) product safety and standards links" Spectrum Management Agency (Australia): http://www.sma.gov.au/spectrum/comply/emc/index.htm The Australian EMC Framework (downloadable free) Test & Measurement World http://world.std.com/~techbook/emclinks.htm "Links to info on the EMC Directive. The links are to noncommercial sites where you can find technical info such as what are the standards applicable to the EMC Directive. Also a link to the column 'Can You Afford the CE Marking?'" University of Missouri-Rolla Electromagnetic Compatibility Laboratory http://www.emclab.umr.edu University of Warwick ATC EMC Group (esp. automotive EMC testing) http://www.warwick.ac.uk/~esrjo/robert.html 1.5.2 Commercial Web Sites carrying useful EMC/safety related information ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ BABT (British Approvals Board for Telecommunications: http://www.babt.co.uk/ Claude Lyons Limited http://www.lyons.demon.co.uk/epsma.html CE Marking on Power Supplies - Guidance from the EPSMA (see also Section 1.11 of this FAQ, "Official & Quasi-official Advice") Compliance Online - a monthly electronic newsletter for environmental regulatory compliance. http://www.ieti.com/taylor/compliance.html Conformance http://www.conformance.co.uk Includes a full list of the 'CE Marking Directives' and the UK legislation which enforces them. Emcnet http://www.emcnet.com EMC acronyms http://www.emcnet.com/emc4.htm EPL Ltd. http://www.epl.co.uk Telecoms/EMC/safety approvals info & telecoms test equipment Horrocks Technology http://ourworld.compuserve.com/homepages/Horrocks_Technology Info on European Regulatory and Policy Documents on disk or CD ROM. KTL - info on LVD and EMC http:/www.ktl.co.uk/ktl/cemark.htm Patton & Associates, Inc http://www.patton-assoc.com The CE Mark and Network Connection Mark along with instructions for size and placement can be down loaded. Patton intend to add the ability to down load all Approval Marks listed on this page as soon as time permits. List of EMC standards: http://www.rfi.co.uk/wwwrestricted/StdBull_OJ.htm Summary of EMC issues http://www.compulink.co.uk/~duchess/emc.htm Technology International http://www.TechIntl.com (CE Marking & Quality) TUV Product Service http://www.tuvps.com Westbay Technology http://www.emcnet.com/westbay/westbay1.htm (demo versions of low cost pc emc packages can be downloaded) 1.6 Standards Organizations ~~~~~~~~~~~~~~~~~~~~~~~ FAQ: Safety and EMC Compliance - Organisations Most recently posted to sci.engr.electrical.compliance on 09 Feb 1997. Maintained by Paul E Bennett <email@example.com> who will welcome additions and amendments. URL: http://world.std.com/~techbook/stdsorgs.htm 1.7 Specifications for Safety and EMC Compliance ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 1.7.1 FAQ: Safety and EMC Compliance - European Standards Most recently posted to sci.engr.electrical.compliance on 09 Feb 1997. Maintained by Paul E Bennett <firstname.lastname@example.org> who will welcome additions and amendments. URL: http://world.std.com/~techbook/standard.htm Note: AMERICAN STANDARDS : EASTERN EUROPEAN STANDARDS Some US and Eastern European standards are mentioned in this FAQ. Paul Bennett comments: "The few that appear here may be candidates for an eventual separate individual FAQ for each of the global areas. It is desirable that others should take on this task (preferably if they live in the area of the globe concerned)." 1.7.2 FAQ: Safety and EMC Compliance - North American Standards Volunteers to generate and maintain this FAQ are required. 1.7.3 FAQ: Safety and EMC Compliance - R-o-W Standards Volunteers to generate and maintain this FAQ are required. Note: A partial listing of Australian / New Zealand standards is given in section 10 below. 1.8 Books and Guides ~~~~~~~~~~~~~~~~ FAQ: Safety and EMC Compliance - Books and Guides Most recently posted to sci.engr.electrical.compliance on 09 Feb 1997. Maintained by Paul E Bennett <email@example.com> who will welcome additions and amendments. URL: http://world.std.com/~techbook/cebooks.htm 1.9 The CE Mark ~~~~~~~~~~~ A copy of the CE-MARK in PCX format is available by an email request to Jeremy Turner <Jeremy@srscomp.demon.co.uk>. The CE Mark logo is also available from BABT at http://www.babt.co.uk in their "Logos and Approval Marks" page http://www.babt.co.uk/graphics.htm (The logo shows the CE mark complete with Notified Body number and "crossed hockey sticks", but you can easily edit it to suit, as the file expands into 17 or 18 different file formats, which should suit everybody's software!) 1.10 Australia and New Zealand ~~~~~~~~~~~~~~~~~~~~~~~~~ NOTE: Much thanks to Chris Healy <firstname.lastname@example.org> for the following updated information. New Zealand has had EMC regulation for some time, and Australia introduced mandatory requirements for all electrical products first offered for sale from the first of January 1997. While both countries use the C-tick as a compliance mark, the regulations for each country are currently independent. A recently signed MRA between Australia and New Zealand will, at some time in the future, result in mutual acceptance of technical and regulatory requirements, thus requiring the establishment of compliance in one country only. The regulations in Australia and New Zealand are both based on Declarations of Conformity, with the party responsible for the declaration being resident in the applicable country. This requirement is similar to the EU requirements. Australia ~~~~~~~~~ The Australian regulations came into force on 1 January 1997, for new products. The regulations will apply to all products from 1 January 1999. The Australian requirements are to: Establish a sound technical grounds for compliance; Make a Declaration of Conformity; Prepare a compliance folder of technical construction file; and Label the product. Ref. Government Notices: Radiocommunications Standards (Electromagnetic Compatibility) No.1 of 1996, and Radiocommunications (Compliance Labelling - Incidental Emissions) Notice. Electromagnetic Compatibility Fremework, Information for Suppliers (1996) All market sectors are covered: commercial, residential and light industrial, installation/maintenance, automotive, heavy industry (power transmission and large scale, manufacturing). Applicable emission standards are:- AS/NZS 4251 Generic AS/NZS 1044 Household Electrical Appliances, Portable Tools & Similar Electrical Equipment AS/NZS 1053 Sound & Television Receivers & Associated Equipment AS/NZS 2064.1/2 Industrial, Scientific & Medical Equipment AS/NZS 2557 Vehicles, Motor Boats and Spark Ignition Engine Driven Devices AS/NZS 3548 Information Technology Equipment AS/NZS 4051 Fluorescent Lamps & Luminaires AS/NZS 4052 Microwave Ovens No time frame has been set for the introduction of immunity standards. Note: Where EMC requirements are a part of other regulators' requirements, the SMA will accept the specific sector regulators requirements in place of the SMA requirements. For telecommunications, EMC has been removed from the new Telecommunications Bill currently before Parliament and due for enforcement from 1 July 1997. The current AUSTEL requirement (AS3548 class A) will continue until 1 January 1998, then be replaced with the SMA requirements. There are two marks for use on products for denoting compliance under the EMC Framework. These are: 1) The C-Tick mark: This mark is intended for general use on products to declare compliance with EMC regulations. The C-tick mark is also used by AUSTEL in place of the "AUSTEL PERMITTED" on Telecommunications Products. 2) The Regulatory Compliance Mark (RCM): The Regulatory Compliance Mark is a general mark indicating compliance with regulations. The RCM is accepted by the SMA as an alternative to the C- tick. The rules for use of the mark are specified in joint Australian and New Zealand Standard: AS/NZS4417 Marking of Electrical products to indicate compliance with regulations. Currently there are three parts to the standard Part 1 General Rules for use of the mark Part 2 Specific requirements for electrical safety regulatory applications Part 3 Specific requirements for electromagnetic compatibility applications. There is also activities to extend the mark to use on plumbing products, radio transmitters, telecommunications and medical products. The RCM mark is currently accepted by the Australian electrical safety regulators as an alternative to their certification marks. The catch is that compliance with the requirements of the SMA, AND certification by Electrical Safety regulator are required before the RCM can be used. In fact, all parts of AS4417 relevant to a product must be complied with before the RCM can be applied. Both these marks can only be used in Australia with the permission of the Spectrum Management Agency. Pro Formas for application to use the marks are obtained from: Manager, Radio Communications Standards Spectrum Management Agency, PO Box 78 , BELCONNEN ACT 2616 Fax: +61 6 253 2424 Or down loaded from the SMA web site, URL: http://www.sma.gov.au Details on the EMC Framework for Australia may be obtained from the SMA website listed above, specifically http://www.sma.gov.au/spectrum/comply/emc/index.htm or by fax or E-mail (email@example.com) to the SMA. Information on Australian/NZ EMC standards and Framework is also available at: http://www.aedc.com.au/emc Questions and Answers # ~~~~~~~~~~~~~~~~~~~~~ # Following are excerpts from a letter received by Douglas Scott, principal # compliance engineer at ECRM Inc <firstname.lastname@example.org> from David Brumfield, # Assistant Manager of the Radiocommunications Standards section of the # Australian Spectrum Management Agency. # # Question #1 # Who is considered the Australian Importer or Australian Agent? Our dealer # who may or may not have an office in Australia? The first customer who # buys one of our products? Could this be one of our employees in our Hong # Kong or United Kingdom offices? To my knowledge, we do not delegate # authority for anyone to act as our representative except in the case of # selling our products. # # Answer #1 # "In accordance with the EMC requirement any person of company who imports a # product whether by direct mail, sea container or air cargo and that product # is intended for sale in Australia, that person or company is the importer # and the product is subject to the EMC compliance requirements. # # On this point do you envisage individuals or companies bringing into # Australia your product for their own use? If the product is brought into # Australia by a single customer and is not intended for sale on the open # market here then the product is exempt from the EMC framework." # # Question #2 # What if we do not have anyone resident in Australia? Who is it that must # "hold the Declaration"? # # Answer #2 # "The agency does not insist that you have somebody resident in Australia. # The onus for responsibility for placing a product on the market is on the # importer. You may assist this importer by providing sufficient information # to support a declaraion of conformity with the standard by the importer." # # Question #3 # Is our Declaration issued for the CE Mark an acceptable substitute for an # Australian version? Would it be if we added the reference to AS/NZS # 3548:1995 to our existing declaration? # # Answer #3 # "The declaration of conformity must be in the Australian format and be # signed by a responsible person resident in Australia." # # Question #4 # Our existing certification label contains our name and address along with # the CE and CSA marks as well as the appropriate safety information. Is # that acceptable for the labeling requirements? # # Answer #4 # "The existing labelling would not meet our requirements and would be # deficient in important information such as the C-Tick mark and the identity # of the importer. This agency requires that information for the # traceability of the product and its importer, particulalry at the time of # audit of an importer's compliance folder. The legal information relating # to this requirement can be accessed on our web page." # # Question #5 # Is the use of the C-TICK marking mandatory or optional? # # Answer #5 # "The use of the C-Tick is mandatory for products placed on the Australian # market." # # Question #6 # How do I deal with private label products? We have arrangements with # several other companies that sell our products under their own labels. # Sometimes the certification label I apply has our name on it and sometimes # the label carries the name of the private label company. In both cases we # may ship direct to the end-user. # # Answer #6 # "If the product is shipped direct to the end user and is not intended for # sale on the open market then that product is exempt from the EMC framework. # However, if it is sold at a later stage the product will need to be # labelled, and the end user becomes the importer and he would be required to # establish a compliance folder. See point 1." # # Question #7 # If necessary, will you issue a "Supplier Number" to our company in the USA # and allow the Declaration to be held here at the main office with copies # held in the UK and/or Hong Kong? # # Answer #7 # "A supplier code can not be issued directly to an overseas company. If the # overseas company has an Australian office or Australian subsidiary # domiciled in this country the supplier code would be issued to that company # or independent importer in Australia. The declaration would need to be # signed by the Australian connection and be made available when requested # within 10 days of the request." # # Question #8 # Would you please send me a complete copy of your handbook on the EMC # Framework for Residential, Commercial and Light Industry? # # Answer #8 # "Full information about the EMC framework can be found on this agency's web # page http://www.sma.gov.au/. A hard copy of the"Information to Suppliers" # is enclosed." # # # New Zealand ~~~~~~~~~~~ In New Zealand, the regulations class equipment into levels, 0 being low- risk products, 1 being most other products except transmitters. Declarations for level 1 must be lodged including a fee with the Ministry. Labelling for EMC compliance is voluntary in New Zealand, Declarations are mandatory. Where labelling is used, the C-tick mark and the RCM mark as listed for Australia are acceptable, however the requirements for using the mark are slightly different. Contact: Senior Technical Officer (Regulatory) Communications Division, Ministry or Commerce PO Box 2847, Wellington, NEW ZEALAND Fax: (64)04-473 2489 Further information may be obtained from the New Zealand Government website, and specifically from the following documents: http://www.govt.nz/comms/rsm/pib18.html - For general information. http://www.govt.nz/comms/rsm/rfs50.html - For Standards. In the UK, information about Australia and New Zealand can be provided by Ian Clasper, GAMBICA, Westminster Tower, 3 Albert Embankment London SE1 7SW Tel: 0171 793 3050 Fax: 0171 793 7635 email: email@example.com URL: http://www.gambica.demon.co.uk 1.11 Official & Quasi-official Advice ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ UK DTI (Department of Trade & Industry): Business in Europe Hotline 0117 944 4888 (for EMC Information Packs, LVD Booklet etc) DTI Guidance Notes on the EMC Regulations http://www.cix.co.uk/~approval/dtiemc1.htm Electrical Equipment (Implementing the LVD) Guidance Notes on the UK Regulations July 1995 http://www.cix.co.uk/~approval/lvdgd.htm CE/EMC CLUBS - UK Scotland: Paisley 0141 848 3415 N. Ireland: Lisburn 01846 623 102 England/Wales: Sunderland 0191 515 2000 Salford 0161 278 2700 firstname.lastname@example.org York 01904 434 440 email@example.com Pontypridd 01443 482 482 firstname.lastname@example.org Birmingham 01527 595 066 Derby 01332 661 461 X3246 Swindon 01793 783 137 email@example.com Oxford 01865 784 888 Hemel Hemp'd 01442 230 442 Basingstoke 01256 851 193 firstname.lastname@example.org Leatherhead 01372 367 029 email@example.com Canterbury 01227 763 414 Liverpool 0151 231 2052 nowrec@Livjm.ac.uk Helpline for the South East 0990 168 186 fax 01372 374 074 Automotive 01203 348 541 firstname.lastname@example.org CE MARKING - ADVICE FROM BEAMA Third Edition, February 1996 L10.00 (non-members), L6.00 (members) BEAMA, Westminster Tower, 3 Albert Embankment, London SE1 7SL, UK Telephone: +44 (0) 171 793 3035 Fax: +44 (0) 171 793 3054 CE MARKING ON POWER SUPPLIES - Guidance from the EPSMA Available free of charge from Matthew Towers - EPSMA Secretariat The European Power Supply Manufacturers Association Belgrade Centre, Denington Road, Wellingborough, Northants NN8 2QH, UK Telephone: +44 (0) 1933 44 22 02 Fax: +44 (0) 1933 44 22 40 email: email@example.com This document is now also available at http://www.lyons.demon.co.uk/epsma.html EUROPEAN LEGISLATIVE REQUIREMENTS FOR THE MARKING OF MEASURING INSTRUMENTS Free from The National Weights and Measures Laboratory (NWML) Department of Trade and Industry, Stanton Avenue, Teddington TW11 0JZ, UK. Tel: +44 (0) 181 943 7214 Fax: +44 (0) 181 943 7270 email: firstname.lastname@example.org [See also details of NWML Home Page above] "WORLD ELECTRICITY SUPPLIES" Available from BSI (+44 (0) 181 996 7000) under reference TH20338, for L21. It... "Gives supply sources and household, commercial and industrial voltage, voltage tolerance and frequency for over 200 countries worldwide. Also available as a wall chart (TH20329). *** CONTINUED - PART 2 *** --------------------------------------------------------------------------- E&OE: please post corrections/additions to sci.engr.electrical.compliance or email to Bill@lyons.demon.co.uk or email@example.com ---------------------------------------------------------------------------
Supersedes: <firstname.lastname@example.org> # Last Posted: Thu, 15 May 97 15:21:02 GMT # URL: http://world.std.com/~techbook/compliance_faq.html textfile: http://www.lyons.demon.co.uk/seecfaq2.txt FAQ: SOURCES OF EMC AND SAFETY COMPLIANCE INFORMATION - PART 2 First posted: April 17, 1996 Fifteenth issue: June 15, 1997 # CONTENTS - PART 1 ~~~~~~~~~~~~~~~~~ 1.1 Introduction 1.2 Journals devoted wholly or mainly to EMC and safety compliance 1.3 Conferences and Exhibitions 1.4 Listservers 1.5 WWW Sites 1.5.1 Non-commercial 1.5.2 Commercial Web sites carrying useful EMC/safety information 1.6 Standards Organizations 1.7 Specifications for Safety and EMC Compliance 1.8 Books and Guides 1.9 CE Mark 1.10 Australia and New Zealand 1.11 Official & Quasi-official Advice CONTENTS - PART 2 (THIS PART) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 2.1 The sci.engr.electrical.compliance newsgroup 2.1.1 Background and History 2.1.2 Charter and Rationale 2.1.3 Guidelines 2.2 European Voltage Harmonisation 2.3 Commonly-asked Questions and Answers about the EMC Directive 2.4 The Low Voltage Directive (LVD) Acknowledgments 2.1 The sci.engr.electrical.compliance newsgroup ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ 2.1.1 Background and History ~~~~~~~~~~~~~~~~~~~~~~ The desire for a Usenet newsgroup devoted to "compliance" matters such as EMC and safety relative to electrical and electronic equipment had been expressed by a number of posters to various newsgroups. As part of the reorganization of the sci.electronics.* heirarchy carried out by Mark Zenier <email@example.com>, he had prepared a draft Request for Discussion (RFD), and this became the basis for the establishment of s.e.e.c This is the FAQ for the sci.engr.electrical.compliance newsgroup. It supersedes the "Pre-FAQ: Sources of EMC & Safety Compliance Information" which was posted to sci.physics.electromag monthly from January 15, 1996 until April 4, 1996 pending the establishment of the s.e.e.c newsgroup. Since some newsreaders have difficulty with articles approaching or exceeding approx 64k in length, this FAQ has now been divided into two parts. This is Part 2. This FAQ was created by, and is currently maintained by, Bill Lyons <Bill@lyons.demon.co uk> or <firstname.lastname@example.org>, who welcomes suggestions for additions or amendments. It will be posted to s.e.e.c approximately monthly, with pointers in the following related newsgroups: sci.electronics.misc sci.electronics.design sci.engr.electrical.sys-protection sci.physics.electromag alt.engineering.electrical and the following mailing lists: email@example.com firstname.lastname@example.org The latest issue of this FAQ is archived at: http://world.std.com/~techbook/compliance_faq.html PLEASE ADVISE CORRECTIONS OF ANY ERRORS YOU MAY DETECT, OR SUGGESTIONS OF ADDITIONAL USEFUL INFORMATION, AS INDICATED AT THE END OF THIS FAQ. N.B. A hash mark (#) in the right-hand margin indicates new or modified information since the previous issue. 2.1.2 Charter and Rationale ~~~~~~~~~~~~~~~~~~~~~ The following is extracted from the RFD (Request for Discussion) and the successful CFV (Call for Votes) which resulted in the official creation of s.e.e.c on 17th April 1996:- Newsgroups line: sci.engr.electrical.compliance - Laws, regulations and design for EMC, safety. CHARTER: sci.engr.electrical.compliance Discussions on the laws, regulations, and safety approval procedures governing the production, design and marketing of electronic and electrical equipment, and the engineering techniques used to comply with them. RATIONALE: sci.engr.electrical.compliance Discussions on how to manufacture electronic equipment that has to meet the various government regulations are occuring in several different newsgroups (sci.electronics.misc, sci.physics.electromag, alt.engineering.electrical) and various persons have expressed the desire to have a common location. (There is large interest in Europe and with companies who export to there due to recent European Union regulations.) The name is derived from the common name of this subfield of electrical engineering, compliance engineering. 2.1.3 Guidelines ~~~~~~~~~~ This is an unmoderated newsgroup and in the interests of participants it is hoped that the following guidelines will be agreed by users: 1. This is a technical discussion newsgroup with subscribers using many heterogeneous operating systems and platforms. All postings should be in plain ASCII text, and on-topic relative to the charter and rationale of the newsgroup. (It is helpful if you wrap text at about 70 characters/line, so that it may be moderately quoted without exceeding 80 characters.) 2. Exceptionally, if you feel you must post short binaries, such as small schematics, diagrams, etc, they should be in compressed format (e.g. TIFF, JPEG or postscript) not exceeding 10k. Long binaries/graphics and long program files must NOT be posted. Please arrange for them to be available at an ftp or Web site. A short announcement describing the nature of the material and giving the URL where it may be accessed is welcome. 3. Announcements of conferences, seminars, courses, exhibitions and meetings devoted wholly or mainly to compliance matters and related products are welcomed and encouraged, as are short announcements of new books and guides. 4. Commercial announcements or "plugs" for products are not appropriate, but short announcement of the URLs of commercial Web sites carrying details of products related to the purposes of the newsgroup are acceptable. A specific recommendation of a particular product as a solution to a problem is acceptable. 5. Short announcements of job vacancies in the compliance/EMC/safety area are acceptable. Postings of CVs are NOT acceptable. 6. Normally, postings should be signed. However, it is recognised that there may be legitimate reasons for on-topic postings via anonymous remailers, e.g. if a matter is commercially sensitive. 2.2 European Voltage Harmonisation ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ The nominal European voltage is now 230V 50 Hz (formerly 240V in UK, 220V in the rest of Europe) but this does not mean there has been a real change in the supply. Instead, the new "harmonised voltage limits" in Europe are now: 230V -10% +6% (i.e. 207.0 - 243.8V) in most of Europe (the former 220V nominal countries), and 230V -6% +10% (i.e. 216.2 - 253.0V) in UK (former 240V nominal). This is really a fudge and means there is no real change of supply voltage, only a change in the "label", with no incentive for electricity supply companies to actually change the supply voltage. To cope with both sets of limits an equipment will therefore need to cover 230V +/-10% i.e. 207-253V. This will actually become the official limit for the whole of the EU in 2003. 2.3 Commonly-asked Questions and Answers about the EMC Directive ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ Frequently-asked questions and answers by Brian Jones, EMC Consultant to Nutwood UK Limited, publishers of the EMC '97 Reference Handbook & Directory, Edition 2. http://www.emc-journal.co.uk. The following information is believed to be correct at the time of going to press (April 1997). It is not possible to cover individual circumstances in general answers such as these, and caution should therefore be exercised in the use of this information. Any changes to these answers due to changed circumstances, legal precedents or changes to Commission or national guidelines will appear in the updates. Q1. Is Due Diligence tempered by cost? A1. The DTI has published a document entitled "Minimising the cost of meeting the EC Directive on Electromagnetic Compatibility (EMC) 89/336/EEC as amended by EC Directive 92/31/EEC." The second edition was published towards the end of 1995, and is available from the DTI. It is also reproduced in the EMC Handbook. This document sets out the minimum actions required to meet the legislation. It has also been suggested that courts may take account of the value of the product, or size of the company, in judging a case. The manufacturer should satisfy himself that he has taken all reasonable steps. It would be sensible to carry out periodic emission testing if only one sample was tested initially. The manufacturer takes sole responsibility for his products' performance, and must be prepared to justify the actions he has taken (or not) to the enforcement authorities. Q2. How long can non-compliant goods in stock at the end of 1995 be offered for sale? Can such goods cross borders between Member States? A2. There is no time limit in the UK, but the majority of other Member States will not allow non-compliant stock to be sold after the end of 1996. The situation in other Member States is described in the section on legislation across Europe. Whatever the stated position of the enforcement bodies in different Member States, it will become increasingly difficult to move non-compliant goods, and it is likely that proof of date of manufacture will be required. Q3. Is military equipment excluded in all Member States? A3. Military equipment (apparatus designed for use as arms, munitions and war material within the meaning of Article 223.1(b) of the Treaty of Rome) is excluded from the UK Regulations provided it does not have an alternative non-military use. The laws are not identical in all Member States of the EEA. The EMC Handbook will identify those where compliance with the EMC Directive is not excluded. Military equipment which finds its way onto the open market (as surplus goods, for example) may be caught by the UK Regulations since it would no longer have a purely military use. Q4. Who signs the Declaration of Conformity when the manufacturer is outside the EEA? A4. The manufacturer may sign the Declaration of Conformity whether he is located inside or outside the EEA. If outside the EEA, then the certificate must identify the person within the EEA who is responsible for placing the apparatus on the EEA market. It is this person who must hold the Declaration of Conformity at the disposal of the Competent Authorities. A manufacturer outside the EEA may delegate his authorised representative within the EEA to issue the Declaration of Conformity and affix the CE Mark. Supply to an authorised representative does not come within the scope of the Regulations. Q5. Who is an authorised representative? A5. Someone, or a company, empowered by the manufacturer to act on his behalf. For his own due diligence, he should be satisfied that the information provided is sufficient to enable him to issue the Declaration of Conformity, and that he is able to bind the manufacturer to commitments. It is unlikely that an organisation that simply imports goods would have the contractual position to act as an authorised representative. Q6. What constitutes an excluded installation? A6. In the UK, excluded installation means two or more combined items of relevant apparatus or systems put together at a given place (whether or not in combination with any other item) to fulfil a specific objective, but not designed by the manufacturer(s) for supply as a single functional unit. In effect, an excluded installation is a collection of compliant apparatus. Thus a large installation supplied as a single unit is not excluded, whereas one supplied by a number of manufacturers is outside the scope of the UK Regulations. An example would be a production area in a factory comprising a number of stand-alone process stations each supplied by a different manufacturer, for printed board populating, flow soldering, ultrasonic welding, etc. Each process station would need a Declaration of Conformity in its own right, but the production area as a whole would not. Interpretations may differ in other Member States. Q7. How can large systems be declared compliant? A7. A large installation supplied by a single manufacturer may be considered a system and comes within the scope of the Directive. Only one published European standard has so far addressed this issue (ETS 300 127 for large telecommunications equipment) and this is not harmonised. Such systems could be declared compliant via the Technical Construction File Route. Recent draft guidance from the Commission suggests that if the individual parts of the system are themselves compliant relevant apparatus, and if the system is installed in accordance with the manufacturer's instructions, this could be considered sufficient for the standards route. It is for the manufacturer to assess the risks in deciding the most appropriate course of action. Q8. What constitutes a sub-assembly? A8. Recent draft guidance from the Commission has clarified the definition, and items which are designed, manufactured and intended to form part of an item of apparatus do not have to comply with the Directive (only the finished product must so do). If, however, the item would perform a direct function for an end user, and is placed on the market, then it is covered by the requirements of the Directive. A direct function is defined by the Commission as any function of the component itself which fulfils the intended use and which is available without further adjustment or connections other than simple ones which can be performed by any person not fully aware of the EMC implications. Q9. With contract manufacturing, who is responsible for the Declaration of Conformity? A9. This should be a contractual matter to be agreed between customer and supplier. The authorities seem to have a relaxed attitude about who issues the Declaration of Conformity providing the declaration is produced. Recent draft guidance from the Commission suggests that a manufacturer may subcontract design if he produces the product, or subcontract production if he is responsible for the design and EMC performance, without compromising his manufacturing status. Logically, the organisation taking responsibility for the design and performance of the product should be responsible, but they will need to demonstrate (via Quality Management Systems or otherwise) that they have control over the manufacturing process as if the they were manufacturing the product themselves. Q10. Is a custom-made one-off item "placed on the market"? A10. The UK Regulations make use of the concept of supply rather than placing on the market, which makes the position clearer. Even one-off items are covered by the Directive, when they are supplied for an end user. Q11. Is reconditioned second-hand equipment covered? A11. If the EMC performance of the product is unaffected, it may be considered second-hand, and the EMC Directive does not apply. If in the process of reconditioning, the EMC characteristics are changed to a material degree then the reconditioner becomes a manufacturer and therefore responsible for compliance with the Directive. If the EMC performance is improved from the original, then no further action is necessary. Q12. Can compliance with more than one Directive be stated on one Declaration of Conformity? A12. Yes, providing all the relevant information is given for each Directive, including the year of manufacture for certificates declaring conformity to the Low Voltage Directive. Q13. Do software upgrades affect the validity of the CE Mark? A13. There has been much debate on this subject, and the consensus to date suggests that software changes should be considered in assessing whether a re-evaluation for EMC is necessary. From an emissions perspective, the equipment should have been exercised to a maximum extent, possibly by the use of a special program. Analysis may show that the new software does not exercise the equipment to a greater extent than that tested originally. However, changes in software can affect susceptibility, particularly to transients. Q14. What degradation of performance is acceptable for immunity testing? A14. The manufacturer may state this in the user documentation, providing the degradation is acceptable and would not compromise safety. If no statement is made, then in cases of dispute, the performance that a user would reasonably expect will be used. Q15. Does an assembly of CE Marked sub-assemblies make for a compliant product? A15. Not necessarily. There are sound technical reasons why this should be so. The final manufacturer takes responsibility for the EMC performance of the completed product. Q16. What is the responsibility of an installer? A16. If the installer is not the supplier, he should carry out the installation in accordance with the manufacturer's instructions. Q17. How do I decide if a printed wiring assembly should be CE Marked or not? A17. Boards intended for an end user should carry the CE Mark, backed by a Declaration of Conformity. Boards which are intended only to form part of another system, and intended to be incorporated into a finished product need not be marked, as they are components, and outside the scope of the Directive. Q18. What do I have to do if I sell personal computers after fitting an extra card to them? A18. When this is done, the person carrying out the act performs the final stage of manufacture of the product as supplied to the end user, and therefore takes responsibility for the EMC performance of the whole. The assembler should request details of the assessment carried out on the plug-in card from the manufacturer of that product. The Directive does not require testing to be performed, and assuming the basic computer and the cards are CE Marked, the assembler may be satisfied with some simple derived tests to satisfy himself that the final product remains compliant. This may not sufficient if the assembly consists of a larger number of modules fitted to a box containing only a power supply or power supply and mother board. Q19. Can a user upgrade a non-compliant product which was taken into service before 1996? A19. The modified product will be taken into service by the user. If the EMC performance has been altered by the upgrade, the user will be responsible for the product meeting the protection requirements of the Directive (but does not need to meet the requirements for supply). Q20. Do control panels need a CE mark? A20. If they are sold to an end user for him to integrate into a system, yes. If they are sold only to a machine builder who assembles the final product, no. Q21. How can I show due diligence when assembling products and systems from CE marked sub-assemblies or apparatus? A21. It is difficult to offer general guidance here as different measures will be needed for the wide variety of possible situations. A computer system assembled from finished products (i.e. keyboard, mouse, monitor and completed box containing boards, disc drives and power supply) may need no further assessment; there is only one way these can be interconnected and they will have been assessed as completed products by their manufacturers. A machine consisting of PLCs, motor drives, encoders, sensors, etc. may require a full assessment. Q22. Is all laboratory equipment covered by the educational relaxation? A22. No. In the UK, only equipment which would not, except for the provisions of Regulation 8, comply with the protection requirements under normal conditions of use, and which is used in education and training establishments for the purposes of experimentation, learning or practical training, is covered by the modified application of that Regulation. Test apparatus, designed or adapted to generate or be susceptible to electromagnetic disturbance is covered by the modified application of Regulation 9, and must not create disturbances outside the immediate electromagnetic environment of the apparatus. Q23. Does the signatory of the Declaration of Conformity go to jail if the product is shown to be non-compliant? A23. Not all offences under the UK Regulations could result in custodial penalties. Only Regulations 83 (contravention of a prohibition or suspension notice), 84 (giving false or misleading information) and 86(2) (impersonating an officer of an enforcement authority, have this penalty. To date, no-one has been sent to jail in the UK for infringement of a New Approach Directive. It is possible that this could happen at some time in the future for a very serious breach of regulations, but this is complex issue of employment law, and is beyond the scope of these answers. Regulation 89 provides further information. Q24. What happens when the signatory leaves the company? A24. The certificate is still valid, but signatory can no longer be held responsible for the actions of the company he has left. Q25. Are products which have previously been used by an end user outside the EEA, or by the manufacturer or wholesaler, considered second-hand? A25. No. To be considered second-hand under the EMC Directive, products must have been previously used by an end user within the EEA. Q26. If an end user imports a product directly from a country outside the EEA for his own use only, does the product require a CE Mark? A26. Latest thinking from the enforcement authorities is that the end user takes the product into service, and is therefore ensuring that the product complies with the protection objectives of the directive, but no assessment, Declaration of Conformity, or CE Mark is required. The product has not been supplied within the EEA. Q27. Which directive applies to products intended for use on forklift trucks? A27. These do not come under the automotive or agricultural directives, and the EMC Directive applies. Q28. What is the position with loudspeakers? A28. Passive loudspeakers consisting of moving coil units and passive crossovers inside a cabinet are benign electromagnetically, although it is understood that in Germany the CE Mark is required, and there may be other countries where the products cannot be sold without the mark. The large permanent magnet of loudspeaker units can affect TVs and monitors when in close proximity (unless magnetically-shielded) and this should be covered in the instructions for use. Q29. Are quartz wristwatches covered by the regulations? A29. No, they have been exempted by common agreement of Member State Competent Authorities. Q30. Are there any requirements for instructions for use to be in the language of a Member State? A30. The requirement for products to be supplied with instructions for use is contained within the Directive in Annex III, but recent guidance from the Commission has placed greater stress on the need for such instructions. Regulation 5(6) applies in the UK. It would seem logical that if there must be instructions for use, the user must be able to understand them. The DTI has indicated that products supplied in the UK must have instructions in English; it would be expected that of Member States would insist on similar provisions. Q31. When can a standard be used for self-certification under the standards route? A31. When it has been harmonised, i.e. it has been published by CENELEC or ETSI and transposed into a national standard in at least one Member State and it had been listed in the Official Journal of the European Communities. Note that to use this route, the harmonised standard(s) applied must make a complete provision, i.e. they must cover all aspects of emission and immunity. Q32. Where can I examine the standards? A32. Most central reference libraries hold copies of British Standards, which includes BS implementation of European Norms. Those with access to university or other academic institution libraries may also find copies there. Some libraries hold copies as microfiche which is not so easy to read. Members of the British Standards Institution and BSI committee members may use the BSI library in Chiswick free of charge (prior booking necessary) but a charge is made for non-members. BENIGN APPARATUS This is "apparatus" as described in Regulation 7(2), but is excepted from the requirements by Regulation 17. Benign apparatus is therefore not "relevant apparatus". Regulation 36(6) prohibits the affixing of the CE Mark for EMC to any apparatus which is not relevant apparatus. A CE Mark applied to such apparatus would therefore be technically in breach of Regulation 85(1)(b). It is understood that the DTI has a relaxed view of this, providing the marking is not materially wrong. There are, however, possible other problems with the affixing of the mark to such apparatus, under the Trade Descriptions Act (see below). COMPONENTS AND SUB-ASSEMBLIES INTENDED FOR FURTHER MANUFACTURING Although many words have been written on this subject (including articles in the EMC Journal) a closer examination of the wording of the Directive and the UK EMC Regulations has resulted in an amendment to the advice. Components and sub-assemblies are not "apparatus" and are not covered in the Directive or the UK Regulations. It follows therefore, that there is no offence in the EMC Regulations for affixing the CE Mark to these items. However, by adding a CE Mark, a manufacturer is adding a trade description. If the item were shown in some way to be not in conformity with the protection requirements of the Directive, then the CE Mark could constitute a "false and misleading statement" and therefore constitute an offence under Section 1 of the Trade Descriptions Act 1968. Although there would be a technical breach, it is possible that no action would be taken unless the description was false to a material degree. If the item was shown to be the cause of relevant apparatus causing interference or suffering a suscepibility problem, or indeed failing an EMC test, then a complaint could lead to a prosecution under the Trade Descriptions Act. By affixing the mark, therefore, the component or sub-assembly manufacturer has possibly taken on liability for the EMC performance of his product. As components and sub-assemblies are not required to meet the EMC Regulations, if they were not marked, there would be no offence, even if they were shown to be the cause of an EMC problem as described above. The advice from the DTI and the TSOs continues to be that components and sub-assemblies should not be CE Marked for EMC. 2.4 The Low Voltage Directive (LVD) ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~ (a) A note from Alan M Hudson <email@example.com> I'm not an expert on the LVD, but for what it's worth, I'll put down what I believe to be correct (but may not be !!): Yes - the LVD has been around since 1973, and is therefore in force now (so you probably meet it now), but the CE marking requirement only came into play on 1 Jan 1997. It applies to equipment operating in the 50 - 1000 Vac or 75 - 1500Vdc. The only route to conformity is "Self Declaration" to either Harmonised standards (in the OJ), or if not relevant/available, then to International standards, or if also not relevant/available, then to National standards. There are some product-specific Harmonised standards around - EN60950 for ITE, and EN60065 for domestic equipment. The compilation of a "Technical File" is mandatory, I believe (as opposed to the EMC "Technical Construction File" which is only needed for the TCF route to compliance). You may want to check out http://www.ktl.co.uk/ktl/cemark.htm and http://www.safetylink.com especially http://www.safetylink.com/lvd.asc (The last contains the full text of the Low Voltage Directive - Council Directive 72/23/EEC of 19 February 1973). (b) From Gerry McMahon, National Electronics Test Centre, Dublin, Ireland <firstname.lastname@example.org>: Subject: Are you ready for the EU Low Voltage Directive ? The EU Low Voltage Directive (LVD) will be mandatory from 1st January 1997. In an effort to inform manufacturers of electrical and electronic equipment on the scope of the LVD, the National Electronics Technology Centre (NETC), Forbairt [http://www.netc.ie/] maintains a Frequently Asked Questions (FAQ) page on the LVD at: http://www.netc.ie/lvdfaq.htm Contact Person : Jackie Fitzgerald at NETC [email@example.com] ACKNOWLEDGMENTS ~~~~~~~~~~~~~~~ The s.e.e.c FAQs could not have been prepared without the much appreciated help and advice of many people. If I have omitted anyone from the following list, please accept my apologies. Paul E Bennett firstname.lastname@example.org Eckard Blumschein email@example.com Ian Clasper firstname.lastname@example.org Kristin Eckhardt email@example.com Andy Gulliver firstname.lastname@example.org Chris Healy email@example.com Dr. Todd Hubing firstname.lastname@example.org Alan Hudson email@example.com Alan E Hutley firstname.lastname@example.org Mark Jurgen email@example.com Eric Lifsey Eric.Lifsey@natinst.com Mirko Matejic firstname.lastname@example.org Ross McKay email@example.com Adrian McLeod firstname.lastname@example.org Gerry McMahon email@example.com Art Michael firstname.lastname@example.org David Patton email@example.com David Perlmutter Dave_Perlmutter@3mail.3Com.COM Roger Prenger firstname.lastname@example.org John Quinlan email@example.com Martin Rowe firstname.lastname@example.org Rene Schmit email@example.com Douglas Scott firstname.lastname@example.org Dr John Stockton email@example.com Jeremy Turner Jeremy@srscomp.demon.co.uk Frank Warner firstname.lastname@example.org Tim Williams email@example.com John Woodgate firstname.lastname@example.org --------------------------------------------------------------------------- E&OE: please post corrections/additions to sci.engr.electrical.compliance or email to Bill@lyons.demon.co.uk or email@example.com ---------------------------------------------------------------------------
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