Path: ...!news.mixmin.net!eternal-september.org!feeder3.eternal-september.org!news.eternal-september.org!.POSTED!not-for-mail
From: Phil Hobbs <pcdhSpamMeSenseless@electrooptical.net>
Newsgroups: sci.electronics.design
Subject: Re: EMC compliance question
Date: Fri, 11 Oct 2024 19:51:00 -0000 (UTC)
Organization: A noiseless patient Spider
Lines: 121
Message-ID: <vebvj4$3pj2t$1@dont-email.me>
References: <67070ba9$1$1783$882e4bbb@reader.netnews.com>
 <ve9e5c$39rmc$1@dont-email.me>
 <dsfggj1a5m9mise9781qmh1roqv3pb68jr@4ax.com>
 <vebshs$3p3c0$1@dont-email.me>
 <m9uigjh5mh3rbiqkkpr660vnmtanf5a15f@4ax.com>
MIME-Version: 1.0
Content-Type: text/plain; charset=UTF-8
Content-Transfer-Encoding: 8bit
Injection-Date: Fri, 11 Oct 2024 21:51:00 +0200 (CEST)
Injection-Info: dont-email.me; posting-host="f12a7012de18d77ddc98c865cadfa02c";
	logging-data="3984477"; mail-complaints-to="abuse@eternal-september.org";	posting-account="U2FsdGVkX1/LI+Ima/Jq9YaHrUUNm+Fz"
User-Agent: NewsTap/5.5 (iPhone/iPod Touch)
Cancel-Lock: sha1:83eLSBd5IQ/3cWokDSLaBVuvBNk=
	sha1:mBC2ywddP6V4aTnVaPGHHQTwvTc=
Bytes: 6494

john larkin <jl@glen--canyon.com> wrote:
> On Fri, 11 Oct 2024 20:59:09 +0200, Klaus Vestergaard Kragelund
> <klauskvik@hotmail.com> wrote:
> 
>> On 10-10-2024 23:11, john larkin wrote:
>>> On Thu, 10 Oct 2024 13:41:07 -0700, Don Y
>>> <blockedofcourse@foo.invalid> wrote:
>>> 
>>>> On 10/9/2024 4:03 PM, bitrex wrote:
>>>>> What's the deal with the "CPU board" exemption?
>>>>> 
>>>>> "CPU board. A circuit board that contains a microprocessor, or frequency
>>>>> determining circuitry for the microprocessor, the primary function of which is
>>>>> to execute user-provided programming, but not including:
>>>>> A circuit board that contains only a microprocessor intended to operate under
>>>>> the primary control or instruction of a microprocessor external to such a
>>>>> circuit board; or
>>>>> A circuit board that is a dedicated controller for a storage or input/output
>>>>> device."
>>>>> 
>>>>> So if one sells a board that has say a PIC on it and some support logic, and
>>>>> the 9kHz+ signals are all internal to the uP (self-clock), but it's otherwise a
>>>>> functionally complete design other than it's not in a housing, is that an
>>>>> exempt product?
>>>> 
>>>> Who is your customer?  If you are selling it as a *product*,
>>>> it is not a *compliant* product so your customer inherits
>>>> no certifications (because there are none).
>>>> 
>>>> If your customer integrates it into *his* product, then
>>>> the responsibility for "product certification" falls on him
>>>> (so, you have saved *yourself* a few pennies on the certification
>>>> process and left him with any "problems" that your board may
>>>> pose to *his* certification).
>>> 
>>> A few pennies for a certified test lab to do full certs?
>>> 
>>>> 
>>>> If you are selling to hobbyists, you *may* be able to get by
>>>> as a noncompliant product (the first case, above) -- so long
>>>> as none of your (few?) customers finds themselves drawing
>>>> the ire of neighbors, etc. when your device interferes with
>>>> their pursuit of life, liberty and happiness.
>>>> 
>>>> But, you are still exposed as the seller of that noncompliant
>>>> product.  How likely will your customers "have your back"
>>>> if things get sticky?
>>>> 
>>>> In the latter case, your customer (integrator) will *likely*
>>>> be thankful for any steps you have taken to certify your
>>>> "component" as he goes about looking for certification on
>>>> *his* composite system.
>>>> 
>>>> Why do you think so many products are sold with El Cheapo,
>>>> off-brand wall warts instead of taking the power supply
>>>> design *into* the overall product?
>>> 
>>> A wart relieves one of all the AC-line safety certifications. There
>>> are some big warts these days, including 48v ones.
>>> 
>> 
>> If your product can power usage is larger than 15W, then you get close 
>> to nothing by using external SELV supply, because then a lot of the 
>> demands on safety are back in play
>> 
>>> One can resell a cheap wart with the usual molded-in (usually fake)
>>> UN/CE/CSA markings, or let the customer buy their own wart.
>>> 
>>> 
>>>> 
>>>> Lastly, it's just "good engineering" -- and great experience -- to
>>>> go through the process so you know what to *avoid* in your
>>>> future designs.  (ditto for safety requirements)
>>>> 
>>>> Increasingly, I am seeing extra scrutiny on devices that CAN "talk"
>>>> to ensure they aren't talking to anyone that they can't *justify*.
>>>> "Why are you phoning home?"  "Why are you initiating HTTP requests?"
>>>> "Why are you trying to resolve some oddball domain name?"
>>>> 
>>>> [These, of course, are a lot harder to "guarantee" without (and
>>>> even *despite*!) releasing full sources.  Especially for OTS/FOSS
>>>> OSs that may have been preconfigured (for your convenience) to
>>>> support services having communications requirements that you
>>>> of which you may be ignorant!]
>>> 
>>> Software certs on top of hardware certs?
>>> 
>>>> 
>>>> Assume your customer is going to need/want to certify his
>>>> use of your device and give him a leg up in that process,
>>>> pre-sale.
>>> 
>>> For a small company making a modest number of some test instrument,
>>> full certs will multiply development cost. That may be why I don't see
>>> a lot of small instrument companies in europe.
>>> 
>>> The guys I was working with in Oxford laughed at me when I asked if
>>> our atom probe system would need to be CE tested. "CE means Cant
>>> Enforce."
>>> 
>> 
>> Some just takes the risks. If you are caught it can be an expensive 
>> risk. On the other hand, I have never heard of a case where the company 
>> went bankrupt. Have heard of large fines, but nothing that killed the 
>> company
> 
> What's crazy is how expensive the CE specs are. I can buy one PDF for
> $600, and it will reference a bunch of others. Recursively.
> 
> These specs have the force of law. It's like being forced to pay to
> know what's legal or not.
> 
> 

With the vast accretion of laws and regulations we’ve seen in the past 30
years or so, we’re all breaking several every day. 

That’s why the rate of guilty pleas is over 98%—they can always get you for
something, and a plea bargain at least shortens the ordeal. 

Phil Hobbs