Technical Guidance Note 8

TOPIC: PC add-on boards

ISSUE: 4

REVISION DATE: 6.11.98

PREVIOUS REVISION DATE: 27.1.98

BACKGROUND: PC add-in boards are available for users to configure their own PC’s. There is a vast number of possible combinations possible for any PC and hence there exists a confusion about the correct application of the EMC Directive to these products.

PROBLEM: Does the EMC Directive apply to PC boards? and, if so, how may conformity be assessed? Which is the correct route to compliance; the self-certification route or a TCF?

GUIDELINES:

Summary: A manufacturer of PC add-on boards can use either the Self-Certification route or the TCF route to demonstrate compliance of his products with the EMC Directive. PC add-on boards require their own declaration of conformity because they are marketed direct to the end-user. The declaration of conformity applies to the board not the system in which it is used; therefore the declaration should cover the variants of the board not the variants of the systems in which it used.

Explanation:

The EMC Directive applies to PC add-in boards if they have a "direct function" for the end user, AND if they are placed on the market as a single commercial unit for distribution or use. An example of a product that meets both these criteria would be a fax/modem card.
The board may be tested in a representative PC system for compliance with the applicable harmonised European standards. A manufacturer may choose to test in more than one PC system (testing in the top 3 - 5 market leaders might be a sensible approach), to give greater confidence in the product and further strengthen a due diligence approach.
The manufacturer must issue an EC Declaration of Conformity for the add-in board, but it is not necessary to have Declarations for each possible system because the Declaration applies to the board, not to the system in which it is used.
Regardless of the number of variants of PC systems in which the board may be installed, it is not necessary to use a TCF. If the applicable harmonised standards have been applied, i.e. if the board has been tested to these standards in a representative PC system or systems and has been found to comply with them, then the 10.1 route has been used and the Manufacturer can issue a Declaration of Compliance. To do so the manufacturer must apply sufficient EMC expertise to be able to state with confidence that the testing completed is sufficient to cover all the variants. Where the manufacturer is not confident to make this judgement he may call upon outside EMC expertise and one option could be to write a TCF and submit it to a Competent Body. If the manufacturer chooses not to apply these standards he must compile a TCF and obtain a report or certificate from a competent body.

Disclaimer
No responsibility or liability can be accepted by the EMC Test Laboratories Association or any of its officers or members for the contents, specifications and/or advice referred to or contained in this Technical Memorandum and/or action taken as a result of information contained in this Technical Memorandum. Note that:
1. The Association is not by supplying this Technical Memorandum providing professional advice or guidance to any specific party on any specific matter and no legal relationship is created by the provision of this Technical Memorandum.
2. Parties should take specific advice when dealing with specific situations and consult their own professional advisors in this regard.
3. Members are free to deviate from the above guidelines where they think it appropriate, unworkable, or not commercially viable. Under these circumstances, the EMCTLA Secretariat should be informed of the reasons for the deviation so that the matter can be reviewed.