Hi Tom -

Right - if the installer installs the product NOT according to directions,
then any interference is his problem. But if the installation is done
according to the manufacturer's instructions and causes interference, then
it is likely the manufacturer will bear some or all responsibility.

Of course, the installer/user still will be asked to cease operation if the
interference is causing a problem. The argument "The manufacturer said it
was OK!" will not convince authorities to allow operation to continue if
there is a significant problem.

Best regards,
John McBain


On Sat, Feb 18, 2023 at 6:14 PM T.Sato <[email protected]> wrote:

> On Sat, 18 Feb 2023 11:07:01 -0800,
>   John Mcbain <[email protected]> wrote:
>
> > Absolutely, the requirement is "... it complies with this Directive when
> > properly installed, maintained and used for its intended purpose."  But
> > what is "it"?
> >
> > I maintain that "it" is the product that is tested and sold, not all the
> > possible final configurations in which combinations of "it" might be
> > found.
>
> Assume a product that is clearly intended to be installed and used with
> tens of the same model of the product.
> If the product is installed and used as intended and caused interference,
> although with other tens of same model of the product, isn't it caused
> the interference?
>
> > The final installer/user, not the manufacturer, would be responsible for
> > whatever interference might be caused by the in-use combination of
> multiple
> > units of compliant products UNLESS the manufacturer sells that
> combination
> > as a product.
>
> The EMC Directive require to provide instruction neessary to comply
> with the essential requirements.
>
> If installer didn't follow the provided instruction and caused
> interference problem, I think the installer is responsible.
>
> However, if the installer follow the provided instruction if any
> (and electric code, if applicable) but still caused interference
> problem, the installer (maybe end-user himself, who is probably layman
> at least for EMC) still responsible for that?
>
> Regards,
> Tom
>
>
> > On Sat, Feb 18, 2023 at 2:13 AM T.Sato <[email protected]> wrote:
> >
> >> On Fri, 17 Feb 2023 21:12:40 -0800,
> >>   John Mcbain <[email protected]> wrote:
> >>
> >> > The key is testing the <product>.  If all the light bulbs in your
> house
> >> and
> >> > the connecting wiring was sold as a single product, then presumably it
> >> > would have been tested for EMC in that configuration.  I doubt that is
> >> what
> >> > happened.  😆
> >>
> >> Well, standards usually require to test product, in a representative
> >> or minimum configuration.
> >>
> >> However, in case of the EMC Directive, it requires "... it complies
> >> with this Directive when properly installed, maintained and used for
> >> its intended purpose."
> >>
> >> If if is considered that to install tens of LED lights in a house is
> >> covered by the "intended purpose", shouldn't the LED lights still
> >> comply with the essential requirements of the Directive in that
> >> configuration, too?
> >>
> >> Regards,
> >> Tom
> >>
> >>
> >> > On Fri, Feb 17, 2023 at 6:56 PM Ken Javor <
> [email protected]>
> >> > wrote:
> >> >
> >> >> I’m finding this an extremely interesting discussion. I don’t have
> >> >> anything definitive to offer, but I do have a question to help stir
> the
> >> pot.
> >> >>
> >> >> If the possibility that multiple items might be used together and
> that
> >> >> emissions will be additive in some fashion is a justification for
> >> testing
> >> >> multiple units at a time, what about ... light bulbs?
> >> >>
> >> >> Meaning CFLs or LEDs.
> >> >>
> >> >> My house is full of them.  It is reasonable to assume that most
> >> >> homes/businesses are. Perhaps the emissions limits for these were
> based
> >> on
> >> >> this reasonably foreseeable outcome?
> >> >>
> >> >> Ken Javor
> >> >> Phone: (256) 650-5261
> >> >>
> >> >>
> >> >> ------------------------------
> >> >> *From: *John Mcbain <[email protected]>
> >> >> *Reply-To: *John Mcbain <[email protected]>
> >> >> *Date: *Fri, 17 Feb 2023 14:22:44 -0800
> >> >> *To: *<[email protected]>
> >> >> *Subject: *Re: [PSES] Adding more than one EUT
> >> >>
> >> >> Hi Derek -
> >> >>
> >> >> Typical requirement for a unit that may be sold and used in multiples
> >> >> (that is, all the units can be sold together as one product) is you
> can
> >> >> test just one IF adding the other units does not increase the
> emissions.
> >> >>
> >> >> Of course the most practical way to determine that is to assemble the
> >> >> multiple units to see what happens.  If the test result for testing
> max.
> >> >> connected units compared to testing only one unit shows no
> significant
> >> >> difference, then you're good - but definitely archive those test
> >> results!
> >> >>
> >> >> If you can't pass the test with all units connected, then whatever
> you
> >> do,
> >> >> don't let Marketing create a multiple-unit product to sell.  ;-)
> >> >>
> >> >> Similarly, the desktop PC system that James mentioned would have all
> >> power
> >> >> cords separately tested for conducted emissions as a fully connected
> >> system
> >> >> (monitor, printer, scanner, etc. attached) if it is a  product sold
> as a
> >> >> complete all-included system.
> >> >>
> >> >> Best regards,
> >> >> John McBain
> >> >>
> >> >>
> >> >> On Fri, Feb 17, 2023 at 1:59 PM James Pawson (U3C) <
> >> >> [email protected]> wrote:
> >> >>
> >> >>
> >> >> Hi Derek,
> >> >>
> >> >>
> >> >> Is the daisy chain connection the AC supply or some other power bus?
> >> >>
> >> >>
> >> >> How is 8 units daisy chained any different to 8 separate units all on
> >> the
> >> >> same power bus? We are looking for individual emission contributions
> >> from
> >> >> each connected unit.
> >> >>
> >> >>
> >> >> If measuring conducted emissions on a desktop pc (y'know, the big
> ones
> >> we
> >> >> had before everyone had laptops to work from home...) the you would
> just
> >> >> measure the PC, not the monitor and printer and scanner and modem and
> >> and
> >> >> and...
> >> >>
> >> >>
> >> >> Just thinking aloud
> >> >>
> >> >> All the best
> >> >>
> >> >> James
> >> >>
> >> >>
> >> >> ---- Lfresearch wrote ----
> >> >>
> >> >> Hi folks,
> >> >>
> >> >>
> >> >>
> >> >> I’ve been asked to test a light fixture that has the ability to be
> daisy
> >> >> chained up to 8 units.
> >> >>
> >> >>
> >> >>
> >> >> When I run conducted emissions, I’m wondering if I need to insist on
> >> >> having 8 units plugged in at once i.e. fully populated, OR, can I
> just
> >> test
> >> >> one fixture at a time since that’s how the system is likely to be
> used
> >> >> also..
> >> >>
> >> >>
> >> >>
> >> >> Is there a legal requirement or precedent on how this should be
> tested
> >> as
> >> >> I’m going round in circles arguing with myself here.
> >> >>
> >> >>
> >> >>
> >> >> Thanks,
> >> >>
> >> >>
> >> >>
> >> >> Derek.
> >> >>
> >> >>
> >> >>
> >> >> SSCLabs,
> >> >>
> >> >> Reno, NV.
> >> >>
> >> >> -
> >> >>
> >> >> ----------------------------------------------------------------
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