TRANSITION RULES AND EMC/EMI/ESD TEST-REPORT RETENTION RULES
This web site is being maintained by John R. Barnes, who was the President
and Chief Engineer of dBi Corporation from 2002 to September 30, 2013,
when we closed because ObamaCrap made it too expensive for us to remain in
business.
John R. Barnes KS4GL, PE, NCE, NCT, ESDC Eng, ESDC Tech, PSE, Master EMC
Design Engineer, SM IEEE
December 19, 2010
jrbarnes@iglou.com
This document briefly summarizes the transition rules that must be followed
when an electromagnetic compatibility (EMC), electromagnetic interference
(EMI), or electrostatic discharge (ESD) standard that pertains to your
product(s) is amended or replaced. It also summarizes the national/
international requirements for retaining the EMC/EMI/ESD test reports for:
United States:
- FCC 47 CFR is published in the Code of Federal Regulations in the early
spring of each year- but only includes revisions up to October 1 of the
previous year. So this published (and downloadable) version will be 6
to 18 months out of date.
- The FCC publishes a new or revised regulation as a "Report and Order" in
the Federal Register. This Report and Order specifies the Effective
Date for the regulation.
- The FCC may also publish a "Public Notice" in the Federal Register
which reaffirms the effective date for the regulation.
- EMC/EMI/ESD records must be kept for 2 years "after the manufacture of
said equipment has been permanently discontinued", or until the
"conclusion of an investigation or proceeding ... involving the
equipment".
Sources:
- http://www.hottconsultants.com/regulations.html
- http://www.access.gpo.gov/nara/cfr/cfr-table-search.html
- http://www.access.gpo.gov/cgi-bin/cfrassemble.cgi?title=200147
- http://www.access.gpo.gov/su_docs/aces140.hmtl
- http://ftp.fcc.gov/oet/info/rules/part15/part15_dec18_01.pdf
- http://www.nad.org/infocenter/newsroom/othernews/fccabcs.html#RO
Canada:
- A standard takes effect at the dates given in section 1 of the
standard.
- The manufacturer must keep EMC/EMI/ESD test reports for at least 5
years.
Sources:
- http://strategis.ic.gc.ca/pics/sf/ices003.pdf
- http://www.i-spec.com/EMC/canada.html
European Union:
- Product or product family specific standards take precedence over
generic standards.
- You may use a standard/amendment once it has been published in the
Official Journal of the European Communities (OJ).
- You must use a standard/amendment after the "Date of cessation of
presumption of conformity" of the superceded standard/amendment.
- You must use a standard/amendment until a standard/amendment that
supercedes it, or has a tighter scope covering your product(s), is
published in the OJ.
- You may use the standard/amendment until it reaches its "Date of
cessation of presumption of conformity".
- The manufacturer or authorized representative must keep the Declaration
of Conformity for 10 years after placing the product on the market.
Sources:
- http://europa.eu.int/comm/enterprise/electr_equipment/emc/index.htm
- http://www.incompliancemag.com/index.php?option=com_content&view=article&id=159:emc-standards-from-a-european-perspective&catid=24:current-issue&Itemid=126
Australia and New Zealand:
- For AS/NZS, CISPR, or IEC standards and amendments adopted by Australia
and New Zealand:
- You may use the standard/amendment as of its date of publication.
- You must use the standard/amendment starting two years after its
date of publication.
- For EN standards and amendments adopted by Australia and New Zealand:
- You may use a standard/amendment once it has been published in the
Official Journal of the European Communities (OJ).
- You must use the standard/amendment beginning with the "Date of
cessation of presumption of conformity" of the superceded standard.
- The supplier must keep EMC/EMI/ESD test reports for 5 years after
ceasing to supply a product to Australia/New Zealand.
Sources:
- http://www.rfi-ind.com.au/web/C-Tick%20Book_%20Sep%202008.pdf, page 16.
- http://www.comlaw.gov.au/comlaw/legislation/
legislativeinstrumentcompilation1.nsf/0/
9EF80B6CC805B992CA257672001CEA68/$file/
RadLabelElectromagCompNotice2008.pdf, Section 6.3
- http://www.aca.gov.au/publications/industry/manuals/emcbook.pdf
- http://www.aca.gov.au/consumer/faq/emc.htm
Japan:
- Standards take effect at the date given in the standard.
- Unknown must keep EMC/EMI/ESD test reports for two ? years after the
product goes out of production
Sources:
China:
- You may use a standard/amendment as of unknown.
- You must use a standard/amendment as of unknown.
- Unknown must retain EMC/EMI/ESD test reports for unknown.
-
Sources:
Taiwan:
- Standards take effect based on the type of commodity- 1 JAN 1998 for
most information technology equipment (ITE).
- Unknown must keep EMC/EMI/ESD test reports for unknown
Sources:
- http://www.ce-mag.com/archive/1999/novdec/Lin.html
- http://www.bsmi.gov.tw/english/emc/e_emc_hp.htm
- http://www.bsmi.gov.tw/english/emc/e_emc_10.htm
DISCLAIMER
These web pages are freely offered to anyone who wishes to use them. No
warranty for their use is expressed or implied. The most-current versions may
be downloaded from the our web site at
http://www.dbicorporation.com/.
These web pages can point you to regulations and standards applying to your
product(s), but please refer to the regulations and standards themselves when
deciding how to test your product(s). A regulation's or standard's title
gives you strong clues as to what it covers, but its scope (usually section 1)
tells you for sure. Carefully check the footnotes in tables, to see if your
product falls into an exception that lets you avoid unnecessary tests (or
sometimes requires additional special testing). Exceptions that can help you
also sometimes hide in the Test Setup section (usually section 7). Also check
the Test Report section (usually section 10) for any special documentation
required.
COMMENTS
If you refer to one or more of these documents in written communications, please
attribute them to
http://www.dbicorporation.com/.
Similarly, if you link to them from your own web page(s), we would appreciate
an E-mail to
jrbarnes@iglou.com giving the
universal resource link (URL) so that we may provide a reciprocal link.
Please send critiques, corrections, and/or additions to
jrbarnes@iglou.com , or
by snailmail to:
John Barnes
216 Hillsboro Ave
Lexington, KY 40511-2105
dBi Corporation was a
one-man test house (testing laboratory) based in Lexington, Kentucky, testing
a wide variety of commercial electronic products for electromagnetic
compatibility (EMC), electromagnetic interference (EMI), and electrostatic
discharge (ESD) under its ISO 17025 accreditation. dBi was founded in
Winchester, Kentucky in 1995 by Donald R. Bush, shortly after he retired from
30 years service with IBM Lexington's/ Lexmark's EMC Lab. John R. Barnes,
who'd worked with Don at IBM Lexington and Lexmark, bought dBi in 2002
after Don's death, and moved the company to Lexington, Kentucky. John closed
dBi at 11:59pm EDT on September 30, 2013, because ObamaCrap had
increased operating expenses to the point that we could no longer afford to
remain in business.
We'd like to thank all of the clients who chose dBi to test their
products from 1995 to 2013. Below is a brief summary of our accomplishments
during the 18 years we were in business.
From 1995 to 2001, under Don Bush's ownership and operation, dBi:
- Did the official approval testing of 141 products developed by 20
client companies.
- Did the official FCC/ Industry Canada (IC) Verification and Declaration
of Conformity (DoC) testing of 92 products.
- Did the official FCC/IC Certification testing of 15 products.
- Did the official CE Marking testing of 100 products.
From 2002 to 2013, under John Barnes' ownership and operation, dBi:
- Tested 389 products and 2 testers developed by 44 client companies.
- Did the official approval testing of 357 products and 2 testers, getting
all but 5 of them to meet all of the FCC, Industry Canada
(IC), CE Marking, C-Tick, and Regulatory Compliance Mark (RCM) standards
and requirements for their desired market areas.
- Did the official FCC/IC Verification and Declaration of Conformity (DoC)
testing of 296 products.
- Did the official FCC/IC Certification testing of 24 products.
- Did the official CE Marking testing of 271 products and 2 testers.
- Did the official e-Mark testing of 3 products.
- Did the official Australia/New Zealand Verification testing of 170
products.
- Co-sponsored John's writing the
Robust Electronic Design Reference Book,
Volumes I and II.
- Served as an expert witness on electronics in three lawsuits.
Last revised December 19, 2010.
