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?
On Wed, 9 Oct 2024 19:03:28 -0400, bitrex <user@example.net> wrote:
What's the deal with the "CPU board" exemption?
Where is there such an 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?
On 10/9/2024 7:18 PM, john larkin wrote:
On Wed, 9 Oct 2024 19:03:28 -0400, bitrex <user@example.net> wrote:
What's the deal with the "CPU board" exemption?
Where is there such an exemption?
It's under the section on sub-assemblies:
<https://www.ecfr.gov/current/title-47/part-15/subpart-B#p-15.101(e)>
A "CPU board" as defined previously is considered a type of sub-assembly.
As a hypothetical say someone sells a product that's a PCB with a PIC on
it and some relays that has e.g. RS-232 port and terminal blocks to
connect to other stuff. It's in some sense a functional product, but the
user must at least connect it to some load of their choosing for it to >actually do anything. And they can put it in a housing if they wish, or
not, whatever.
Is this still a "sub-assembly"?
"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?
On Wed, 9 Oct 2024 21:29:09 -0400, bitrex <user@example.net> wrote:
On 10/9/2024 7:18 PM, john larkin wrote:
On Wed, 9 Oct 2024 19:03:28 -0400, bitrex <user@example.net> wrote:
What's the deal with the "CPU board" exemption?
Where is there such an exemption?
It's under the section on sub-assemblies:
<https://www.ecfr.gov/current/title-47/part-15/subpart-B#p-15.101(e)>
A "CPU board" as defined previously is considered a type of sub-assembly.
As a hypothetical say someone sells a product that's a PCB with a PIC on
it and some relays that has e.g. RS-232 port and terminal blocks to
connect to other stuff. It's in some sense a functional product, but the
user must at least connect it to some load of their choosing for it to
actually do anything. And they can put it in a housing if they wish, or
not, whatever.
Is this still a "sub-assembly"?
"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?
Do you really care?
My Brit friends say that CE means Can't Enforce.
It's been a long time since I saw an FCC truck bristling with antennas snooping around.
On 10/9/2024 7:18 PM, john larkin wrote:
On Wed, 9 Oct 2024 19:03:28 -0400, bitrex <user@example.net> wrote:
What's the deal with the "CPU board" exemption?
Where is there such an exemption?
It's under the section on sub-assemblies:
<https://www.ecfr.gov/current/title-47/part-15/subpart-B#p-15.101(e)>
A "CPU board" as defined previously is considered a type of sub-assembly.
As a hypothetical say someone sells a product that's a PCB with a PIC on
it and some relays that has e.g. RS-232 port and terminal blocks to
connect to other stuff. It's in some sense a functional product, but the
user must at least connect it to some load of their choosing for it to >actually do anything. And they can put it in a housing if they wish, or
not, whatever.
Is this still a "sub-assembly"?
"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?
Do you really care?
My Brit friends say that CE means Can't Enforce.
On 10/10/2024 13:25, Clive Arthur wrote:
On 10/10/2024 03:21, john larkin wrote:
<snip CE chat>
Do you really care?
My Brit friends say that CE means Can't Enforce.
Or Chinese Export.
They may say that, but I bet they comply - it means if your competitor
finds out that you don't comply you have problems. I've never worked
anywhere where it's not taken seriously.
Same here. I've nursed many products through the EMC and
safety compliance processes over the years. There have
been few changes to EMC, but the safety regulations for
audio and IT products and for test equipment have seen
some radical changes - mostly for the better.
John
On 10/10/2024 03:21, john larkin wrote:
<snip CE chat>
Do you really care?
My Brit friends say that CE means Can't Enforce.
Or Chinese Export.
They may say that, but I bet they comply - it means if your competitor
finds out that you don't comply you have problems. I've never worked >anywhere where it's not taken seriously.
On 10/10/2024 13:25, Clive Arthur wrote:
On 10/10/2024 03:21, john larkin wrote:
<snip CE chat>
Do you really care?
My Brit friends say that CE means Can't Enforce.
Or Chinese Export.
They may say that, but I bet they comply - it means if your competitor
finds out that you don't comply you have problems. I've never worked
anywhere where it's not taken seriously.
Same here. I've nursed many products through the EMC and
safety compliance processes over the years. There have
been few changes to EMC, but the safety regulations for
audio and IT products and for test equipment have seen
some radical changes - mostly for the better.
John
On Thu, 10 Oct 2024 13:25:04 +0100, Clive Arthur
<clive@nowaytoday.co.uk> wrote:
On 10/10/2024 03:21, john larkin wrote:
<snip CE chat>
Do you really care?
My Brit friends say that CE means Can't Enforce.
Or Chinese Export.
They may say that, but I bet they comply - it means if your competitor
finds out that you don't comply you have problems. I've never worked
anywhere where it's not taken seriously.
In europe, "taking seriously" often means buying a reel of CE stickers
and slapping them on everything.
Did you EMI lab test everything that you sold?
On Thu, 10 Oct 2024 13:25:04 +0100, Clive Arthur
<clive@nowaytoday.co.uk> wrote:
On 10/10/2024 03:21, john larkin wrote:
<snip CE chat>
Do you really care?
My Brit friends say that CE means Can't Enforce.
Or Chinese Export.
They may say that, but I bet they comply - it means if your competitor
finds out that you don't comply you have problems. I've never worked
anywhere where it's not taken seriously.
In europe, "taking seriously" often means buying a reel of CE stickers
and slapping them on everything.
Did you EMI lab test everything that you sold?
We mostly sell things that go onto bigger systems, and our customer
worries about certifications. So we only need to not make them fail.
Our box could be buried deep inside their system.
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).
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?
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!]
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.
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?
On 10/10/2024 13:25, Clive Arthur wrote:
On 10/10/2024 03:21, john larkin wrote:
<snip CE chat>
Do you really care?
My Brit friends say that CE means Can't Enforce.
Or Chinese Export.
They may say that, but I bet they comply - it means if your competitor
finds out that you don't comply you have problems. I've never worked
anywhere where it's not taken seriously.
Same here. I've nursed many products through the EMC and
safety compliance processes over the years. There have
been few changes to EMC, but the safety regulations for
audio and IT products and for test equipment have seen
some radical changes - mostly for the better.
John
On Thu, 10 Oct 2024 13:25:04 +0100, Clive Arthur
<clive@nowaytoday.co.uk> wrote:
On 10/10/2024 03:21, john larkin wrote:
<snip CE chat>
Do you really care?
My Brit friends say that CE means Can't Enforce.
Or Chinese Export.
They may say that, but I bet they comply - it means if your competitor
finds out that you don't comply you have problems. I've never worked
anywhere where it's not taken seriously.
In europe, "taking seriously" often means buying a reel of CE stickers
and slapping them on everything.
Did you EMI lab test everything that you sold?
We mostly sell things that go onto bigger systems, and our customer
worries about certifications. So we only need to not make them fail.
Our box could be buried deep inside their system.
We only once were blamed for an important EMI failure, and that turned
out to be our customers fault.
There must be ballpark a million shops in the USA that assemble PCs
from parts, mostly Chinese parts, the other CE kind, and I doubt if
1% of those assemblers do any EMI testing.
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.
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."
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
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.
A wart used in an EMC certification becomes part of it. Hence
mrfs listing and retailing part numbers for suitable use.
Warts can be (and are) listed independently, to reduce
potential testing and deployment gliches. A listed
wart doesn't guarantee radiated compliance, only facilitates
conducted performance on that one, main, port.
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.
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.
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:
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.
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.
Somebody was talking about 48V warts. Some standards only allow 24V (for wet environments), and 32V for certain parts of the world
On Thu, 10 Oct 2024 14:11:35 -0700, john larkin <jl@glen--canyon.com>
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.
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.
A wart used in an EMC certification becomes part of it. Hence
mrfs listing and retailing part numbers for suitable use.
Warts can be (and are) listed independently, to reduce
potential testing and deployment gliches. A listed
wart doesn't guarantee radiated compliance, only facilitates
conducted performance on that one, main, port.
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.
On 12-10-2024 01:31, legg wrote:
On Thu, 10 Oct 2024 14:11:35 -0700, john larkin <jl@glen--canyon.com>
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.
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.
A wart used in an EMC certification becomes part of it. Hence
mrfs listing and retailing part numbers for suitable use.
Warts can be (and are) listed independently, to reduce
potential testing and deployment gliches. A listed
wart doesn't guarantee radiated compliance, only facilitates
conducted performance on that one, main, port.
All of the EMC tests still needs to be done even if you use a wart.
But LVD (safety) becomes a lot easier, if it's below 15W consumption (no >glow-wire test etc)
Somebody was talking about 48V warts. Some standards only allow 24V (for
wet environments), and 32V for certain parts of the world
48 is super common now. All our phones are PoE powered, which is
typically about 54 volts. Digikey sells warts up to 65.
The phones are cool. I can take one to Hawaii and plug it in and it
works just like it does here.
I imagine that europe has tens, maybe hundreds of millions of PoE
devices with the chinese version of the CE mark molded into the case.
So if european manufacturers realy have to do all the CE certs and
testing, they have one more reason that they can't compete with
imports.
On 10/12/2024 11:22 AM, john larkin wrote:
48 is super common now. All our phones are PoE powered, which is
typically about 54 volts. Digikey sells warts up to 65.
The phones are cool. I can take one to Hawaii and plug it in and it
works just like it does here.
I imagine that europe has tens, maybe hundreds of millions of PoE
devices with the chinese version of the CE mark molded into the case.
So if european manufacturers realy have to do all the CE certs and
testing, they have one more reason that they can't compete with
imports.
So as of 2019 it looks like the US rules are similar to the European
"can't enforce" rules in that the manufacturer takes responsibility for >everything and it's up to the mfgr how and what tests they perform to >determine compliance:
<https://www.electronicdesign.com/technologies/test-measurement/article/21209868/recent-developments-in-emc-legislation>
This makes it sound like it's not too expensive to do some basic
compliance tests on a small-volume product in house:
<https://incompliancemag.com/emc-bench-notes-how-to-use-spectrum-analyzers-for-emc/>
Need a 1 GHz-ish spectrum analyzer at least as the main tool which
aren't exorbitantly expensive nowadays.
On 12-10-2024 01:31, legg wrote:
On Thu, 10 Oct 2024 14:11:35 -0700, john larkin <jl@glen--canyon.com>
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.
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.
A wart used in an EMC certification becomes part of it. Hence
mrfs listing and retailing part numbers for suitable use.
Warts can be (and are) listed independently, to reduce
potential testing and deployment gliches. A listed
wart doesn't guarantee radiated compliance, only facilitates
conducted performance on that one, main, port.
All of the EMC tests still needs to be done even if you use a wart.
But LVD (safety) becomes a lot easier, if it's below 15W consumption (no >glow-wire test etc)
Somebody was talking about 48V warts. Some standards only allow 24V (for
wet environments), and 32V for certain parts of the world
On Sat, 12 Oct 2024 11:38:30 +0200, Klaus Vestergaard Kragelund ><klauskvik@hotmail.com> wrote:
On 12-10-2024 01:31, legg wrote:
On Thu, 10 Oct 2024 14:11:35 -0700, john larkin <jl@glen--canyon.com>
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.
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.
A wart used in an EMC certification becomes part of it. Hence
mrfs listing and retailing part numbers for suitable use.
Warts can be (and are) listed independently, to reduce
potential testing and deployment gliches. A listed
wart doesn't guarantee radiated compliance, only facilitates
conducted performance on that one, main, port.
All of the EMC tests still needs to be done even if you use a wart.
But LVD (safety) becomes a lot easier, if it's below 15W consumption (no >>glow-wire test etc)
Somebody was talking about 48V warts. Some standards only allow 24V (for >>wet environments), and 32V for certain parts of the world
In these certain parts of the world, what do they use for telephones?
The standard central office batteries were and still are 48 Vdc. Which
is why the electrical codes in the US and EU ignore anything below 50
Volts or so.
Only very recently are cellphones taking over.
Joe Gwinn
The standards bodies are parasites on society, as bad as the worst academic publishers.
The standards committees are composed of volunteers, often working
for universities or companies who pay their salaries, but never paid by the standards body for their free labour. Then the standards are copyrighted and sold at a huge profit, often to the same organisations whose experts contributed all of the value incorporated in the standards. The standards bodies are generally non-profit organisations, and they ensure this non-profit
characteristic by increasing the pay of their directors until they run out of profit.
The standards become referenced in laws, and thereby have the force of law, but
are copyrighted by a private entity, and not even the politicians writing the laws incorporating these standards can read them without paying.
Do not ever volunteer your time to work on a proprietary standard.
Here is a nice video by Carl Malamud (of https://public.resource.org/ ): https://www.youtube.com/watch?v=2tOJdGaMvVw
He had a legal victory: There has been some European court decision that in future they will have to allow public access to standards written into law:
https://www.heise.de/news/EuGH-Entscheid-Europaeische-Normen-muessen-gratis-zugaenglich-sein-9646757.html
On Sat, 12 Oct 2024 13:11:02 -0400, Joe Gwinn <joegwinn@comcast.net>
wrote:
On Sat, 12 Oct 2024 11:38:30 +0200, Klaus Vestergaard Kragelund >><klauskvik@hotmail.com> wrote:
On 12-10-2024 01:31, legg wrote:
On Thu, 10 Oct 2024 14:11:35 -0700, john larkin <jl@glen--canyon.com>
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.
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.
A wart used in an EMC certification becomes part of it. Hence
mrfs listing and retailing part numbers for suitable use.
Warts can be (and are) listed independently, to reduce
potential testing and deployment gliches. A listed
wart doesn't guarantee radiated compliance, only facilitates
conducted performance on that one, main, port.
All of the EMC tests still needs to be done even if you use a wart.
But LVD (safety) becomes a lot easier, if it's below 15W consumption (no >>>glow-wire test etc)
Somebody was talking about 48V warts. Some standards only allow 24V (for >>>wet environments), and 32V for certain parts of the world
In these certain parts of the world, what do they use for telephones?
The standard central office batteries were and still are 48 Vdc. Which
is why the electrical codes in the US and EU ignore anything below 50
Volts or so.
Only very recently are cellphones taking over.
Joe Gwinn
At work, we use PoE phones, through the internet. The PoE switches
typically supply about 54 volts. (I've recently been testing PoE power >pickoff bricks.)
At home, we use cell phones. Our old Bell System phone number was
converted to free service over our cable modem, and probably still
works, but we unplugged the phones because it was mostly spam calls.
On 10/12/2024 2:38 AM, Klaus Vestergaard Kragelund wrote:
Somebody was talking about 48V warts. Some standards only allow 24V
(for wet environments), and 32V for certain parts of the world
48V wall-warts/bricks are typically used in midspan PoE
injectors (and as standalone power supplies for PDs
without PSEs). As such, almost always in dry locations.
Can those "certain parts of the world" use PoE products
with nominal 48VDC delivered over the twisted pairs?
Is the limit on the "packaging" or on the potential?
On 12/10/2024 18:07, john larkin wrote:
On Sat, 12 Oct 2024 12:25:27 -0400, bitrex <user@example.net> wrote:
On 10/12/2024 11:22 AM, john larkin wrote:
48 is super common now. All our phones are PoE powered, which is
typically about 54 volts. Digikey sells warts up to 65.
The phones are cool. I can take one to Hawaii and plug it in and it
works just like it does here.
I imagine that europe has tens, maybe hundreds of millions of PoE
devices with the chinese version of the CE mark molded into the case.
So if european manufacturers realy have to do all the CE certs and
testing, they have one more reason that they can't compete with
imports.
So as of 2019 it looks like the US rules are similar to the European
"can't enforce" rules in that the manufacturer takes responsibility for
everything and it's up to the mfgr how and what tests they perform to
determine compliance:
<https://www.electronicdesign.com/technologies/test-measurement/
article/21209868/recent-developments-in-emc-legislation>
This makes it sound like it's not too expensive to do some basic
compliance tests on a small-volume product in house:
<https://incompliancemag.com/emc-bench-notes-how-to-use-spectrum-
analyzers-for-emc/>
Need a 1 GHz-ish spectrum analyzer at least as the main tool which
aren't exorbitantly expensive nowadays.
I can buy a spectrum analyzer and a surfboard antenna for under $1000,
and can take a product out in the country and do an open-field test
and crudely ballpark its EMI signature.
CE requires screen room testing and more quantitative measurement.
The reality today is that few products are honestly certified for EMI
or safety, and life goes on pretty well. If a product causes massive
EMI problems or hurts people, civil and criminal liabilities apply.
My experience differs. Every product that I have been involved
with has been independently tested by Intertek or a test lab of
similar status.
On 12/10/2024 18:07, john larkin wrote:
On Sat, 12 Oct 2024 12:25:27 -0400, bitrex <user@example.net> wrote:
On 10/12/2024 11:22 AM, john larkin wrote:
48 is super common now. All our phones are PoE powered, which is
typically about 54 volts. Digikey sells warts up to 65.
The phones are cool. I can take one to Hawaii and plug it in and it
works just like it does here.
I imagine that europe has tens, maybe hundreds of millions of PoE
devices with the chinese version of the CE mark molded into the case.
So if european manufacturers realy have to do all the CE certs and
testing, they have one more reason that they can't compete with
imports.
So as of 2019 it looks like the US rules are similar to the European
"can't enforce" rules in that the manufacturer takes responsibility for
everything and it's up to the mfgr how and what tests they perform to
determine compliance:
<https://www.electronicdesign.com/technologies/test-measurement/article/21209868/recent-developments-in-emc-legislation>
This makes it sound like it's not too expensive to do some basic
compliance tests on a small-volume product in house:
<https://incompliancemag.com/emc-bench-notes-how-to-use-spectrum-analyzers-for-emc/>
Need a 1 GHz-ish spectrum analyzer at least as the main tool which
aren't exorbitantly expensive nowadays.
I can buy a spectrum analyzer and a surfboard antenna for under $1000,
and can take a product out in the country and do an open-field test
and crudely ballpark its EMI signature.
CE requires screen room testing and more quantitative measurement.
The reality today is that few products are honestly certified for EMI
or safety, and life goes on pretty well. If a product causes massive
EMI problems or hurts people, civil and criminal liabilities apply.
My experience differs. Every product that I have been involved
with has been independently tested by Intertek or a test lab of
similar status.
It's impressive how few EMI problems there are in real life.Maybe that is because many products are actually tested and compliant.
I can remember when audio equipment was very susceptible to
interference from many sources. Those days are mostly gone.
I have come across exceptions of course.
John
On 12-10-2024 12:00, Don Y wrote:
On 10/12/2024 2:38 AM, Klaus Vestergaard Kragelund wrote:
Somebody was talking about 48V warts. Some standards only allow 24V (for wet
environments), and 32V for certain parts of the world
48V wall-warts/bricks are typically used in midspan PoE
injectors (and as standalone power supplies for PDs
without PSEs). As such, almost always in dry locations.
Can those "certain parts of the world" use PoE products
with nominal 48VDC delivered over the twisted pairs?
Is the limit on the "packaging" or on the potential?
In IEC60730 (safety for household products), 2.1.5 SELV is defined as maximum 42V. Note states that for the US and Canada the SELV voltage is max 30VRMS (which equates to 42.4Vpeak). Those numbers are when dry, when wet it reduces to 15V/21.2V peak.
Normally things are dry, so US is 30V. I do not know how it is possible to allow 48V warts.
Searching a little, it seems the 48V systems are approved against telecommunication standards which may not use the SELV nomenclature
NEC has higher voltages, up to 60VDC, but matters little since most product needs to comply to 60730/60950, and now 62368 has replaced 60950.
The touch voltages are defined in yet another standard, IEC61201. I do not have
access to that one.
The 48V warts are also strange in that when the product is tested for peak SELV
voltage a single fault must be introduced. So if you mess with the feedback of
the SMPS, the trip voltage determines the maximum voltage, and that is most likely significantly higher than 48V.
On Sat, 12 Oct 2024 23:30:46 +0100, John R Walliker
<jrwalliker@gmail.com> wrote:
On 12/10/2024 18:07, john larkin wrote:
On Sat, 12 Oct 2024 12:25:27 -0400, bitrex <user@example.net> wrote:
On 10/12/2024 11:22 AM, john larkin wrote:
48 is super common now. All our phones are PoE powered, which is
typically about 54 volts. Digikey sells warts up to 65.
The phones are cool. I can take one to Hawaii and plug it in and it
works just like it does here.
I imagine that europe has tens, maybe hundreds of millions of PoE
devices with the chinese version of the CE mark molded into the case. >>>>>
So if european manufacturers realy have to do all the CE certs and
testing, they have one more reason that they can't compete with
imports.
So as of 2019 it looks like the US rules are similar to the European
"can't enforce" rules in that the manufacturer takes responsibility for >>>> everything and it's up to the mfgr how and what tests they perform to
determine compliance:
<https://www.electronicdesign.com/technologies/test-measurement/article/21209868/recent-developments-in-emc-legislation>
This makes it sound like it's not too expensive to do some basic
compliance tests on a small-volume product in house:
<https://incompliancemag.com/emc-bench-notes-how-to-use-spectrum-analyzers-for-emc/>
Need a 1 GHz-ish spectrum analyzer at least as the main tool which
aren't exorbitantly expensive nowadays.
I can buy a spectrum analyzer and a surfboard antenna for under $1000,
and can take a product out in the country and do an open-field test
and crudely ballpark its EMI signature.
CE requires screen room testing and more quantitative measurement.
The reality today is that few products are honestly certified for EMI
or safety, and life goes on pretty well. If a product causes massive
EMI problems or hurts people, civil and criminal liabilities apply.
My experience differs. Every product that I have been involved
with has been independently tested by Intertek or a test lab of
similar status.
> It's impressive how few EMI problems there are in real life.
Maybe that is because many products are actually tested and compliant.
I can remember when audio equipment was very susceptible to
interference from many sources. Those days are mostly gone.
I have come across exceptions of course.
John
Most audio equipment is digital now.
On Sat, 12 Oct 2024 11:38:30 +0200, Klaus Vestergaard Kragelund <klauskvik@hotmail.com> wrote:
On 12-10-2024 01:31, legg wrote:
On Thu, 10 Oct 2024 14:11:35 -0700, john larkin <jl@glen--canyon.com>
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.
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.
A wart used in an EMC certification becomes part of it. Hence
mrfs listing and retailing part numbers for suitable use.
Warts can be (and are) listed independently, to reduce
potential testing and deployment gliches. A listed
wart doesn't guarantee radiated compliance, only facilitates
conducted performance on that one, main, port.
All of the EMC tests still needs to be done even if you use a wart.
But LVD (safety) becomes a lot easier, if it's below 15W consumption (no
glow-wire test etc)
Somebody was talking about 48V warts. Some standards only allow 24V (for
wet environments), and 32V for certain parts of the world
48 is super common now. All our phones are PoE powered, which is
typically about 54 volts. Digikey sells warts up to 65.
The phones are cool. I can take one to Hawaii and plug it in and it
works just like it does here.
I imagine that Europe has tens, maybe hundreds of millions of PoE
devices with the Chinese version of the CE mark molded into the case.
So if European manufacturers really have to do all the CE certs and
testing, they have one more reason that they can't compete with
imports.
On 12/10/2024 6:20 am, john larkin 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.
The standards bodies are parasites on society, as bad as the worst
academic publishers. The standards committees are composed of
volunteers, often working for universities or companies who pay their >salaries, but never paid by the standards body for their free labour.
Then the standards are copyrighted and sold at a huge profit, often to
the same organisations whose experts contributed all of the value >incorporated in the standards. The standards bodies are generally
non-profit organisations, and they ensure this non-profit characteristic
by increasing the pay of their directors until they run out of profit.
On Sat, 12 Oct 2024 10:47:24 -0700, john larkin <JL@gct.com> wrote:
On Sat, 12 Oct 2024 13:11:02 -0400, Joe Gwinn <joegwinn@comcast.net>
wrote:
On Sat, 12 Oct 2024 11:38:30 +0200, Klaus Vestergaard Kragelund >>><klauskvik@hotmail.com> wrote:
On 12-10-2024 01:31, legg wrote:
On Thu, 10 Oct 2024 14:11:35 -0700, john larkin <jl@glen--canyon.com> >>>>> 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.
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.
A wart used in an EMC certification becomes part of it. Hence
mrfs listing and retailing part numbers for suitable use.
Warts can be (and are) listed independently, to reduce
potential testing and deployment gliches. A listed
wart doesn't guarantee radiated compliance, only facilitates
conducted performance on that one, main, port.
All of the EMC tests still needs to be done even if you use a wart.
But LVD (safety) becomes a lot easier, if it's below 15W consumption (no >>>>glow-wire test etc)
Somebody was talking about 48V warts. Some standards only allow 24V (for >>>>wet environments), and 32V for certain parts of the world
In these certain parts of the world, what do they use for telephones?
The standard central office batteries were and still are 48 Vdc. Which
is why the electrical codes in the US and EU ignore anything below 50 >>>Volts or so.
Only very recently are cellphones taking over.
Joe Gwinn
At work, we use PoE phones, through the internet. The PoE switches >>typically supply about 54 volts. (I've recently been testing PoE power >>pickoff bricks.)
Maybe someday.
At home, we use cell phones. Our old Bell System phone number was
converted to free service over our cable modem, and probably still
works, but we unplugged the phones because it was mostly spam calls.
Yeah, although I still keep the landline, even though it is now via
fiber. I get at least as much spam and malware from iphone and
computer.
On 10/12/2024 4:02 PM, Klaus Vestergaard Kragelund wrote:
On 12-10-2024 12:00, Don Y wrote:
On 10/12/2024 2:38 AM, Klaus Vestergaard Kragelund wrote:
Somebody was talking about 48V warts. Some standards only allow 24V
(for wet environments), and 32V for certain parts of the world
48V wall-warts/bricks are typically used in midspan PoE
injectors (and as standalone power supplies for PDs
without PSEs). As such, almost always in dry locations.
Can those "certain parts of the world" use PoE products
with nominal 48VDC delivered over the twisted pairs?
Is the limit on the "packaging" or on the potential?
In IEC60730 (safety for household products), 2.1.5 SELV is defined as
maximum 42V. Note states that for the US and Canada the SELV voltage
is max 30VRMS (which equates to 42.4Vpeak). Those numbers are when
dry, when wet it reduces to 15V/21.2V peak.
Normally things are dry, so US is 30V. I do not know how it is
possible to allow 48V warts.
Searching a little, it seems the 48V systems are approved against
telecommunication standards which may not use the SELV nomenclature
NEC has higher voltages, up to 60VDC, but matters little since most
product needs to comply to 60730/60950, and now 62368 has replaced 60950.
The touch voltages are defined in yet another standard, IEC61201. I do
not have access to that one.
The 48V warts are also strange in that when the product is tested for
peak SELV voltage a single fault must be introduced. So if you mess
with the feedback of the SMPS, the trip voltage determines the maximum
voltage, and that is most likely significantly higher than 48V.
But, is the constraint on the "wall wart package"? Or, on the presence
of ~48V on conductors that are accessible to the user?
E.g., an N-port PoE switch looks like the (output) power cords from
N 48V wall warts. (technically, this is only the case while the
cables are physically connected to their PDs as the PSE should
power down the unconnected port).
Because the switch "isn't a wall wart", is it exempt?
Or, is all this moot because PoE switches aren't "household kit"?
In IEC60730 (safety for household products), 2.1.5 SELV is defined as
maximum 42V. Note states that for the US and Canada the SELV voltage is max >>> 30VRMS (which equates to 42.4Vpeak). Those numbers are when dry, when wet it
reduces to 15V/21.2V peak.
Normally things are dry, so US is 30V. I do not know how it is possible to >>> allow 48V warts.
Searching a little, it seems the 48V systems are approved against
telecommunication standards which may not use the SELV nomenclature
NEC has higher voltages, up to 60VDC, but matters little since most product >>> needs to comply to 60730/60950, and now 62368 has replaced 60950.
The touch voltages are defined in yet another standard, IEC61201. I do not >>> have access to that one.
The 48V warts are also strange in that when the product is tested for peak >>> SELV voltage a single fault must be introduced. So if you mess with the
feedback of the SMPS, the trip voltage determines the maximum voltage, and >>> that is most likely significantly higher than 48V.
But, is the constraint on the "wall wart package"? Or, on the presence
of ~48V on conductors that are accessible to the user?
POE voltage is directly on the pins of the ethernet interface.
The designer
insources the external wart with 48V nominal voltage (which can be more under single fault)
There may be a loop hole
If you ship the adapter/wart with the product you should test as a system, right?
But if you just state it needs 48V in, you can blame the wart manufacturer if it puts out more voltage.
E.g., an N-port PoE switch looks like the (output) power cords from
N 48V wall warts. (technically, this is only the case while the
cables are physically connected to their PDs as the PSE should
power down the unconnected port).
Because the switch "isn't a wall wart", is it exempt?
Or, is all this moot because PoE switches aren't "household kit"?
I just took a random POE ethernet switch which uses a 54V external adapter: https://www.proshop.dk/Switch/Netgear-GS110TPv3-8-Port-Gigabit-PoE-Ethernet-Smart-Switch-with-2-SFP-Ports-and-Cloud-Management/2871263
No mention of standards in the datasheet. But found a reference in the hardware
manual: https://www.downloads.netgear.com/files/GDC/GS108Tv3/GS108Tv3_GS110TPv3_GS110TPP_HIG_EN.pdf
Page 2, link to netgears compliance document: https://www.netgear.com/about/regulatory/
Then searched for the model no in the Declaration of conformance: https://kb.netgear.com/11621/EU-Declarations-of-Conformity?article=11621
Finally here:
https://www.downloads.netgear.com/files/DoC/204-11529-04_CE_GS110TPv3_EN-EP-FR-IT-GR-SP_19SEP22.pdf?_ga=2.171448224.1872638720.1728816211-1033670545.1728816210
Mentions use of 60950 and 62368
I am doing EMC tests tomorrow at a test-house, so will ask them whats the deal ;-)
On 12-10-2024 12:00, Don Y wrote:
On 10/12/2024 2:38 AM, Klaus Vestergaard Kragelund wrote:
Somebody was talking about 48V warts. Some standards only allow 24V
(for wet environments), and 32V for certain parts of the world
48V wall-warts/bricks are typically used in midspan PoE
injectors (and as standalone power supplies for PDs
without PSEs). As such, almost always in dry locations.
Can those "certain parts of the world" use PoE products
with nominal 48VDC delivered over the twisted pairs?
Is the limit on the "packaging" or on the potential?
In IEC60730 (safety for household products), 2.1.5 SELV is defined as
maximum 42V. Note states that for the US and Canada the SELV voltage is
max 30VRMS (which equates to 42.4Vpeak). Those numbers are when dry,
when wet it reduces to 15V/21.2V peak.
Normally things are dry, so US is 30V. I do not know how it is possible
to allow 48V warts.
Searching a little, it seems the 48V systems are approved against >telecommunication standards which may not use the SELV nomenclature
NEC has higher voltages, up to 60VDC, but matters little since most
product needs to comply to 60730/60950, and now 62368 has replaced 60950.
The touch voltages are defined in yet another standard, IEC61201. I do
not have access to that one.
The 48V warts are also strange in that when the product is tested for
peak SELV voltage a single fault must be introduced. So if you mess with
the feedback of the SMPS, the trip voltage determines the maximum
voltage, and that is most likely significantly higher than 48V.
On 10/12/2024 3:06 AM, Chris Jones wrote:
The standards bodies are parasites on society, as bad as the worst
academic publishers.
To be fair, one typically has a financial interest (e.g., product development) that merits access to a "Standard". And, an organization really only needs *one* copy thereof.
What I don't fathom is why academics would want to (tolerate) insert
some "impediment" to access for their publications who adds no real
value. There, one would think you would want as widespread distribution
as possible (as "publication" is a metric for academics; if no one
is *consuming* your research, what value that?). I.e., one could
expect many individuals at a single organization to have copies of
specific papers without even being aware of their presence in other
cubicles.
The standards committees are composed of volunteers, often working for
universities or companies who pay their salaries, but never paid by
the standards body for their free labour. Then the standards are
copyrighted and sold at a huge profit, often to the same organisations
whose experts contributed all of the value incorporated in the
standards. The standards bodies are generally non-profit
organisations, and they ensure this non-profit characteristic by
increasing the pay of their directors until they run out of profit.
In the days of dead tree publication, one could understand the need
for someone to undertake this activity. Just typesetting a document
can be a significant task.
But, given the prevalence of DTP tools and the ease of self-publishing,
this activity seems to be obsolescent -- in THAT form.
The standards become referenced in laws, and thereby have the force of
law, but are copyrighted by a private entity, and not even the
politicians writing the laws incorporating these standards can read
them without paying.
Do not ever volunteer your time to work on a proprietary standard.
Here is a nice video by Carl Malamud (of https://public.resource.org/ ):
https://www.youtube.com/watch?v=2tOJdGaMvVw
He had a legal victory: There has been some European court decision
that in future they will have to allow public access to standards
written into law:
https://www.heise.de/news/EuGH-Entscheid-Europaeische-Normen-muessen-gratis-zugaenglich-sein-9646757.html
That doesn't really help folks who are *not* in Europe.
And, legislation with similar goals has often been subverted, stateside.
The folks victimized don't seem to have a loud enough voice to make
a difference. (witness the right-to-repair movement).
On Sat, 12 Oct 2024 11:38:30 +0200, Klaus Vestergaard Kragelund ><klauskvik@hotmail.com> wrote:
On 12-10-2024 01:31, legg wrote:
On Thu, 10 Oct 2024 14:11:35 -0700, john larkin <jl@glen--canyon.com>
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.
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.
A wart used in an EMC certification becomes part of it. Hence
mrfs listing and retailing part numbers for suitable use.
Warts can be (and are) listed independently, to reduce
potential testing and deployment gliches. A listed
wart doesn't guarantee radiated compliance, only facilitates
conducted performance on that one, main, port.
All of the EMC tests still needs to be done even if you use a wart.
But LVD (safety) becomes a lot easier, if it's below 15W consumption (no >>glow-wire test etc)
Somebody was talking about 48V warts. Some standards only allow 24V (for >>wet environments), and 32V for certain parts of the world
In these certain parts of the world, what do they use for telephones?
The standard central office batteries were and still are 48 Vdc. Which
is why the electrical codes in the US and EU ignore anything below 50
Volts or so.
Only very recently are cellphones taking over.
Joe Gwinn
On Sat, 12 Oct 2024 21:06:32 +1100, Chris Jones
<lugnut808@spam.yahoo.com> wrote:
On 12/10/2024 6:20 am, john larkin 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:
Standards have become an established method of protecting local
industry from lower cost imported goods from less socially
responsible sources.
It's one way of encouraging social responsibility and raising
technical awareness abroad, if you are an important market for
the products of secondary industry.
They try to do this with tertiary industries (financial and
service), but the weasels generally tap dance faster than
the regulators, have more money and less conscience.
Hence CE.
On Sat, 12 Oct 2024 13:11:02 -0400, Joe Gwinn <joegwinn@comcast.net>
wrote:
On Sat, 12 Oct 2024 11:38:30 +0200, Klaus Vestergaard Kragelund
<klauskvik@hotmail.com> wrote:
On 12-10-2024 01:31, legg wrote:
On Thu, 10 Oct 2024 14:11:35 -0700, john larkin <jl@glen--canyon.com>
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.
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.
A wart used in an EMC certification becomes part of it. Hence
mrfs listing and retailing part numbers for suitable use.
Warts can be (and are) listed independently, to reduce
potential testing and deployment gliches. A listed
wart doesn't guarantee radiated compliance, only facilitates
conducted performance on that one, main, port.
All of the EMC tests still needs to be done even if you use a wart.
But LVD (safety) becomes a lot easier, if it's below 15W consumption (no >>> glow-wire test etc)
Somebody was talking about 48V warts. Some standards only allow 24V (for >>> wet environments), and 32V for certain parts of the world
In these certain parts of the world, what do they use for telephones?
The standard central office batteries were and still are 48 Vdc. Which
is why the electrical codes in the US and EU ignore anything below 50
Volts or so.
Only very recently are cellphones taking over.
Joe Gwinn
Telecom standards tend to mirror BellCore regs.
Telecom standards tend to mirror BellCore regs.
And thinking about that, the ringing voltage was close to 100Vrms, and using flimsy connectors. Amazing that was legal
On 13/10/2024 1:21 pm, legg wrote:
On Sat, 12 Oct 2024 21:06:32 +1100, Chris Jones
<lugnut808@spam.yahoo.com> wrote:
On 12/10/2024 6:20 am, john larkin 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:
<snip>
Standards have become an established method of protecting local
industry from lower cost imported goods from less socially
responsible sources.
Since they are published internationally, they don't protect the local >industry all that well. When I was working in England we paid attention
to the American Underwriter's Laboratory standards so we could sell our
stuff in the US.
It's one way of encouraging social responsibility and raising
technical awareness abroad, if you are an important market for
the products of secondary industry.
They try to do this with tertiary industries (financial and
service), but the weasels generally tap dance faster than
the regulators, have more money and less conscience.
Hence CE.
Americans are cynical about CE. When I was designing stuff in Europe we
did take it seriously - just as seriously as UL.
On Mon, 14 Oct 2024 03:03:48 +1100, Bill Sloman <bill.sloman@ieee.org>
wrote:
On 13/10/2024 1:21 pm, legg wrote:
On Sat, 12 Oct 2024 21:06:32 +1100, Chris Jones
<lugnut808@spam.yahoo.com> wrote:
On 12/10/2024 6:20 am, john larkin 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:
<snip>
Standards have become an established method of protecting local
industry from lower cost imported goods from less socially
responsible sources.
Since they are published internationally, they don't protect the local
industry all that well. When I was working in England we paid attention
to the American Underwriter's Laboratory standards so we could sell our
stuff in the US.
It's one way of encouraging social responsibility and raising
technical awareness abroad, if you are an important market for
the products of secondary industry.
They try to do this with tertiary industries (financial and
service), but the weasels generally tap dance faster than
the regulators, have more money and less conscience.
Hence CE.
Americans are cynical about CE. When I was designing stuff in Europe we
did take it seriously - just as seriously as UL.
If you have a European (or any international) market, you have to
take the IEC regulations seriously - even UL's and CSA's later
standards were/are coordinated with them . . . .with national
exceptions.
A list of fines if you place products on the EU marked without CE or non-compliant CE:
https://www.sicomtesting.com/en/blog/ce-marking-conformity-checks/
On 12-10-2024 12:00, Don Y wrote:
On 10/12/2024 2:38 AM, Klaus Vestergaard Kragelund wrote:
Somebody was talking about 48V warts. Some standards only allow 24V
(for wet environments), and 32V for certain parts of the world
48V wall-warts/bricks are typically used in midspan PoE
injectors (and as standalone power supplies for PDs
without PSEs). As such, almost always in dry locations.
Can those "certain parts of the world" use PoE products
with nominal 48VDC delivered over the twisted pairs?
Is the limit on the "packaging" or on the potential?
In IEC60730 (safety for household products), 2.1.5 SELV is defined as
maximum 42V. Note states that for the US and Canada the SELV voltage is
max 30VRMS (which equates to 42.4Vpeak). Those numbers are when dry,
when wet it reduces to 15V/21.2V peak.
Normally things are dry, so US is 30V. I do not know how it is possible
to allow 48V warts.
Searching a little, it seems the 48V systems are approved against >telecommunication standards which may not use the SELV nomenclature
NEC has higher voltages, up to 60VDC, but matters little since most
product needs to comply to 60730/60950, and now 62368 has replaced 60950.
The touch voltages are defined in yet another standard, IEC61201. I do
not have access to that one.
The 48V warts are also strange in that when the product is tested for
peak SELV voltage a single fault must be introduced. So if you mess with
the feedback of the SMPS, the trip voltage determines the maximum
voltage, and that is most likely significantly higher than 48V.
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