Re:[K3] CE Mark
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Hi Rowland,
> No CE mark seen but I dont think it needs one in Kit form. For the kit version likely not, but, afaik, anyone who ordered an assembled K3 in the EU will, without a CE Marking have a problem. Way back when, Eric did say that he was looking into getting the K3 certified. Mine is to be a kit... Ordered within a few hours of the announcement hitting the internet. vy 73 de toby _______________________________________________ Elecraft mailing list Post to: [hidden email] You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com |
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Toby Deinhardt wrote:
> > > No CE mark seen but I dont think it needs one in Kit form. > > For the kit version likely not, but, afaik, anyone who ordered an Although it might be technically legal (speculation), I very much doubt that the kit exemption envisaged a pre-aligned sub-assembly kit, like the K3. As far as I remember, the equivalent position for PCs is that board level components have to have individual EMC certification. In that case, they can be certified based on using extremely good cases, etc., but the K3 components are only intended to be used in a K3, so that loophole won't work. -- David Woolley Emails are not formal business letters, whatever businesses may want. RFC1855 says there should be an address here, but, in a world of spam, that is no longer good advice, as archive address hiding may not work. _______________________________________________ Elecraft mailing list Post to: [hidden email] You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com |
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> Although it might be technically legal (speculation), I very much
> doubt that the kit exemption envisaged a pre-aligned sub-assembly kit, As much as I hate to bother Eric right now, maybe he could give us a short update on the CE Marking certification status of the K3. Eric was looking into the legal situation and preparing to have the K3 certified back in April/May (shortly after the announcement). It would be a real pity if this creates problems for anyone on our side of the the Atlantic. vy 73 de toby _______________________________________________ Elecraft mailing list Post to: [hidden email] You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com |
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In reply to this post by David Woolley (E.L)
An interesting parallel with home-build PCs, but the difference is that PC
boards are sold separately on the open market and in theory can be connected with many other manufacturers' boards to make up a system; as such I would interpret them as products within their own right. The K3 boards are not on the open market as products, they are only viable when coupled together, ie unique to the final unit which is the K3. This is a kit of unique parts for one use, not a collection of various manufacturers' products. IMHO. David G3UNA ----- Original Message ----- From: "David Woolley" <[hidden email]> To: "Elecraft List" <[hidden email]> Sent: Tuesday, November 06, 2007 9:17 PM Subject: Re: [Elecraft] [K3] CE Mark > Toby Deinhardt wrote: >> >> > No CE mark seen but I dont think it needs one in Kit form. >> >> For the kit version likely not, but, afaik, anyone who ordered an > > Although it might be technically legal (speculation), I very much doubt > that the kit exemption envisaged a pre-aligned sub-assembly kit, like the > K3. As far as I remember, the equivalent position for PCs is that board > level components have to have individual EMC certification. In that case, > they can be certified based on using extremely good cases, etc., but the > K3 components are only intended to be used in a K3, so that loophole won't > work. > > > > -- > David Woolley > Emails are not formal business letters, whatever businesses may want. > RFC1855 says there should be an address here, but, in a world of spam, > that is no longer good advice, as archive address hiding may not work. > _______________________________________________ > Elecraft mailing list > Post to: [hidden email] > You must be a subscriber to post to the list. > Subscriber Info (Addr. Change, sub, unsub etc.): > http://mailman.qth.net/mailman/listinfo/elecraft > Help: http://mailman.qth.net/subscribers.htm > Elecraft web page: http://www.elecraft.com _______________________________________________ Elecraft mailing list Post to: [hidden email] You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com |
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In reply to this post by David Woolley (E.L)
Hi David,
Since the K3 kit requires 7 to 8 hours of customer assembly of our components following the detailed steps in our 60 page assembly manual, and because it does involve customer alignment and set up of the PLL, filters etc (via the front panel interface) it clearly does fall under the amateur radio kit CE exemption. We do some of the alignment for you, but you certainly get to do some too. Any your quality of assembly/test/alignment directly impacts the final performance of the radio. This is not your father's four board plug together home built PC :-) Also, the regular CE statement of conformity for built products requires us to maintain manufacturing quality information and processes on the final built product. Something that is impossible for us to do on a customer built kit, since we have no control over the customer. While we certainly have designed the K3 to exceed any requirements in this area, it is clear that if the final assembly is done by the customer that we have no way of absolutely guaranteeing or controlling this. That's another reason for the creation of the exemption for amateur radio kits. The regulators obviously felt that since the builder's were licensed amateur radio operators in most cases, they were trained in the art and would maintain a reasonable level of quality on their own. Thus its impossible for a manufacturer= to issue a CE statement on any amateur radio kit. And as far as Toby's question on CE for the built K3 - Yes, we will not ship built K3s for sale to the EC until we have finished the test suite for CE on them. We had to wait until we were shipping to run the tests on actual production units. We're completing this testing now. Fortunately the CE statement of conformity is a self certification by the manufacturer (us) and does not require any regulatory filing or approval through bureaucratic channels etc. As a side note: Some of tests required for CE are pretty bizarre when applied to a ham radio transceiver - As an example the radio must be tested for spurious emissions from the radio in receive mode even though the acceptable levels for spurious and on channel signals in transmit far exceed these RX test values. It looks like most of the regulations were written for commercial radio equipment that was intended for use by non-technical users from the general public. Fortunately, we easily exceed these requirements. Just a lot of formal testing and paperwork to do! 73, Eric WA6HHQ ----- David Woolley wrote: > Toby Deinhardt wrote: >> >> > No CE mark seen but I dont think it needs one in Kit form. >> >> For the kit version likely not, but, afaik, anyone who ordered an > > Although it might be technically legal (speculation), I very much > doubt that the kit exemption envisaged a pre-aligned sub-assembly > kit, like the K3. As far as I remember, the equivalent position for > PCs is that board level components have to have individual EMC > certification. > Elecraft mailing list Post to: [hidden email] You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com |
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In reply to this post by dj7mgq
In what way do you envision?
Its reached at least one 'G' now - I don't care about CE at all - it isn't worth the paper its printed (or often not) on. I've come across quite a lot of imported gear with a CE - no way does it meet even the most basic standard. Sorry, this came out confrontational - its not meant to be. But frankly - I just want my K3 and I don't care about 'useless' certification. On 6/11/07 21:50, "Toby Deinhardt" <[hidden email]> sent: > It would be a real pity if this creates problems for anyone on our side > of the the Atlantic. -- A bit of fragrance always clings to the hand that gives the rose. -Chinese proverb _______________________________________________ Elecraft mailing list Post to: [hidden email] You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com |
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In reply to this post by David Cutter
Hi David,
I agree with this point too. All of the components of the K3 are designed only for use inside that radio and not as general general options for other manufacturer's products. The boards are not stand alone products. 73, Eric WA6HHQ ---- David Cutter wrote: > An interesting parallel with home-build PCs, but the difference is > that PC boards are sold separately on the open market and in theory > can be connected with many other manufacturers' boards to make up a > system; as such I would interpret them as products within their own > right. The K3 boards are not on the open market as products, they are > only viable when coupled together, ie unique to the final unit which > is the K3. This is a kit of unique parts for one use, not a > collection of various manufacturers' products. IMHO. > > David > G3UNA > Elecraft mailing list Post to: [hidden email] You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com |
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In reply to this post by M0XDF
Hallo David,
AFAIK, you as the importer of electronic devices are responsible for conformity with EU regulations, whether they make sense or not. It is easy to imagine an official, with nothing better to do, causing serious problems for the importer of said equipment. A lot of what is in the CE marking requirements, imvho, make good sense, but there is no real mechanism to enforce them, especially because the CE Marking uses a self certification system. It is far too easy for producers and/or European importers/distributors to fudge on their certification and conformity. Which, as you correctly noted, often makes the CE Marking almost worthless. > Sorry, this came out confrontational - its not meant to be. But frankly - I > just want my K3 and I don't care about 'useless' certification. I also want my K3 (kit) but would hate to see Elecraft and/or Elecraft's customers run into any problems, just because a CE Marking was missing. vy 73 de toby PS: I am not a lawyer, so any and all of the above could be wildly false. PPS: I did not take your mail as confrontational. No worries here. _______________________________________________ Elecraft mailing list Post to: [hidden email] You must be a subscriber to post to the list. Subscriber Info (Addr. Change, sub, unsub etc.): http://mailman.qth.net/mailman/listinfo/elecraft Help: http://mailman.qth.net/subscribers.htm Elecraft web page: http://www.elecraft.com |
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