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When is product certification not required?

Hi,

I have been having a discussion with a colleague regarding the testing and certification requirements of a particular product. 

Assume the product is battery powered, voltage under LVD, no pressure requirements, no ATEX requirements, intentional radiator (2.4GHz). Crucially, the device is not to be sold. Instead it is to be issued to specific customers for a term, before being returned back to us. 

His argument is that as the device is not sold, that it isn't subject to any specific certification. My argument is that it is put into service, at least outside of our premises, so the requirements apply. 

Obviously different regions have different rules, so any experience/advice on UK, EU, and USA would be appreciated. 

Many thanks,

Stephen

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  • Indeed and it is RF /EMC where I too see most chance of coming unstuck for the unwary - two pieces of kit, both meeting EMC emissions, and also immunity may still interfere with each  other if placed side by side. The levels are such that things probably won't interfere if they are next door to each other, unless the victim one is a communications receiver of some sort, but there is enough gaps between the permitted levels that kit that only just makes it to the worst case levels in the standards will struggle if co-located.   As a lot of what I get involved in is either to DEFSTAN or MILSPEC, so we have another 30dB or more  to go in terms of filtering and shielding to get a clear pass, so that tends to lead to over-design on the commercial products, but we still get the odd radiating mains lead of an unfortunate length and that kind of thing.

    Mike.

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  • Indeed and it is RF /EMC where I too see most chance of coming unstuck for the unwary - two pieces of kit, both meeting EMC emissions, and also immunity may still interfere with each  other if placed side by side. The levels are such that things probably won't interfere if they are next door to each other, unless the victim one is a communications receiver of some sort, but there is enough gaps between the permitted levels that kit that only just makes it to the worst case levels in the standards will struggle if co-located.   As a lot of what I get involved in is either to DEFSTAN or MILSPEC, so we have another 30dB or more  to go in terms of filtering and shielding to get a clear pass, so that tends to lead to over-design on the commercial products, but we still get the odd radiating mains lead of an unfortunate length and that kind of thing.

    Mike.

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