04 October 2018, 10:20 | #41 | |||||||||||
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04 October 2018, 10:30 | #42 | |
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Given the penalties for violation I opted not to sell my boards myself. |
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04 October 2018, 10:57 | #43 | ||
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The other side of things is that the directive doesn't prescribe any limits, targets or test methods. It's up to the manufacturer to select an appropriate approach that documents their compliance with the directive. Generally this will be testing for the limits of a standard (typically ISO or local harmonised equivalent), but any approach is allowed so long as it's justified. If you can write a good justification as to why your device doesn't need to be tested in an EMC lab, that will be enough. Of course, it needs to stand up to scrutiny from the reporting body should you ever be audited, so "I didn't feel like it" doesn't wash here. A detailed, comprehensive write-up on the frequencies used in the device, including all the calculations for the worst-case traces on the board and the expected radiated and conducted interference, how you addressed these (calculations for bypass capacitor size), comparative test results performed with a spectrum analyser and everything else like this should be a reasonable justification. Of course, compiling such a justification can take days or weeks, but if it's sound and does actually justify the lack of testing, it could save you thousands in unnecessary lab fees. Quote:
Note: obviously don't take this as legal advice - it's clearly not. But wrangling ISO standards and CE & FDA approval for medical devices (including electronics) is a significant portion of my day job. Last edited by Daedalus; 04 October 2018 at 12:08. |
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04 October 2018, 11:09 | #44 |
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Indeed. Thanks for that. The issue i had was that unless if fixed the crystal in place you couldn't be sure what frequencies might get generated. Which is one reason i fought against people who wanted a replaceable crystal. The other reason was space obviously.
I guess I could argue that it would sit inside the A500 shielding but i'm not sure if that would fly. It doesnt physically fit. |
04 October 2018, 12:02 | #45 | |
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I dont want to get banned from being a company director or do prison time. It seems that everything that comes out of Poland has CE on it. But the vampire doesnt have CE marking on it for example. They respect the rules. Is there some dude in Poland that does EMC testing for $100??? |
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04 October 2018, 12:02 | #46 | |
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Yeah google translator is sh*t. In those posts I mean something else and those opinions are simply jokes or sarcasm. If you misunderstood those words because of translator then sorry but it's not our fault. You or anyone can simply sent email or post in ppa.pl and ask about project details in english, and everything will be clear instead of trash talking and joking. Maybe we overreact a little but but put yourself in our position..... Polish Amiga community imho is one of the strongest in world ( right behind UK and GER),so you shouldn't be in state of shock that someone with skill and good idea made new expansion for our beloved computer line. Cheers |
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04 October 2018, 12:13 | #47 | |
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A lot of your response to me seems quite heated, and that's fine - I note that you're in the very trade that I am making assumptions around. If i am wrong, then obviously i'll concede to better knowledge, but there really is no need for us to get heated over any of this, agreed? You've actually raised some very interesting points that have made me re-think my outlook a little. Especially regarding 'home project' vs 'commercial' etc. I'll get back to this thread when I can, and respond to you properly - but please, this 'bee in your bonnet' stuff - it just isn't necessary or even justified. I have tried the warranty system you refer to, and it has proven to be, shall we say - not up to standard? Or at the very least i've been left with zero confidence. As we speak I am talking via email to Lotharek also seems to take issue with the same 'commerical supplier' i bought the Furia from. So it isn't as simple as you might think. Speak later - kind regards John |
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04 October 2018, 12:18 | #48 | |
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I respect the Polish amiga community. I own a Furia and it is an incredible card. I also respect the Polish. This is nothing personal at all. I am also not in a state of shock over your accelerator card. I'm sure its brilliant. I don't understand why you think this is some kind of jealousy issue? I haven't trash talked once. Once. I have been respectful whenever I have shared my opinions and even my frustrations. I think thats as clear as I can be, and i think google translate can do a good enough job of translating it to Polish if necessary. I really should get back to work, lol. John |
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04 October 2018, 12:59 | #49 | |||||
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04 October 2018, 13:07 | #50 | |
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This is exactly how the workings of this has been explained to me also (by somebody I trust). Last edited by hooverphonique; 04 October 2018 at 13:20. |
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04 October 2018, 13:29 | #51 | ||||
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That's it. If you personally declare that these two conditions are true for your product, then you can stick a CE mark on it, and it's legal. The key thing is your declaration, which is a legal document, and is why manufacturers either test or justify their guarantee instead of simply saying "it's all good". A manufacturer needs to be able to stand by their declaration, documenting why they believe it's true, but what gives them that belief is entirely up to them. Quote:
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04 October 2018, 13:36 | #52 | |
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04 October 2018, 15:34 | #53 | |
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Perhaps more relevant is the fact that there are many valid exemptions from the RoHS directive. Certain classes of medical devices are exempt, as are certain aspects of automotive, aviation, space and military equipment. One exemption in particular states that parts and products manufactured with the sole purpose of upgrading or repairing electronic equipment placed on the market prior to 2006 do not need to meet RoHS regulations. This is essentially for keeping old electronics out of landfill by extending their useful lives, but I'd say there's a pretty good argument for using this when it comes to Amigas. In this case, the RoHS directive requirements aren't applicable and a CE mark still applied based on the EMC directive, though it would be wise to have that decision and justification well documented in the design files. The WEEE regulations still apply in this situation however, so the wheelie bin symbol should be applied in any case. |
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04 October 2018, 15:38 | #54 | |
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Now please note the problem with my Furia was not CPU based, it was a few bad ram chips as i'm sure you'll know if you've read my rants. But say you have EMC testing or a legal declaration for a particular prototype, and then you sell that product with varying types of NOS (or even just salvaged) components as well as counterfeit components different from those used in the original prototype. Does that in any way invalidate the declaration/EMC test? Also, with regard to counterfeit chips coming out of China - must you be able to show that the components used are genuine and thus themselves conform to their own degree of whatever testing is required? Can you EMC test or write a declaration for one board and then sell a bunch of other boards with different chips on - all under the same declaration? I'm genuinely just curious here. See the Furia I and Solderbro have (and i'm sure a few others) has a CPU mask that idrougge claims is fake, and a date code that as far as i can research is patently impossible. Freescale stopped production of the 020 in 2010, these are stamped 2015. They carry the Freescale logo. They work!.. ish. They just shouldn't exist! I know this is splitting hairs - again its not related to my problems just a question of curiosity - but presumably if the chips used on your board are provably fake, then any EMC/safety/whatever requirements Freescale/Motorola were required to comply with (if any?) are no longer valid? What about second hand parts? If its genuine NOS then i'm going to guess its fine? What if its pulled from an old device? Does that change anything? I'm in a particularly hyper mood this week, as i'm sure you may have noticed , so if i'm bombarding you with irrelevant questions just tell me to shut the f&(k up, haha - but as i say i'm just curious. Particularly with reference to the fake chips - which unfortunately i believe we are increasingly unable to avoid. (I don't for a second believe Lorathek et al knew or in any way chose to use counterfeit parts). Cheers, John |
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04 October 2018, 16:55 | #55 | |||||||
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If there is a difference that might result in a different noise profile, the calculations made in the original justification would have to be re-done and the board adjusted to suit if necessary, or if it was tested in a lab, retesting would be required. Again, some good justification documentation here could save a lot of money, e.g. testing just the affected area of the board for changes from the original measurements instead of retesting the entire system. Quote:
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FTDI (a Scottish company incidentally) have also had their USB-serial chips cloned and used worldwide in thousands of different devices, often unknowingly by the device manufacturer, and only being discovered years later when an updated driver stopped the counterfeits (and thus the devices built around them) from working. Unfortunately for the manufacturers in these cases, buying chips directly from China means there's very little discourse when they're suddenly swamped in returned faulty devices. Buying them from EU or US sources would offer some protection, but that's not always possible. |
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04 October 2018, 17:07 | #56 |
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04 October 2018, 17:38 | #57 | ||
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In your opinion, would it be difficult/worthwhile for a fab in China to clone the likes of an 020? See - if its just a re-branded 16mhz model with a dodgy date, then it shouldn't work at 33mhz. Lotharek is right about that. It must be a 25mhz model. But at the same time it couldn't possibly have been manufactured in 2015. What about rejects? Could companies in China get hold of reject or returned 25mhz chips and re-label them with a recent date? It's just baffling to me. Seems like a lot of effort just to sell to a niche motorola 020 market - unless like I say its rebranded rejects/returns, but 25mhz models... I really don't get it. John Quote:
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04 October 2018, 17:58 | #58 | |
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If a friend sends me his TF530 PCB, and his parts, and i build it for him, and return it to him. For free. Thats just hobbyist electronics, right? I mean there's no harm in that? Okay so what if I charge him for assembly? I'm not selling him a product - i'm giving him his product back having tinkered with it. I'm assembling it for him in exchange for money - a service. I'm talking about threads the likes of 'send me your parts and i'll build your 530 - it'll cost £30 a board for me to build and send it back' for example. Would that require the same sort of CE certification as you've already mentioned? John |
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04 October 2018, 18:11 | #59 |
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CPU speeds are (or perhaps were) often determined based on testing and market demand. So (assuming the same package) all 68020s start off the same, and during testing it's found that some work fine at 33MHz, others not. Those that work are labelled 33MHz, others are labelled 16MHz, even though they're basically the same part. But if there's a batch where all the chips work at 33MHz, and an order for 16MHz parts is waiting, a certain number of the parts will be marked 16MHz anyway, just to fill the order. These parts will happily "overclock" to 33MHz, and so depending on your luck you could end up with something like that. Relabelling chips is probably fairly common (I once saw an 030 accelerator where they didn't even bother, just ground away the frequency designator so you couldn't see it was overclocked), and the selling of reject or "beta" test parts through side markets is definitely a big thing with semiconductors valued at more than a few quid each.
Yeah, that's a work-around I guess. It all gets a bit hazy, but kits are exempt, and charging just for labour is entirely out of the scope of CE marking. I've even heard of fully built boards that just need one connector soldered to it being sold as "kits", which is probably a bit of a stretch, but seems to be a used work-around. |
04 October 2018, 18:31 | #60 | ||
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What you're saying could still be very true though. 16's re-badged as 25's could well still happily run at 33. At the end of the day if they're the essentially identical, as you say, to the 25's - then they'd overclock just as much as genuine 25's. It's the unlucky few for whom that doesn't work so well. As I say Solderbro had to take it down to 25 again to get it stable, but mine seems okay at 33 despite them having the exact same print on the chip. Quote:
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