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Old 11 October 2018, 14:47   #81
Daedalus
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Originally Posted by project23 View Post
Btw i've been reading a bit and i think RoHS 2 is mandatory for CE now, so no accelerator with a non RoHS chip (very few) as the CPU can't be CE stamped.
RoHS was already mandatory for CE stamping, and RoHS 2 is just a revised version of the directive.

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Can an accelerator be regarded as a replacement part (they're exempt)? After all you're replacing the original CPU. I just think thats one hell of a narrow loophole, hah.
Spare parts are exempt (and are allowed to upgrade the original equipment, so CPUs don't have to be a 1:1 replacement), but to qualify under that rule, the original equipment would have to have stopped working. But that's not really where you should be looking. There is also an exemption that applies for repairs and upgrades to equipment sold before 2006 that would qualify, as it isn't just about spare parts for repair. I'll have to look up the exact wording, but it's to the effect of using parts to upgrade functionality or capacity. The re-use of second-hand parts is also allowed, provided it's all documented as such, so if the old CPUs can be considered pulls from old equipment, they should be exempt that way too. Whichever way you approach it, there's plenty of scope there for justifying the use of 68K CPUs.
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Old 11 October 2018, 14:55   #82
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RoHS was already mandatory for CE stamping, and RoHS 2 is just a revised version of the directive.


Spare parts are exempt (and are allowed to upgrade the original equipment, so CPUs don't have to be a 1:1 replacement), but to qualify under that rule, the original equipment would have to have stopped working. But that's not really where you should be looking. There is also an exemption that applies for repairs and upgrades to equipment sold before 2006 that would qualify, as it isn't just about spare parts for repair. I'll have to look up the exact wording, but it's to the effect of using parts to upgrade functionality or capacity. The re-use of second-hand parts is also allowed, provided it's all documented as such, so if the old CPUs can be considered pulls from old equipment, they should be exempt that way too. Whichever way you approach it, there's plenty of scope there for justifying the use of 68K CPUs.
Thanks, it's all so bloody confusing. I'm reading a couple of RoHS PDF's and looking at wikipedia obviously but obviously i'm just a layperson.

So far my understanding was RoHS initially was separate from the CE stamp. RoHS 2 came into effect in 2013 and was mandatory for the CE stamp therefore making unnecessary the RoHS (wheeliebin?) mark for CE stamped devices after 2013.

I'm also reading in this RoHS 2 FAQ that electronic boards, including the likes of graphics cards, are not regarded as finished EEE devices despite the fact that the finished product with the device installed in is a finished EEE device itself.

I've yet to read/understand how finished and unfinished EEE matters, haha.

You can tell i'm not in work this week can't you

John
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Old 11 October 2018, 15:09   #83
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From my point of view ... even if I could justify everything satisfactorily ... if I were hauled up to a court/hearing to do that it would cost me more than just doing the testing.
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Old 11 October 2018, 15:35   #84
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From my point of view ... even if I could justify everything satisfactorily ... if I were hauled up to a court/hearing to do that it would cost me more than just doing the testing.
First this is all hypothetical. I'm not trying to persuade you to do anything commercial, or anything like that. I just find the subject quite interesting.

Fair point - have you actually looked into how often cases as small as yours (i mean you'd be selling what, a few hundred boards a year max?) come about?

I imagine you'd be on the bottom of a list and the penalties would be at the low end of the scale, especially for a small business. I'm talking the 'declaration' route here, not the testing.

Not a suggestion, just thinking out loud really.

EDIT: I mean the only real concern is EMI, right? And as a Ham (i get the feeling you are too? you've spoke of SDR or a few times i think - or just a passing interest?) I can tell you that even big cases of EMI infringement, like those bloody homeplugs (imagine your vertically running twin and earth power cables acting as antennas on the homeplug frequencies and their harmonics) - Ofcom/etc don't seem to give a rats a$$.

The problem arises if your EMI issues are on bands/harmonics reserved for commercial/military/medical/or otherwise reserved bands and they make a complaint. This can be easily checked for and a solid argument made based on the frequencies used and the low power consumption. You're not using anything resonant with 25, 33, or 50 megs, and the 7meg side is taken care of by prior compliance by commodore I guess. I'll look up some compliance numbers if i can - purely out of curiosity - again i'm not trying to give you advice or persuade you to do anything anything. I just think its an interesting discussion is all.

John

Last edited by project23; 11 October 2018 at 15:49. Reason: EMI stuff
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Old 11 October 2018, 16:11   #85
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Thanks, it's all so bloody confusing. I'm reading a couple of RoHS PDF's and looking at wikipedia obviously but obviously i'm just a layperson.
There's a lot of paraphrasing and so on out there, but the full directive can be found here.

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So far my understanding was RoHS initially was separate from the CE stamp. RoHS 2 came into effect in 2013 and was mandatory for the CE stamp therefore making unnecessary the RoHS (wheeliebin?) mark for CE stamped devices after 2013.
Well, yeah, that's sort of it. RoHS was always a CE directive, but being tied to the CE mark came in in the 2011 revision. Prior to that it had its own RoHS marking that was generally seen alongside the CE mark, though IIRC it wasn't mandatory. The Wheelie-bin logo is different, that refers to WEEE compliance, which is the recycling of equipment that could potentially contain hazardous materials and makes certain obligations on the original manufacturer, like free recycling of the item being replaced and so on. That's mandatory and independent from the CE mark.

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I'm also reading in this RoHS 2 FAQ that electronic boards, including the likes of graphics cards, are not regarded as finished EEE devices despite the fact that the finished product with the device installed in is a finished EEE device itself.
Hmmm, it is a little vague to be fair, but in general it comes down to the end user. If the product is only ever intended to be installed as part of the manufacture of another product, then it's classed as a component, not a finished product (the finished product still has to satisfy the CE directives however...) But most graphics cards, sound cards and so on are intended to be bought and fitted by the end user, and as such need to comply in their own right, and you'll see that most manufacturers include a declaration of conformity with the board, and also usually online for download.

I looked up the exemptions, and the particular parts that are of interest are from Article 4:
Quote:
1. Member States shall ensure that EEE placed on the market, including cables and spare parts for its repair, its reuse, updating of its functionalities or upgrading of its capacity, does not contain the substances listed in Annex II.
where Annex II lists all the regulated substances and the maximum allowed concentrations. This paragraph is what requires each EU member state to pass laws enforcing compliance with the directive. The exact wording may change from state-to-state, but most (including the UK) are pretty much the same.

And then:

Quote:
4. Paragraph 1 shall not apply to cables or spare parts for the repair, the reuse, the updating of functionalities or upgrading of capacity of the following:

(a) EEE placed on the market before 1 July 2006;

(b) medical devices placed on the market before 22 July 2014;

(c) in vitro diagnostic medical devices placed on the market before 22 July 2016;

(d) monitoring and control instruments placed on the market before 22 July 2014;

(e) industrial monitoring and control instruments placed on the market before 22 July 2017;

(f) EEE which benefited from an exemption and which was placed on the market before that exemption expired as far as that specific exemption is concerned.
Points (b)-(f) aren't relevant for Amiga stuff (though we took advantage of (c) to re-use older PCB designs in some of our products so they could be on the market while we took our time redesigning them with newer parts). But point (a) clearly applies in the case of Amigas, which for the most part qualify by over a decade. So the laws put in place to apply paragraph 1 are required to include exceptions for "updating the functionalities or upgrading the capacity" of pre-2006 equipment. I think that's pretty straightforward.

Also of interest:
Quote:
5. Paragraph 1 shall not apply to reused spare parts, recovered from EEE placed on the market before 1 July 2006 and used in equipment placed on the market before 1 July 2016, provided that reuse takes place in auditable closed-loop business-to-business return systems, and that the reuse of parts is notified to the consumer.
Ah, it appears the reuse of pulled CPUs clause expired in 2016. Sorry, I hadn't remembered that detail...

And finally:
Quote:
6. Paragraph 1 shall not apply to the applications listed in Annexes III and IV.
Annexes III and IV are specific niche cases where the properties of the restricted materials are intrinsic to the operation of the part, such as radiation sensors, certain types of lighting, ultrasonics, various medical equipment and so on, and are intended to give these industries more time to develop alternative methods.
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Old 11 October 2018, 16:14   #86
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The issue is they tend to look at penalties in terms of company performance. My livelihood is through my business so I’m not going to risk that for something with such small profits. Spending 3 days of my time on this would simply be more expensive than EMI testing. And EMI testing is more than the profits you ever see selling Amiga hardware... and people still moan about the prices.
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Old 11 October 2018, 16:18   #87
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The issue is they tend to look at penalties in terms of company performance. My livelihood is through my business so I’m not going to risk that for something with such small profits. Spending 3 days of my time on this would simply be more expensive than EMI testing. And EMI testing is more than the profits you ever see selling Amiga hardware... and people still moan about the prices.
*nod*

Didn't realise you already had your own business, thought this'd just be a side thing. Make much more sense now.
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Old 11 October 2018, 16:28   #88
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cut for space saving
Thanks, that clears a lot of stuff up, and i'm sure raises a lot more questions!

Thanks for the link, i'll give it a read over. I take it this is separate to the conditions of the actual CE certification, which from what you've said previously I believe in the case of Amiga cards only really includes EMI testing?

So with the properly prescribed declarations (whatever that costs) or EMI testing, it seems that accelerator cards for the Amiga can certainly be CE stamped today even if they contain 'spare parts' that are non RoHS compliant.

So it really would just be a case of someone drafting the appropriate declaration that testing isn't necessary I guess?

Cheers for all of this - it really is an interesting/complicated mess.

John
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Old 11 October 2018, 16:49   #89
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Thanks for the link, i'll give it a read over. I take it this is separate to the conditions of the actual CE certification, which from what you've said previously I believe in the case of Amiga cards only really includes EMI testing?
Well, this is another directive like the EMC directive that must be complied with, but from the parts I posted there it would appear that Amiga cards are indeed exempt, leaving them under the scope of just the EMC directive (and, of course, what ever local laws apply where they're being sold).

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So with the properly prescribed declarations (whatever that costs) or EMI testing, it seems that accelerator cards for the Amiga can certainly be CE stamped today even if they contain 'spare parts' that are non RoHS compliant.
That's what it looks like, yes. But the declaration and EMI testing aren't mutually exclusive. The declaration must always be made to apply a CE mark, how you arrive at a position in which you can make that declaration is up to you.

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So it really would just be a case of someone drafting the appropriate declaration that testing isn't necessary I guess?
That's not really how the declaration works. The actual declaration will only list which directives apply and the standards that are met to show compliance with the directive. If directives aren't applicable, you don't list them.

What you should have is proper documentation of how you arrived at the position of being able to make the declaration. That will include an assessment of all relevant directives, and a rationale explaining any exemptions applied. That will also include results of any testing carried out, and details of any calculations and simulations carried out in lieu of testing. These documents need to be held for a minimum length of time after the product is sold (IIRC this is 10 years for consumer electronics, it's indefinite for medical devices).
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Old 11 October 2018, 18:18   #90
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Take a look here, this is what I've done;


https://github.com/PR77/A500_ACCEL_RAM_IDE-Rev-2
That looks very neat, kudos!
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Old 11 October 2018, 18:43   #91
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What you should have is proper documentation of how you arrived at the position of being able to make the declaration. That will include an assessment of all relevant directives, and a rationale explaining any exemptions applied. That will also include results of any testing carried out, and details of any calculations and simulations carried out in lieu of testing. These documents need to be held for a minimum length of time after the product is sold (IIRC this is 10 years for consumer electronics, it's indefinite for medical devices).
Probably some confusion here. What i was referring to by 'declaration' was what was mentioned a few pages back by having a document drafted basically arguing why EMC testing isn't necessary because of x, y, z, etc, by thorough analysis of the board.

Cheers again,

John
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Old 11 October 2018, 18:48   #92
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Ah yes, as opposed to the formal declaration. I would think of such documents as justifications or rationales, not declarations. Sorry
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Old 11 October 2018, 19:11   #93
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First boot with 68040 cpu

[ Show youtube player ]
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Old 11 October 2018, 21:04   #94
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Cool ! Hope that i can buy it soon !!
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Old 11 October 2018, 23:28   #95
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project23 why would i care if something has a warranty or not , if its proved to work why would i care about it blowing up as i can just buy another , like plasmab stuff its awesome and its just a hobby at the end of the day its all fun if it works and if it dont worth a try .
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Old 11 October 2018, 23:38   #96
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project23 why would i care if something has a warranty or not , if its proved to work why would i care about it blowing up as i can just buy another , like plasmab stuff its awesome and its just a hobby at the end of the day its all fun if it works and if it dont worth a try .
How is something 'proved to work' if you acknowledge it might 'blow up' enough for you to talk about buying another. This message is a little self contradictory, don't you think?

Maybe you have money to blow on such things on a whim. I personally refuse to risk £100 on something that might 'blow up' as you say without any recourse and without the means to repair it myself in the spirit of the hobby it is.

Just my opinion of course.

John

BTW I don't see how this relates to this current discussion? It has nothing to do with how designers and builders may be offended by demands and complaints?

EDIT: Apologies, i confused you with TjLazer. My response doesn't change though (except the 'BTW' bit of course)

@TjLazer - Why don't we just leave this as follows - you didn't mean offence, but the choice of words was the kind that has been heard hundreds of times over and worn designers down to the point that they literally leave the community. Demands and complaints are always remembered - praise isn't.

Last edited by project23; 11 October 2018 at 23:53.
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Old 12 October 2018, 00:59   #97
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I keep looking into this thread hoping for some more information about the actual card.... but no, it’s the same thread derailment that’s been going on for 5 pages now. Please give it a rest or get back on topic or start your own bloody theead.
There is a new video.I posted it few pages ago earlier today.

CS540 boot up with 68040 CPU.

[ Show youtube player ]

There is plenty of hard ware project wich are never notice (or too late) in these English speaking forums.
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Old 12 October 2018, 06:21   #98
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Nice! It must not have fast ram on it as it’s running slow? Can’t wait to see more info on it. A 68040 finally! I’m sure it’ll run hot in the tight case. Hope it won’t have overheating issues like the 3000.
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Old 12 October 2018, 11:44   #99
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It's nice to have a choice, but personally I'm not looking forward to a 68040 expansion.

The 040 does have some (minor) compatibility issue, it is difficult to cool properly on a "keyboard" Amiga, and you need to upgrade your power supply. (it would work for a while with the original PSU, but I've seen many C= PSU eventually dying on these 040 accelerators)

Beside, is there really that many software that requires it ? A few cool demos sure, would also help Lightwave, and maybe also Vroom (for some reason, it doesn't seem to run much better on a 030 compared to a 68000 but get very smooth on a 040). That's about it.

If you compare to the huge improvement the 68030 brings over the 68000, the extra processing power brought from the 68040 over the 68030 is fairly minor. (not in term of actual performance - the difference is huge - , but in term of what it actually brings you as an Amiga user)

It made a lot of sense in the 90s, when we were still hoping for new softwares to take advantage of it. Nowdays, it's still cool, but to me it's not worth it.

I'm happy for people looking forward to it though, but a 68030 extension makes a lot more sense to me.
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Old 12 October 2018, 12:53   #100
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I look away for one evening and come back to this. Please from now on only discuss the progress of the CS540 accelerator and start a new thread on another subforum to discuss any related subject.

If this is impossible, my remaining options are to delete anything that is not a progress update, request for information or congratulation post or just lock this thread.

Edit: I have deleted about 20 posts from here as per the reports sent to the moderation team.

Last edited by Jope; 12 October 2018 at 14:42.
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