[Elecraft] [K3] CE Mark

[Eric Swartz - WA6HHQ, Elecraft]

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
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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. 
>