The message was also for the group, my mistake... It depends,
If the product is sold with a manufacturer provided adapter, then the product has a mains connection. -> LVD
(it is not because there is a connector between power supply and equipment that it becomes safe)
If the product is sold without, it has only the ELV DC connection. -> No LVD LVD is about more than just insulation from the mains.The whole concept of voltage limits in the LVD is wrong, the idea that a device is inherently safe if supplied by 24 volts (for example) is evidently wrong; this is also why those limits has been removed in the RED.
Gert On 10-4-2019 19:32, John Woodgate wrote:
Hello, Gert. Did you mean to reply only to me or to the mailing list? I don't understand your reasoning. The product itself runs from ELV DC, so, even though there is a power supply next to it in the box, surely the LVD doesn't apply? It does, of course, apply to the power supply that is supplied with it.Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associateswww.woodjohn.uk Rayleigh, Essex UK On 2019-04-10 17:51, Gert Gremmen / Ce-test wrote:It depends..If the power supply is an inherent part of the product as “put on the market” then the lvd should apply. If not, so the customer is supposed to buy an adapter himself , then the product is supposed to be a dc supplied product and if this supply voltage is outside the limits for the lvd, such as 5 or 12 voltDC , then the lvd does not applyGert Verstuurd vanaf mijn iPhoneOp 10 apr. 2019 om 18:03 heeft John Woodgate <j...@woodjohn.uk <mailto:j...@woodjohn.uk>> het volgende geschreven:I think:/Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case./The product is outside the LVD/.// //Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures?/The ECO Directive applies to the power supply, not the product./Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC?/It seems a logical solution, and I doubt that it is explicitly prohibited.Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associateswww.woodjohn.uk Rayleigh, Essex UK On 2019-04-10 16:51, Matthew Wilson | GBE wrote:A consumer product is powered by AA cells but also can derive its power from a 'wall wart' mains-DC PSU via a DC jack input on the product. The client who is the manufacturer of the product (as per the EU directive) has decided to supply a third-party wall-wart PSU in the box with the product. The PSU does not carry the product manufacturer's logo but that of the PSU manufacturer (or possibly its importer/distributor assuming the responsibility of manufacturer because it will inevitably be made in Far East).Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case.Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures?Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC?Any thoughts welcome thanks. Regards all. <image723269.png>Disclaimer:This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please delete it from your system, do not use or disclose the information in any way and notify the sender immediately. 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