Mark Montrose wrote:
"RE: European Power Cords
This question relates to the use and application of power cords
provided into the EU when shipped from the USA.
A company builds one version of a highly configurable product. The
user chooses any combination of optional pwbs (over 20 different
options) plugged anywhere into a large backplane along with a choice
of several different power supply assemblies (universal auto-voltage
detect, redundant, non-redundant, etc.). The product is handled by
European distributors who order a large number of units for their
warehouses for reshipment to any country within Europe, including
non-European countries. The manufacturer, located in the USA, has
no idea what country the unit will be sold to or how it is finally
configured since this is up to the European distributor to configure
and sell the unit.
I don't think the authorities having jurisdiction give a damn about
all this. WHO makes the Declaration of Conformity and WHO holds the
technical file, the manufacturer or the distributor ???
The USA manufacturer provides a North American power cord set as a
default item to all shipping assemblies, since most units sold are
to North America. The company, at no charge, will provide to the
distributor a power cord appropriate to the end country's application
This power cord is purchased from a European power cord manufacturer,
located in the UK, and dropped shipped to the distributor, also
located in the UK (one of several European distributors throughout
the continent).
Once again, all this is irrelevant, WHO is the responsible party ?
Do you farm that responsibility out to your distributors, or are
you responsible ????
The following issues have now been raised by a sales manager in the
UK which we are unable to answer.
1. Is it legal to ship North American, 120VAC power cords into the
UK, knowing that these cords will be thrown away upon receipt?
Please provide the statutory Instrument in UK law that says
120 VAC rated cords are illegal for importation, even if they
will never be used.
Wrong question. You can ship whatever you want into the UK. The
issue is whether you can put it on the market in the UK, or anywhere IThe only
questions that you need to answer are in
else. Putting on the market is making it available to a third party,
for the purpose of distribution and/or use. By the way, storage is
not considered placing on the market. Selling to distributors is.
It is a bit US ethnocentric to expect UK law or EU law to say
something about US, 120VAC, 60 Hz powercords. In any event, the
issue here is not UK Statutes, but EU Directives, which are legally
binding laws of the European Union that become mandatory by their
transposition into national laws of the Members States. The UK has
transposed the Low Voltage Directive but that is not relevant either,
because you are distributing all over the map out of the UK.
Boxes that go to Upper Slobovia, do not have to meet EU and EEA
requirements. They probably will have to meet Upper Slobovian
requirements, once they get there.
2. Please provide the UK statutory Instrument (and any other
European Country National Law) that mandates products received
from North America must contain a power cord appropriate to
their national electric requirements, plug specific.
The UK statute is not relevant. EU Directives are. The EU Member
States must allow free movement of goods that meet the essential
requirements of all relevant Directives. Since the plugs are
different in every EU Member State, making having a specific plug
an essential requirement would immediately stop all trade in
electrical equipment.
3. In examining the LVD and EN 60950, no mention is made regarding
the legal requirement to ship a particular power cord into
Europe. The LVD para 3.2.4 mandates electrical requirements
and type of cordage required.
The LVD does not have a para 3.2.4, IEC-950 derivatives do, but will
not specify the plug. Reason is that IEC-950 is not a catalogue of
possible plugs but a safety standard. In addition, good business
acumen dictates providing the equipment with a usable plug in the
country where you sell (and instructions in a language the local
populace can understand).
4. If the USA manufacturer cannot stock variations of European
power cords, then how does your company handle this issue of
multiple power cordsets for use worldwide.
Any USA manufacturer who wants to, can stock any number of European
power cords he wants to. However, he may find it to his advantage
to let that be handled by his distributors. That has nothing to do
with technical requirements, it has something to do with the
economics of any given operation.
5. Are their any other statutory Instruments or requirements
related to power cord usage within the EU not addressed above."
YES, ANNEX I of the LVD, in particular the General Conditions will
tell you that the product should be in such a shape that it is not
likely going to kill someone. My take is that the extra power cord
won't readily lead to corpses. However, if you want to be sure,
ship without cords.
>From your questions, you need a good consultant.
Regards,
Vic
