A little clarification by way of example,

Traditionally if we build a power conversion product for North America, we 
provide a UL/CSA approved circuit breaker as a part of the design.  However 
if we subsequently apply for certificates from an agency in Europe they will 
insist upon a European approved circuit breaker.  Historically we have had 
no success in finding circuit breakers with multiple approvals suitable for 
both continents.  If the component has approval form an accredited test lab 
we feel that it is not unsafe to use.  What is the risk of self-declaring 
compliance to the LVD using only the UL/CSA approved part?  This would be a 
major cost savings.

A second example would be the use of an EMI filter which is already approved 
by one agency (not European).

I heard that this question was posed to the European Commission this year 
(1998) and their response was to the effect that the choice of components is 
up to the manufacturer.  I am unable to recall which email or periodical 
made this statement.  Or was it something I read in the Official Journal.  I 
tried browsing the European Commission's website and was unable to find any 
document to this effect.  It is a difficult site to navigate.

Doug Powell
Advanced Energy Industries, Inc.
Fort Collins, Colorado USA
 ----------
From: [email protected]
To: [email protected]
Subject: Agency approvals on components in CE mar
List-Post: [email protected]
Date: Tuesday, September 08, 1998 10:31AM


It is my understanding that the European Commission has stated that a
manufacturer has the freedom to determine the acceptability of components
used in CE marked products.  (Or words to that effect.)  I would conclude
that this would remove the need for using European agency approved
components in safety critical locations.  Any reputable agency approval, or
appropriate evaluation by the manufacturer, would be acceptable.

Does anyone know of where I can obtain this statement in writing?  I'd like
to have something to back this up.  Also, I welcome comments on the
conclusions I have drawn based on this "alleged" EC statement.

Regards,

Jeff Jenkins
Senior Regulatory Compliance Engineer
Advanced Energy Industries, Inc.
Fort Collins, CO  USA




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