That's odd! In my copy of the LVD, every article is addressed to the "member states". It primarily establishes the commom "rules" for safety within the EU. It is up to the member states to execute and enforce the Directive. The Commission has no enfocement authority over manufacturer.
However, in setting the rules, and suggesting ways in which manufacturers can show proof of conformity, the LVD indirectly requires certain actions by manufacturers. However, ALL Directives are addressed to member states, as to what they must, and cannot, enforce in the way of requirements. Pages 1 and 2 clearly state that the primary purpose of the Directives are to promote better trade within the EU by the adoption of more common requirements. Actually, the EU Directives make it easier for manufacturers to do business there as there is one set of requirements for the entire EU rather than the many that existed before. Using the self-declaration method, backed by EMC test data, and a CB Certificate and Test report, is far easier than each state wanted to test each product to slightly different standards. Conforming to harmonized standards, where they exist, is far easier than using a technical construction file to show how the product attempts to conform. At least, that's my opinion, and we have products approved from Spain to Russia, not counting North America and the Pacific Rim. George Alspaugh "James, Chris" <cnj%[email protected]> on 06/11/98 04:21:54 AM To: George Alspaugh@LEXMARK, Gary Labadie <glabadie%[email protected]> cc: emc-pstc%[email protected] bcc: Subject: RE: Isolation versus IEC1010 >Note that the Low Voltage Directive merely requires member states to >approve the import of only electrical products that are "safe". It >is not directed to manufacturers, nor does it say HOW a manufacturer >must meet this condition Sorry, but have to disagree with this statement - the onus is on manufacturers to produce compliant product and indicate such by the application of the CE mark. That is if they want to market product for use in the EU. It has nothing to do with what member states approve to import. One can import what you like but must not place on the market or even use non compliant product. No it does not say how to comply - you don't even have to use the standards to show you comply - but the standards are there as an "easy" recognised and accepted way to show one does comply. Using the standards only shows pressumption of compliance with a directive i.e. it does not explicitly mean it does comply. Chris > -----Original Message----- > From: [email protected] [SMTP:[email protected]] > Sent: Wednesday, June 10, 1998 9:15 PM > To: Gary Labadie > Cc: [email protected] > Subject: Re: Isolation versus IEC1010 > Note that the Low Voltage Directive merely requires member states to approve the import of only electrical products that are "safe". It is not directed to manufacturers, nor does it say HOW a manufacturer must meet this condition. Typically, one can either get a complete > CB Report to IEC 60950, or explain each and every aspect of the > equipment and how it prevents against the kinds of hazards listed. > These are the two extremes. > > Now, what does the specified voltage range mean? The scope of IEC > 60950 includes equipment that is mains or battery powered. Mains > voltages are hazardous, and batteries can generate terrific heat > when shorted, leading to fire. > > The issue is where your 24V device gets its power. If the mains to > 24V convertor is part of the equipment, it definitely falls into the > LVD range. If the 24V comes from "somewhere else", what is the > current (power) limitation coming into your device in the event of a > fault? What other limitations must be placed on the incoming power > bus to avoid the usual IEC 60950 hazards? > > If you can demonstrate that the entire unit is 24V or below, and is > well protected against hazards induced from outside, it is possible > that it might fall outside the scope of the LVD. > > George Alspaugh > > > > > Please respond to "Gary Labadie" > <glabadie%[email protected]> > > To: emc-pstc%[email protected] > cc: (bcc: George Alspaugh) > bcc: George Alspaugh > Subject: Isolation versus IEC1010 > > > > I would like to get the consensus on the following concept. > > The low Voltage directive applies to products that use 50VAC or 75VDC > and > higher signal levels basically up to 1000VAC. Now, If a product's I/O > and power signals do not exceed 24Vdc anywhere, does the low voltage > directive apply. Here's the catch, the unit contains electrical > isolation between input, output and power signals. The electrical > isolation rating is specified as 250VAC continous. > > Some argue, that since the unit is isolated and has an isolation > rating > the Low voltage directive applies because the isolation specification > exceeds 50VAC. You can also argue that within the scope of the Low > Voltage directive that the I/O and power signals are below the > directives > requirement and hence do not apply if you don't consider whether the > product has electrical isolation or not. > > Does the fact that electrical isolation is included into a product, > affect whether the Low Voltage Directive may or may not apply? > > Best Regards, > > Gary Labadie > Marketing > > Acromag, Inc. > 30765 Wixom Rd. Ph: (248)624-1541 ext. 205 > P.O. Box 437 Fax:(248)624-9234 > Wixom, MI 48393 Email: [email protected] > >
