Let me try to shed a little light on this issue. Gert Gremmen is right in saying that all conflicting (to the directives) national laws (and standards) are in violation of the European Laws (EU contracts). However, as far as the ergonomics and EMF requirements are concerned, there are no conflicts with EU regulations. The EU courts would not be of much help. Second, the GS issue has to do with insurance regulation very much the same way FM is conducting business in the US. GS is not some government mandated mark but strictly voluntarily. GS is however a third party certification program that really works and has international acceptance as well.
Matthias R. Heinze TUV Rheinland -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Ing. Gert Gremmen Sent: Friday, April 24, 1998 1:38 AM To: WOODS, RICHARD; 'emc-pstc' Subject: Re: GS Requirements Borth laws are conflicting with the ce-marking directive of 1992 which guarantees free market access to all equipment that is ce-marked. The ce-mark guarantees that ALL ESSENTIAL requirements for human and environmental safety have been met. As both laws are safety involved, I believe that they conflict. Therefore they are or should have been withdrawn, and anyone may contest them at the European Court. It may be essential how to meet these requirements for commercial reasons, and some test labs may suggest to you that they are obligatory, but they are not. I suggest that you propose this case to the juridical dept of DGXIII. Regards, Gert Gremmen, Ing. == Ce-test, Qualified testing == Consultants in EMC, Electrical safety and Telecommunication Compliance tests for European standards and ce-marking Member of NEC/IEC voting committee for EMC. Our Web presence: http://www.cetest.nl List of current harmonized standards http://www.cetest.nl/emc-harm.htm 15 great tips for the EMC-designer http://www.cetest.nl/features01.htm -----Oorspronkelijk bericht----- Van: WOODS, RICHARD <[email protected]> Aan: 'emc-pstc' <[email protected]> Datum: vrijdag 24 april 1998 2:49 Onderwerp: RE: GS Requirements >Did I miss something along the way? Did Germany delete the "Equipment Safety >Law" of 24 June 1968 and ammended 13th August 1980? Article 3 of the law >says, "The manufacturer or importer of technical equipment may only display >or put into circulation if it is of such a nature, in accordance with the >generally recognized rules of technology and the work safety and accident >prevention regulations . . ." The article then goes on to say " The >manufacturer or importer of an item of technical equipment may affix there >to the symbol "GS = geprfte Sicherheit (safety tested) . . . if the >equipment has undergone a type test by a Test Centre." The law goes on to >describe how the technical rules are developed. > >Remember that an EU state may have any law affecting equipment as long as it >does not conflict with a Directive. Germany has at least two such >requirements: ergonomics for workstations (PCs) and human exposure to EMF. >One cannot receive a GS mark for a PC unless it complies with the ergonomic >requirements of ZH1. That is the law and it is not in conflict with any >directive since there is no directive on ergonomics nor are there any >harmonized standards. Likewise there is no directive on EMF exposure. The >ENV 50166 series will eventually become the harmonized standards. > >Again, all of this is moot if Germany has repealed the Equipment Safety Law >which I don't beleive they have. > >Richard Woods >Sensormatic Electronics >[email protected] >Views expressed by the author do not necessarily represent those of >Sensormatic. > > >> ---------- >> From: Ing. Gert Gremmen[SMTP:[email protected]] >> Sent: Thursday, April 23, 1998 3:14 PM >> To: WOODS, RICHARD; 'emc-pstc' >> Subject: Re: GS Requirements >> >> Hello Richard, >> >> No other requirements are necessary for your products then "manufacturers >> declaration", based on EMC and/or LVD requirements/tests, who are backed >> up >> by appropriate standards to attach the ce-mark and export to europe. Make >> sure safety instructions are in the right European language. Although the >> lVD directive does not insist on this, local authorities are keen on >> maintaining safety. If any problems occcur, directly contact the >> European >> Commission by means of the appropriate office for compliants. Make sure >> you >> have a representative in Europe, who can be contacted for inspection of >> technical files. >> >> Regards, >> >> Gert Gremmen Ing. >> >> == Ce-test, Qualified testing == >> Consultants in EMC, Electrical safety and Telecommunication >> Compliance tests for European standards and ce-marking >> Member of NEC/IEC voting committee for EMC. >> Our Web presence: http://www.cetest.nl >> List of current harmonized standards http://www.cetest.nl/emc-harm.htm >> 15 great tips for the EMC-designer http://www.cetest.nl/features01.htm >> >> >> >> >> >> >> -----Oorspronkelijk bericht----- >> Van: WOODS, RICHARD <[email protected]> >> Aan: 'emc-pstc' <[email protected]> >> Datum: woensdag 22 april 1998 21:02 >> Onderwerp: GS Requirements >> >> >> >Equipment sold in Germany must comply with the GS requirements. Somewhere >> in >> >the bowels of the German Government, there must be a list of standards >> that >> >must be met in order to comply with the GS requirements. Does anyone know >> >where one can find this list? What agency is responsible for >> >maintaining/changing the list? Is there a legal methodology that must be >> >followed in order to change the list, especially a public notice prior to >> >the change? Given that a change is going to take place, are there >> standard >> >transition rules? >> > >> >The particular case at hand is that TUV has informed me that the EMF >> human >> >exposure standards have changed. VDE 0848 parts 2 and 4 have been >> replaced >> >by ENV 50166-1 and ENV 50166-2. Any further information that anyone has >> in >> >this regard would be helpful, especially information on any transition >> >rules. >> > >> > >> >Richard Woods >> >Sensormatic Electronics >> >[email protected] >> >Views expressed by the author do not necessarily represent those of >> >Sensormatic. >> > >> >
