I don't disagree with you, only want to say that EC language is error-prone, and lawyers ran away with it. The basic issue in new approach is not a legal framework, but a system of due diligence. A small loophole in standard or formulation is not meant to offer an escape, nor meant to block a manufacturer from creating a special product.
Look at the application with the LVD, that creates an interpretation of the LVD in "approximate" terms, not legal terms. Some manufacturers have interpreted this as a way to escape from ce marking. Take fa Schaffner and other mains filter manufacturers referring to this document to state that there product is a EMC filter component and not meant to have an electrical safety function in LVD sense. Let me tell you that half of Europe uses Personal computers without a decent ground connection and you must come to the same conclusion as I: A mains filter is a safety critical component that needs ce marking. The filters that the LVD guide refers to are the ones we use in signal ports. This can be concluded from the context, and by using due diligence. Regards, Gert Gremmen, (Ing) ce-test, qualified testing =============================================== Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ =============================================== >>-----Original Message----- >>From: [email protected] [mailto:[email protected]] >>Sent: Friday, March 03, 2000 9:11 PM >>To: [email protected]; [email protected] >>Subject: Re: Technical Documentation >> >> >>In a message dated 03/03/00 12:28:55 GMT Standard Time, [email protected] >>writes: >> >><< >> In my opinion both TCF and Technical Documentation is meant to >>be the same >> in EC language. >> >> >>Hi Gert. >> >>Here's another way of coming at it. >> >>In the UK EMC Regulations, which is UK Law, the term 'Technical >>Construction >>File' is a legal entity. It has a particular description in the >>act and has >>to meet minimum criteria in order to enable a Competent Body to grant a >>compliance certificate. >> >>'Technical Documentation' is a generic term which covers anything >>included in >>a technical file that may be used to support a claim of >>Compliance under the >>Standards Route to compliance. Technical Documentation does not have to >>prove compliance, it could be photo's of a test site, test >>results, or even a >>statement that the equipment does not need to be compliant! e.g. a light >>bulb. >> >>Chris Dupres >>Surrey, UK. >>
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