You do not make it clear as to what Directive you are referring to.  I can
respond regarding safety and the LVD.  The requirements under the LVD are
that equipment must be safe and complying with the principle elements of
the safety objectives of Annex I and that they should be constructed in
accordance with good engineering practise.  If the product complies with
the safety provisions of harmonized standards (listed in the OJ) then in
general it shall be considered to be safe.

The Directive does not say that products not complying with standards are
unsafe, and it does not directly specify which standard should be used for
a particular product (this is only obtained from the scope of the standard
in the OJ).  Therefore you can apply any requirements you like including
those of a 'non-appropriate' standard as long as the product is safe in the
situation that it being used.  If you use an inappropriate standard and the
product is found to be unsafe, you will be liable! - particularly if using
the appropriate sandard would have made the product safe.

Using the example below the options are:
   Retest to the appropriate standard for audio/video (Much of the testing
   will already be covered by the testing to the primary use standard),
   then list the new standard on the DOC.
   Make the judgement that there are no additional hazards associated with
   the secondary use and that compliance with the standard already used is
   sufficient, do not list the new standard as it has not been used.
   If your product is certified with an agency and the secondary use will
   also require certification, I expect there will be no choice but to use
   the new standard

I hope this helps.

Best regards

Glenn Moffat
TUV International UK
Tel: +121 634 8000
Fax: +121 634 8080


Assume a product is primarily intended for a particular use (example: CCTV
for surveillance use) and the appropriate ENs are applied for that intended
use and a Declaration of Conformity is issued listing the applied standard.
Now assume that the product is marketed and sold for a secondary intended
use (example: professional audio/video) where the same essential
requirements apply but other ENs exist for that application. Is it legally
required to also apply the other ENs and list them on the Declaration?


-------------------------------------------
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.

Visit our web site at:  http://www.ewh.ieee.org/soc/emcs/pstc/

To cancel your subscription, send mail to:
     [email protected]
with the single line:
     unsubscribe emc-pstc

For help, send mail to the list administrators:
     Michael Garretson:        [email protected]
     Dave Heald                [email protected]

For policy questions, send mail to:
     Richard Nute:           [email protected]
     Jim Bacher:             [email protected]

All emc-pstc postings are archived and searchable on the web at:
    No longer online until our new server is brought online and the old 
messages are imported into the new server.

Reply via email to