Pryor, I agree with Richards comments and would also advise having a European Lab approval (i.e. GS Mark) since CE is only self declaration.
Best Regards, Jody Leber Laboratory Manager [email protected] http://www.ustech-lab.com U. S. Technologies 3505 Francis Circle Alpharetta, GA 30004 770.740.0717 Fax: 770.740.1508 -----Original Message----- From: Pryor McGinnis [SMTP:[email protected]] Sent: Thursday, February 01, 2001 2:49 PM To: [email protected] Subject: LV Directive Hello All, A client has a device that operates at 20 Vac, >1 A and is supplied by a CE Marked "Wall Plug In" transformer. His question: Does the Low Voltage Directive apply to his device or just the plug-in transformer? If Low Voltage Directive does not apply to his device, what safety regulations do apply directly to the device? Thanks in advance. ----- Original Message ----- From: <[email protected]> To: <[email protected]> Sent: Thursday, February 01, 2001 8:31 AM Subject: RE: RTTE & Placing in Service The Commission's guide to the implementation of directives ("blue book") indicates that a device placed into service for the manufacturer's own use is not placed on the market. In the link below, see section 2.3.1 for Placing on the Market and 2.3.2 for placing in service. Specifically note the third bullet in section 2.3.2. http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/document/ chap02.pdf <http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/document /chap02.pdf> Richard Woods ---------- From: Kevin Harris [SMTP:[email protected]] Sent: Wednesday, January 31, 2001 3:58 PM To: '[email protected]'; [email protected] Subject: RE: RTTE & Placing in Service You are right Richard. More directly to your point here is a quote taken from http://europa.eu.int/comm/enterprise/rtte/interp.htm and then click on question 12 In the context of the new approach "placing on the market" is defined as: < A product is placed on the Community market when it is made available for the first time. This is considered to take place when a product is transferred from the stage of manufacture with the intention of distribution and/or use on the Community market . Moreover, the concept of placing on the market refers to each individual product, not to a type of product, and whether it was manufactured as an individual unit or in series". Now the quote is in the middle of a fairly muddled analysis and perhaps should be taken with a grain of salt but what I get from that is it seems like a sale need not take place to be taken into service and therefor you would have to notify. Best Regards, Kevin Harris Manager, Approval Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: [email protected] <mailto:[email protected]> -----Original Message----- From: [email protected] [mailto:[email protected]] Sent: Wednesday, January 31, 2001 2:04 PM To: [email protected] Subject: RE: RTTE & Placing in Service Thanks for that info Kevin. I think that publication only affects needing a Notified Body per Annex III. The -3 lists the essential test suites, so it is no longer necessary to ask a Notified Body to identify them. Richard Woods ---------- From: Kevin Harris [SMTP:[email protected]] Sent: Wednesday, January 31, 2001 2:07 PM To: '[email protected]'; [email protected] Subject: RE: RTTE & Placing in Service Hi Richard, I think it all becomes a moot point on Feb 7. I was looking at the ETSI site yesterday and they indicate there that EN 300-220-3 will be published in the OJ for the R&TTE directive on that date. EN 300-220-3 is the harmonised EN covering the essential requirements under Article 3.2 of the directive Best Regards, Kevin Harris Manager, Approval Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: [email protected] <mailto:[email protected]> -----Original Message----- From: [email protected] [mailto:[email protected]] Sent: Wednesday, January 31, 2001 12:43 PM To: [email protected] Subject: RTTE & Placing in Service Consider a low power radio transmitter subject to EN 300 220 that is to be used only by the manufacturer's service organization and will not be placed on the market for sale. EN 300 220 is a harmonized standard, but the operating frequency is not harmonized. It appears that the provisions in Article 6 do not apply since the product will not be placed on the market. Article 7 contains the provisions for putting into service. Notification to the spectrum authorities (from Article 6) does not appear to be a requirement even though the frequency is not harmonized. It appears that it is sufficient to comply with the essential requirements and apply the CE marking which must include the alert symbol per Annex VII since the frequency is not harmonized. A member state may restrict the placing in service, but only for the three reasons specified in Article 7.2: efficient use of the spectrum, interference and public health. It appears there is no legal requirement to notify the state prior to placing in service. Thus, any restriction would occur due to the state determining that one of the three reasons apply to one or more devices after it being placed in service. While it may be argued that it is a good idea to notify the states anyway, it does not appear to be a legal requirement. Comments? Richard Woods ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected] ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected] ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected] ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected] ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected]
