Peter I think that your question is answered quite clearly in the second paragraph that I quoted from the guidelines, where it states: 'Following discussions with Member States the Commission has taken the position that the term "designed for use with a voltage range" shall be understood at equipment having either a rated input voltage or a rated output voltage inside this voltage range.'
Therefore the 12V to 120V (or 230V for Europe) device described in your example is quite clearly within the scope of the LVD - and, Yes, similar devices are available in Europe. For example, see the illustration of a similar device for sale on the RS Components Website in the UK at http://rswww.com/cgi-bin/bv/browse/Module.jsp?BV_SessionID=@@@@1646810601.10 34183756@@@@&BV_EngineID=ccchadcghdjlhhmcfngcfkmdgkldfhk.0&stockNo=597475&lo gText=uk520&logType=103&prmstocknum=597475&logText=uk520&logType=103 This has a UK BS1363 13A socket and carries a CE Mark - but under what Directive, or Directives, I do not know as I do not have the DoC. In fact it might well include the EMC Directive as it could be used outside of a vehicle and directly from a 12V automobile battery (a good way to run your central heating timer and boiler controls when there is a mains power cut!) The aim of the LVD is to ensure protection of persons (and domestic animals!), and the shock and fire hazards from such a device are just at least as high as a unit where the equipment is supplied at 230V and has a 230V convenience outlet - so application of the LVD (and possibly the EMCD) is entirely appropriate. Regards John Allen Technical Consultant Electromagnetics, Safety and Reliability Group ERA Technology Ltd Cleeve Rd Leatherhead Surrey KT22 7SA Tel: +44 (0) 1372-367025 (Direct) +44 (0) 1372-367000 (Switchboard) Fax: +44 (0) 1372-367102 (Fax) -----Original Message----- From: Peter L. Tarver [mailto:[email protected]] Sent: 09 October 2002 15:50 To: [email protected] Subject: Twisting the LVD (was: RE: CE Mark vs. e-Mark) John - The case of internal use of elevated voltages (as in a lap top computer screen backlight) is clearly addressed by the interpretation. To test the consistency of the interpretation, imagine a product with a supply voltage below the limits in the LVD, where the LVD would not apply to that product. That product then performs power transformation (or conversion) and, in turn, supplies other equipment (whether ancillary to the equipment performing the conversion or not) at voltages within the scope of the LVD, making the LVD applicable to the latter product. Does the term "supply" in reference to the aforementioned interpretation apply only to the energy sinking port of equipment or to all equipment ports, whether sinking or sourcing electrical energy? Example: A product available in the US (and possibly in Europe) is a power inverter that can supply household appliances using an automobile battery as its source. Handy for weekend campers that prefer to bring a few conveniences along with them. Regards, Peter L. Tarver, PE Product Safety Manager Sanmina-SCI Homologation Services San Jose, CA [email protected] > -----Original Message----- > From: John Woodgate > Sent: Wednesday, October 09, 2002 12:37 AM > To: [email protected] > Subject: Re: CE Mark vs. e-Mark > > Although the wording of the LVD implies that > the voltage limits > apply to internally-generated voltages, there is > now an official > 'interpretation' that they apply only to supply voltages. > -- > Regards, John Woodgate ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. 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