Jim
I agree with your comments about the AEMC Directive, but not (in general)
with those about the LVD for the simple practical fact that the (current)
nominal voltage limit for the latter is 50Vac/75Vdc - and few vehicle
supplies are that high.
About the only cases where I can see the LVD applying to vehicle
installations are when:
a) Parts of the vehicle internal systems are designed for connection to an
external mains supply when "docked" (e.g.: mains-charging of batteries, or
powering of on-board mains-powered equipment such as radio or tv systems);
b) The vehicle has an on-board diesel/petrol-powered mains generator for
similar equipment;
c) The vehicle has an on-board battery-to-mains inverter for similar
equipment;
d) The vehicle has on-board equipment with another type of output at
>50Vac/75Vdc, e.g. a special use DC output power supply or a high-power
radio transmitter with high-voltage outputs.
(We had all those at my previous company which made and installed military
vehicle systems)
In almost all other cases the LVD does not currently apply (although that
might change if the Directive is amended in the way it is currently being
discussed at some length, including removal of the lower voltage limit) -
but the R&TTED might apply if there is telecomms equipment of some sort,
since that has no lower voltage limit.
In the absence of R&TTED issues, the most probable applicable "safety"
directive is the General Product Safety Directive 92/59/EC, which is not a
"CE Marking" Directive - but where essentially the same safety standards can
be applied as under the LVD (etc) as evidence of "due dilegence". In
addition, there are the specific EMC automotive standards - as mentioned
last week in Chris Chileshe's email of 27 Sept, which can be deemed to be
"safety directives" in the context of vehicle operational safety (but again,
not for CE Marking).
Probably the most important aspect of all this is to perform a risk
assessment and standards identification exercise to identify the risks and
the relevant precautionary standards and methodologies - and then apply
these, and record the whole exercise in a formal Technical File (even if a
Directive does not strictly call for one) so that your investigations,
evidence and arguments are clear if the question of safety ever arises from
a legal authority or customer.
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: Jim Eichner [mailto:[email protected]]
Sent: 08 October 2002 00:40
To: 'EMC-PSTC - forum'
Subject: CE Mark vs. e-Mark
Let's suppose you have a product that is bound only for automotive
aftermarket applications, and while it complies with the LVD and the
Automotive EMC Directive (AEMCD), it fails to pass the EMC Directive (EMCD).
For EMC purposes, the directives are very clear: you do not need to meet
the EMCD if your product is solely automotive, only the AEMCD. However for
safety purposes the LVD still seems to apply, suggesting you need to have
the CE Mark. However using the CE Mark requires using all applicable
directives, therefore necessitating compliance with the EMCD, which our
theoretical product does not comply with.
Is there any way to do a "safety only" CE Mark accompanied by the e-Mark for
EMC, thus covering both required bases in the automotive world?
Am I missing a more obvious solution?
Thanks,
Jim Eichner, P.Eng.
Regulatory Compliance Manager
Xantrex Technology Inc.
e-mail: [email protected]
web: www.xantrex.com
Any opinions expressed are those of my invisible friend, who really exists.
Honest. No really.
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To cancel your subscription, send mail to:
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