Hi Steve. My opinion, based on my experience is this:
1. Yes, the product is exempt from the LVD for the reasons stated. 2. If the product is intended to be built into a system, and not used as a standalone device, AND responsibility for the overall system will be declared by the OEM, then you are not obligated to test, mark the product, or show conformity under the EMC Directive either. I think if you put together a declaration indicating both of these factors, you will be in compliance with European Directives. You might want to use the declaration format provided in the Machinery Directive for subassemblies. At least the authorities will be familiar with it. (Theoretically.) You may need to provide contact information for the company who will be taking responsibility for the product while it is in Europe. As far as whether some sort of bond is required while the product is in Europe - I've not heard of this, but that sort of thing sounds like an enforcement issue. Enforcement falls under the jurisdiction of the Member State to which the product is shipped. Each member state my have its own method of dealing with it (or not dealing with it). Greg Galluccio www.productapprovals.com ------------------------------------------- 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: Ron Pickard: [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: http://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
