Neil, Raymond And then, of course, you have the General Product Safety Directive 2001/95/EC which - at least for "consumer" products - is the "catch-all" safety directive for items which are outside the scope of any existing sector-specific directive. Whilst this is not a "CE Marking" directive, Articles 1 and 2 give the broad requirements, and the criteria for safety are given in Article 3, and essentially apply the same general concepts and rules as for the "CE Marking" safety directives such as the existing LVD. Therefore, if you apply the latter to consumer electrical/electronic products - regardless of the voltage range in question - you should be in a position to justify that the products are appropriately safe, and you will be moving in the right direction for compliance with the revised LVD - if the latter ever gets to publication! However, regardless of which approach you take, you should also seriously take into account the draft text of the revised LVD, and particularly Annex I where the first requirement is to perform a comprehensive risk assessment in line with the various potential hazards identified in that Annex I. This approach should provide you with the evidence of safety in a most comprehensive and effect manner - regardless of what else you do do. John Allen Note: Articles 1 & 2 of the GPS are shown below:
Article 1 1. The purpose of this Directive is to ensure that products placed on the market are safe. 2. This Directive shall apply to all the products defined in Article 2(a). Each of its provisions shall apply in so far as there are no specific provisions with the same objective in rules of Community law governing the safety of the products concerned. Where products are subject to specific safety requirements imposed by Community legislation, this Directive shall apply only to the aspects and risks or categories of risks not covered by those requirements. This means that: (a) Articles 2(b) and (c), 3 and 4 shall not apply to those products insofar as concerns the risks or categories of risks covered by the specific legislation; (b) Articles 5 to 18 shall apply except where there are specific provisions governing the aspects covered by the said Articles with the same objective. Article 2 For the purposes of this Directive: (a) ‘product’ shall mean any product — including in the context of providing a service — which is intended for consumers or likely, under reasonably foreseeable conditions, to be used by consumers even if not intended for them, and is supplied or made available, whether for consideration or not, in the course of a commercial activity, and whether new, used or reconditioned. This definition shall not apply to second-hand products supplied as antiques or as products to be repaired or reconditioned prior to being used, provided that the supplier clearly informs the person to whom he supplies the product to that effect; (b) ‘safe product’ shall mean any product which, under normal or reasonably foreseeable conditions of use including duration and, where applicable, putting into service, installation and maintenance requirements, does not present any risk or only the minimum risks compatible with the product's use, considered to be acceptable and consistent with a high level of protection for the safety and health of persons, taking into account the following points in particular: (i) the characteristics of the product, including its composition, packaging, instructions for assembly and, where applicable, for installation and maintenance; (ii) the effect on other products, where it is reasonably foreseeable that it will be used with other products; (iii) the presentation of the product, the labelling, any warnings and instructions for its use and disposal and any other indication or information regarding the product; (iv) the categories of consumers at risk when using the product, in particular children and the elderly." ----- Original Message ----- From: Barker, <mailto:[email protected]> Neil To: '[email protected]' ; [email protected] Sent: Wednesday, March 16, 2005 8:59 AM Subject: RE: Electronic products operating below 50 Vac/75 Vdc Raymond, It is quite simply that when the LVD was first published (32 years ago in 1973!!) voltages below 50Vac, 75Vdc were not considerd to present a hazard, and of course there were not nearly as many low voltage powered devices around then. However, the R&TTE Directive applies the requirements of the LVD without lower voltage limit, so anything that falls within the scope of R&TTE is covered. Further, the LVD itself is currently under review, and it seems very likely that a new LVD will also remove the lower voltage limit. Of course, some standards, notably 60950, include voltage limits within their scope, so no doubt they will also have to be revised, but applying them to low voltage products regardless of what the scope says is simply demonstrating due diligence in addressing product safety. Best regards, Neil R. Barker C.Eng. MIEE FSEE MIEEE Manager Compliance Engineering e2v technologies (uk) ltd 106 Waterhouse Lane Chelmsford Essex CM1 2QU UK Tel: +44 (0)1245 453616 Fax: +44 (0)1245 453410 e-mail: [email protected] Web: http://www.e2v.com <http://www.e2v.com/> From: [email protected] mailto:[email protected]] Sent: 15 March 2005 17:54 To: [email protected] Subject: Electronic products operating below 50 Vac/75 Vdc The scope of LVD directive includes electrical products operating 50-1000 Vac/75-1500 Vdc. On the market, a lot of electrical products especially electronic products are operating under 50 Vac/75 Vdc. Why doesn't LVD Directive cover the products operating under such voltage? Can someone advise which directive or regulation covers this loophole in EU currently. Thanks and regards, Raymond Li ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [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://www.ieeecommunities.org/emc-pstc ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to [email protected] Instructions: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas [email protected] Mike Cantwell [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://www.ieeecommunities.org/emc-pstc
