Chris,
The LVD applies when any input or output voltage is within the scope of the
LVD and your product is not one of those items of electrical equipment or
electrical components that are not specifically excluded by the LVD. Most of
your interfaces are not within the voltage limits of the LVD, though your
modem interface could be (but this is made largely irrelevent by the R&TTED).
As many other people have already said, since your product has a modem
interface it will be covered by the R&TTED in that configuration. Since the
R&TTED has no lower voltage limits, your original question becomes moot. If
you wish to use the harmonised standards route to compliance (which most
people do) then need the product with the modem fitted must comply with a
suitable Harmonised Standard that has been listed in the OJEC as deeming to
meet the essential requirements of that Directive. Since the product with the
modem must meet e.g. EN 60950-1, then that effectively says that the product
minus the modem must also be compliant with the same standard. I am not going
to be drawn into the 'which safety standard should I use' debate, except to
say that if the Directive that applies to your product is the R&TTED then it
would seem a good idea to use one of the Harmonised Standards on the OJEC
listing under the R&TTED!
Also as others have said to you, and I have said to others, if your product
could be supplied to members of the public, or migrated to use by members of
the general public, then the GPSD applies. In fact, if your product is within
the scope of the GPSD then it applies _IN ADDITION TO_ the LVD or R&TTED. The
GPSD is far wider in scope than the LVD or R&TTED as it covers a wide range of
non-electrical products too (such as cosmetics). Therefore, the way in which
standards may be used to demonstrate safety is rather different from with the
LVD or R&TTED: nevertheless, compliance with a Harmonised Standard would
certainly be a first line of defence.
Hopefully you will now have sufficient ammunition to explain to the powers
that be why it is necessary to check compliance with a relevant Harmonised
Standard.
Both the LVD and the GPSD require you to affix the CE marking to attest
conformity, the GPSD does not contain such a provision.
You only mention concerns regarding safety, but these days you also have the
environmental can of worms to contend with. Does your product comply with the
RoHS Directive, are you registered as a producer under the WEEE Regulations in
each Member State you intend to do business in? {Although I understand that
Malta is even behind the UK in terms of transposing the WEEE Directive - I
mention this in case Malta is a big market for you.}
Regards,
Richard Hughes
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