Dear PSTC
I have sent the following to various authorities identified for the EuP at the commissions website for the directive, but so far no replies. Since there is quite a bit of European experience in this group, I would welcome any insights into the following question. "Dear Sir or Madam, My company manufactures machinery and exports it to the European Union that contains components which are, or which are likely to be, within scope of an implementing measure of the Energy Using Products (EuP) Directive (2005/32/EC). For example, ballasts for florescent lighting. The Florescent Ballast Directive (FBD) 2000/55/EC appears only to apply to ballasts that are placed directly on the EU market as a single component or incorporated into luminaries (see for example, Article 2.1). In that sense, the FBD would not apply to the ballasts integrated into my machinery. My company places machinery "on the market" not ballasts. However, looking at the EuP, I get a different sense. As we know, the FBD is an implementing measure of the EuP. In Article 1.2 the EuP states This Directive provides for the setting of requirements which the energy-using products covered by implementing measures must fulfill in order for them to be placed on the market and/or put into service.... While my company is not marketing ballasts, its seems we are indeed placing ballasts into service in the EU when our machinery, in general, is put into service in the EU. Does this mean then that the ballasts we integrate into our machines must conform to the FBD because the FBD is an implementing measure of the EuP? I would appreciate any clarification you can give on this point. " Regards, Lauren Crane (Mr.) Product Regulatory Analyst Corporate Product EHS Lead Applied Materials Inc. Austin, TX 512 272-6540 [#922 26540] -External Use- - ---------------------------------------------------------------- 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/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: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
