Hello Mark,
 
Much information is given in this link of my blog
 
http://globalcompliance.blogspot.com/search?q=Europe
 
Should you need special guidance regarding this issue, I can hook you with our
specialists at TUV Rheinland who are in constant communication with the
authorities
 
Best Regards,
 
Peter
 


--- On Thu, 11/5/09, Mark Gandler <[email protected]> wrote:



        From: Mark Gandler <[email protected]>
        Subject: Market survey on EuP, regulation 1275
        To: [email protected]
        Date: Thursday, November 5, 2009, 4:40 PM
        
        
        Hello, 

        Apologies in advance for raising the dead from the grave, but I have a
feeling what I am not the only one in this boat. 

        Can we have a short survey on how the consumer electronics or any other 
ITE
Class B equipment vendors intend to comply with EuP Directive, implementing
commission regulation 1275? 

        It's being discussed previously on this forum what if you believe it is
inappropriate for your product to have off or standby mode, than you don't do
it. But, new published guidance, clearly require to provide technical
justification to support your position.   

        Today we received a letter from legal department at one of the biggest 
retail
buyers in Netherlands, explicitly asking for off mode (by means of on/off
switch) and agreeing for not having standby mode. The equipment we sell to
them revolves around home networking: wlan, gateways, routers, switches. 

        Can we all share some opinions, if you prefer without mentioning your 
company
name, on this matter? Are your products going to have off mode? if not, what
is your technical justification?

        Just some known facts: if product is Class A, it is exempt. If product 
uses
6V or less adapter, it is exempt. Off mode is defined by being still connected
to mains (here goes one of the arguments of disconnecting power cord), but not
providing any function. 

        Not a fact, but there most likely will be different document for 
networked
standby, so we might can get a away for now from having standby mode for
networking equipment. 

        As well I believe there is a preparatory study going in one of the EU
commission, excluding all networking products from 1275. 

        And last, but not least, Switzerland has their own law/regulation on 
this
matter, which somewhat differ from EU.

        Do we have anyone on this list who is (or can point us to) some kind of
authoritative figure or institution whom we can contact to get some answers?
can I go to attend some EU commission hearing on the matter? Are where any
experts for hire who can provide their opinion? NB? CB? 


        Mark


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This message is from the IEEE Product Safety Engineering Society emc-pstc
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