In the realm of industrial use products on the DoC or Do we had the number and name of the standard(s) that were used to confirm conformance to the Directive. While market surveillance was never a problem for us, and customs in one EU Member State only questioned our product once, and that due to their misinterpretation of the product type, we found that more often it was the customer who asked what the standards were when we only used the number. The question usually came from someone in Purchasing or Quality when they got their copy of the DoC or DoI when the product arrived on their doorstep.
>From then on it was decided to use name in conjunction with the number. And since we had templates for the DoC or DoI and only changed the variables (serial number, date, DoC or DoI document number, etc.) it was not a problem. Steve Brody sgbr...@comcast.net stev...@productehsconsultng.com www.ProductEHSConsulting.com -----Original Message----- From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Monday, November 19, 2012 9:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU-DoC - list of applied standards with full title I think this all begs the question, has anyone experienced any problems with their EU DOC by not providing the Standard's Title? If so, what was the objection and what was necessary to resolve it? The official titles of directives and standards are often way too long and often more confusing then descriptive. We reference directives and standards on our EU DOC by their number and date and follow it with a brief description and sometimes additional useful information. Such as: EN 61010-1:2010 Safety of Laboratory Equipment Or EN55011:2007+A2:2007 RF Emissions Group 1, Class A The directives requirements are, "a reference to the harmonized standards used", so I would think as long as you provide enough information so it is clear what the standards are you should be ok. We think about what information our customers and others might want to see in the DOC and include it if we can. The more descriptive we are the less questions we get from the field, which saves us time and money. We have used this approach for over 16 years and have not had any problems or holdups, so far. The Other Brian -----Original Message----- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge Knudsen Sent: Sunday, November 18, 2012 9:22 AM To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Hello Kris, About 10 years ago my company Niros Telecommunication was contacted by the Belgium Authority whom told that the DoC should be written in Dutch as well as in French and German. At that time we had a DoC written in English, German, French and Italian. We changed to a combination of a short form DoC and one complete DoC written in English. Short form in English: Hereby, [Name of manufacturer], declares that this [type of equipment] is in compliance with the essential requirements and other relevant provisions of Directive 1999/5/EC. The short form DoC can be found at the link below: http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e n.htm See "23. Form of the manufacturers' declaration to be put into the user's manual" We used this form for DoC for the ATEX directive as well. Best regards Helge Knudsen Former Test & Approval manager Niros Telecommunication Denmark -----Original Message----- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier Kristiaan Sent: 18. november 2012 14:13 To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Nick, My country, Belgium, has 3 official national languages, Dutch, French and German. The most recent draft of the Belgian transposition proposal of the RoHS Directive states now that the EU DoC should be drawn up in a language easily understandable by authorities. While the authorities have the right to request a translation in one of the official languages, it allows the use of English. Hopefull other countries follow that example as it worked well for > 20 years. Best regards, Kris Carpentier -----Original Message----- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: zondag 18 november 2012 11:14 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: EU-DoC - list of applied standards with full title It's actually a requirement of some of the directives, not just an addition brought in by transposition in certain countries. Generally, where the Directive requires the Declaration to accompany the product, it must be translated in to the language of the country of the end user. I guess the Commissiion's logic is that the instructions will need to be translated into the same language(s) so it's not a significant additional burden to require the DofC to be translated as well. Nick. On 18 Nov 2012, at 07:56, John Woodgate <j...@jmwa.demon.co.uk> wrote: > In message <867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com>, dated Sat, 17 Nov 2012, Carpentier Kristiaan <kristiaan.carpent...@technicolor.com> writes: > >> Some countries require in their national transposition that the EU >> DoC is issued in the local language. Although most are still in draft: France in French, Portugal in Portuguese, Germany in German, etc&.. >> >> In worst case, we have some 24 languages in EU, so lots of fun for translation. > > Now that IS a hardship for manufacturers. The way to deal with it is > for manufacturers' associations to petition the Commission for a clarification of the 'reference' requirement to mean just EN XXXXX:YYYY - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ 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 <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ 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 <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ 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 <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> ________________________________ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ 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 <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ 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 <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
