Hi Scott:

The product (which was certified to the version of the
standard that was in effect at the time) was tested by
a third-party laboratory (to a new requirement in the
current edition of the standard) and found non-compliant.
Somebody (either the laboratory or the authority) used
the descriptive term "unsafe" because it did not comply
with a safety standard.

(To a naive person, non-compliance with a safety standard
makes an "unsafe" product.)

Since the third-party lab was engaged by the authority,
you have no recourse to the lab (except on a friendly
basis).  Re-test to the "old" version of the standard
can only be authorized by the authority (who has no
interest in your sales and trusts that the third-party
lab is testing correctly, including choice of standard).

You can ask the authority to re-test to the "old" standard,
but I guess that they would rather you "fix" the non-
compliance and then they will authorize a re-test.  The
authority is naive as to whether or not the product is
safe, and will go by the word of the third-party lab.

As much as it hurts, I suggest that your only remedy is
to make the product compliant to the latest version of
the standard.


Good luck,
Rich



On 7/31/2014 10:21 AM, Scott Xe wrote:
Recently we received a sales ban from an authority.  The authority took a 
sample from the market and appointed a 3rd party laboratory for verification of 
LVD conformity.  They found a non conformance on construction according to the 
latest version of safety standard and concluded the product is unsafe.  The 
requirement is new in the latest version and did not appear in the previous 
version.

When our product was verified by the 3rd party test house, it complied with 
previous version of safety standard but was the latest version of the safety 
standard at time of testing.  The new version was issued 2 months later and has 
an additional construction requirement.  The DoW of previous version of safety 
standard is in 2016.  We are at loss how come they consider our product unsafe 
with the latest version of the standard during this transitional period.  Any 
previous experience to deal with such authority can be shared?  It sounds 
ridiculous charge on our product.

Thanks and regards,

Scott



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