On 22/7/2017, 9:48 PM, "Chuck Seyboldt" <[email protected]> wrote:
Dear Scott:
What I meant by that was to describe a legal relationship
between a standard and a country, and that relationship in the
context you described of a competitive test house not wanting to
unnecessarily jack up prices.
I am picturing a hypothetical standard. That standard
has a general part, and several "National Differences" parts. I
took it that you wanted to know how to deal with this situation,
faced with a customer, and maybe the customer and maybe you and
maybe neither knowing which countries the product would be sold
in.
I say that either you educate the customer, because
whether he says it or not, he is naive about the legal
relationship between the standard and the countries and he
expects you to tell him how his unstated expectations might not
be met. In other words, you tell him he can affix the CE
marking, and he assumes this is the same as you telling him he
can now legally sell in all of he Community countries.
When his goods are impounded at the Swedish border, and
he is told they are illegal because they have a mercury-wetted
slip ring, he is going to ask you to pay for his unexpected
costs.
Back to my cryptic statement, this is the sort of thing
you should tell him before he contracts with you for testing:
Standard No. EN 12345-6-78 Applies
Testing to EN 12345-6-78, good for all countries EXCEPT
Sweden, Denmark, and Poland
Cost = $ 9,876.55
Additional Testing required for Sweden and Denmark
Cost = $1,111.11
Additional Testing required for Poland
Cost = $ 432.42
Now he knows the territorial limits of your test report
(driven by National Differences in the standard), and if he wants
to sell in Sweden, it's on him to ask you what is special about
Sweden.
Regards,
Chuck Seyboldt
(207) 893-0352
(207) 838-4026 Cellular
(800) 893-8142 Facsimile
At 09:24 (-0000) on 17.07.22, Scott Xe wrote:
> Dear Chuck,
>
> What is exact meaning of the general report that covers XYZ
> countries, and National Differences in Country A adds $$,
> Country B adds $$, etc.? Are they different countries for
> general part and national differences? To the buyers, they are
> only interested in the products that legally sell to their
> markets.
>
> Thanks and regards,
>
> Scott
>
>
> On 22/7/2017, 8:52 PM, "Chuck Seyboldt" <[email protected]> wrote:
>
>
> Dear Scott:
>
> On that issue, National Differences, if you have told your
> customer you are an expert on European Compliance, they will
> expect expert advice. If National Differences affects their
> ability to sell, they will expect you will have advised them
> of the limits associated with your report.
>
> It is obviously best to tell them in advance that the
> general report covers XYZ countries, and National Differences in
> Country A adds $$, Country B adds $$, etc.
>
> Basically, pass the buck to your customers and potential
> customers, by informing and educating them.
>
> If you, the expert, don't cover this ground, and their
> products are barred from some country, they will be unhappy. The
> ramifications of this are highly variable. Lawsuits over this
> type of subject are common.
>
> Regards,
> Chuck Seyboldt
>
> (207) 893-0352
> (207) 838-4026 Cellular
> (800) 893-8142 Facsimile
>
> At 07:49 (-0000) on 17.07.22, Scott Xe wrote:
>
> > Dear Steli,
> >
> > Thanks for your advice! Do National Differences mean National
> > conditions and National deviations normally in Annex of the
> > standard?
> >
> > How can a testing house ignore the National Differences? I
> > dare to guest the applicants may not decide where the goods to
> > be sold when applies for the testing. Thus the testing house
> > either does not test the national differences or test all
> > national differences. As a commercial testing house, testing
> > them all will increase the testing charges reducing their
> > competitive edge on the market. If the applicant indicates the
> > destined market, the testing house cannot avoid the testing to
> > national differences and deviations. The buyer must be careful
> > to accept the supplier’s evidence when they receive those
> > testing report and see if it fits for purpose.
> >
> > Regards,
> >
> > Scott
> >
> >
> >
> > On 22/7/2017, 6:01 PM, "Steli Loznen" <[email protected]> wrote:
> >
> > Dear Scott,
> > In addition to the Mr. Woodgate comment, please be informed that in the
frame of the CB Scheme need to pay attention to "National Differences" on IEC
standards. This is an important issue which not all time is addressed by the testing houses
which issue the CB Test Reports.
> > Best Regards,
> > Steli
> >
> >
> >
> > Steli Loznen, M.Sc., SM-IEEE
> > Member of BoG IEEE-PSES
> > Convener IEC 62A/MT 62354
> > 17-3 Shaul HaMelech Blvd.
> > Tel Aviv 6436719
> > Israel
> > Tel:+972-3-6912668
> > Fax:+972-3-6913988
> > Mobile:+972-54-7245794
> > e-mail: [email protected]
> >
> > -----Original Message-----
> > From: Scott Xe [mailto:[email protected]]
> > Sent: Saturday, July 22, 2017 11:54 AM
> > To: [email protected]
> > Subject: Re: [PSES] AW: Harmonised standard withdrawn
> >
> > Dear John,
> >
> > It is a good point to note!
> >
> > Thanks and regards,
> >
> > Scott
> >
> >
> > On 22/7/2017, 4:37 PM, "John Woodgate" <[email protected]>
wrote:
> >
> > The EN and the IEC are *never* identical, especially now that
the ENs have to include a succession of 'Z' annexes. Large parts of the technical
content may well be identical, but the ENs include a lot of European 'baggage', which
can't safely be ignored.
> >
> > With best wishes DESIGN IT IN! OOO – Own Opinions Only
> > www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh
England
> >
> > Sylvae in aeternum manent.
> >
> > -----Original Message-----
> > From: Scott Xe [mailto:[email protected]]
> > Sent: 22 July 2017 09:13
> > To: John Woodgate <[email protected]>
> > Subject: Re: [PSES] AW: Harmonised standard withdrawn
> >
> > Hi John,
> >
> > I notice the CB reports that they will conduct the test
according to IEC standard and the standards for destined market, i.e. EN for EU. As
usual, EN standards are derived from IEC standard. If the IEC standard is listed
below the EN standard without indication of modified, the IEC compliance report can
be used as self-declaration of conformity to the directive due to the fact that both
EN and IEC standards are identical.
> >
> > Regards,
> >
> > Scott
> >
> >
> > On 22/7/2017, 2:24 PM, "John Woodgate"
<[email protected]> wrote:
> >
> > That isn't a 'listing' of the IEC standards, it's an
indication of what the EN was derived from. You can see that, because some of the IEC
standards are described as '(modified)'.
> >
> > With best wishes DESIGN IT IN! OOO – Own Opinions Only
> > www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh
England
> >
> > Sylvae in aeternum manent.
> >
> > -----Original Message-----
> > From: Scott Xe [mailto:[email protected]]
> > Sent: 22 July 2017 03:53
> > To: John Woodgate <[email protected]>;
[email protected]
> > Subject: Re: [PSES] AW: Harmonised standard withdrawn
> >
> > Dear John,
> >
> > The attached HS list does have IEC standards. Do they
have other meaning that I might incorrectly interpret it?
> >
> > Thanks and regards,
> >
> > Scott
> >
> >
> > On 22/7/2017, 1:08 AM, "John Woodgate"
<[email protected]> wrote:
> >
> > IEC standards are rarely, if ever, notified in the OJ,
because they are not harmonized so all EU/CENELEC countries do not have to accept
them.
> >
> > With best wishes DESIGN IT IN! OOO – Own Opinions Only
> > www.jmwa.demon.co.uk J M Woodgate and Associates
Rayleigh England
> >
> > Sylvae in aeternum manent.
> >
> > -----Original Message-----
> > From: Scott Xe [mailto:[email protected]]
> > Sent: 21 July 2017 17:50
> > To: [email protected]
> > Subject: Re: [PSES] AW: Harmonised standard withdrawn
> >
> > Hi Durrer,
> >
> > Both IEC and EN 60335-2-24 were in the harmonised
standard list of OJEU before they were removed. Regarding the national standard BS
EN 60335-2-24 should be technically identical with EN 60335-2-24. Although it is
still valid in BSI website, the HS removal is due to UK objection. It does not make
sense using BS EN 60335-2-24 to declare the compliance with LVD.
> >
> > It is good suggestion to take care this known issue in
risk assessment required in LVD. As this issue is being discussed in IEC to EN
standard conversion. For the time being, the latest IEC A2 amendment seems a
reasonable reference to address the fire risk.
> >
> > Regards,
> >
> > Scott
> >
> >
> > On 21/7/2017, 4:16 PM, "Dürrer Bernd"
<[email protected]> wrote:
> >
> > Dear Scott,
> >
> > The removal of the reference to EN 60335-2-24 from
the OJEU means that compliance with this standard does not provide the presumption of
conformity as defined in Article 12 of LVD. Actually, the nationally adopted versions
of this standard are still valid (e.g. BS EN 60335-2-24,
https://shop.bsigroup.com/ProductDetail/?pid=000000000030236214). As IEC 60335-2-24
is not listed as an international standard in the OJEU, I do not see any advantage in
declaring CE compliance with the IEC version, especially as the objection raised by
the UK against the use of highly flammable materials would also apply to fridges
compliant with IEC 60335-2-24.
> >
> > As risk analysis (preferably according to CENELEC
Guide 32) is a mandatory part of the technical documentation (LVD, Annex III, Module
A, 2.), the manufacturer is bound to consider the findings in UK's objection and to
avoid the use of such materials even if they are compliant with the IEC/EN standard.
Please be aware that the obligations of the manufacturer (LVD, Art. 6) also include
the monitoring of products already in the market and to take corrective measures if
it is found that a product presents a risk.
> >
> > Regarding a new product, you may still refer to EN
60335-2-24, but it will not give you presumption of conformity. With the CE DoC you declare
that your electrical equipment provides "a high level of protection of health and safety
of persons, and of domestic animals and property" (LVD, Art. 1), using the standard as a
technical means to demonstrate compliance, but considering also risks that are not adequately
addressed in the standard.
> >
> > Kind regards,
> >
> > Bernd
> >
> > Von: Wiseman, Josh UTC CCS
[mailto:[email protected]]
> > Gesendet: Donnerstag, 20. Juli 2017 21:31
> > An: [email protected]
> > Betreff: Re: [PSES] Harmonised standard withdrawn
> >
> > Scott,
> >
> > You can continue to use EN 60335-1 and reference
IEC 60335-2-24 to show compliance. Just because the EN is withdrawn doesn’t mean the
IEC is no longer valid. Knowing now about the plastic issue, maybe you do some other
evaluation method for it to ensure it’s safe to be used in that application.
> >
> > Josh Wiseman
> > Senior Compliance Engineer
> >
> > Taylor Company
> > Joshua Wiseman
> > Senior Compliance Engineer
> > 750 N. Blackhawk Blvd. | Rockton, IL 61072
> > Office: 815.624.5628 | Cell: 815.262.5517 | Fax:
815.624.5181
> > http://www.taylor-company.com/ |
https://twitter.com/TheTaylorCo | http://www.youtube.com/TheTaylorCompany
> > -----------------------------------------------
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> > -----------------------------------------------
> >
> > From: Scott Xe [mailto:[email protected]]
> > Sent: Thursday, July 20, 2017 9:38 AM
> > To: mailto:[email protected]
> > Subject: [External] [PSES] Harmonised standard
withdrawn
> >
> > The harmonised standard EN 60335-2-24 is removed
from the harmonised standard list on OJEU. The common compliance route of
self-declaration of conformity to LVD using harmonised standard becomes lost. What
are other options to demonstrating the compliance with LVD?
> >
> > Thanks and regards,
> >
> > Scott
> > -
> >
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