Dear list members,
I'd like to know if the RED DoC should list LVD or not.
RED says:
1,4.Radio equipment falling within the scope of this Directive shall not
be subject to Directive 2014/35/EU, except as set out in point (a) of
Article 3(1) of this Directive.
3,1. Radio equipment shall be constructed so as to ensure: (a) the
protection of health and safety of persons and of domestic animals and
the protection of property, including the objectives with respect to
safety requirements set out in Directive 2014/35/EU, but with no voltage
limit applying;
Annex V (DoC) 5: relevant Union harmonisation legislation: -RED, - Other
Union harmonisation legislation where applicable.
I really can't say that being/not being subject to LVD is clear for me here!
My understanding:
3,1(a) - protection of persons, animals and property covers really the
whole LVD requirements (extending its range on low voltage devices).
1,4 - Radio equipment is not subject to LVD but in aspects from 3,1(a)
it is subject to LVD.
So, as 3,1(a) covers the whole LVD requirements the RED device is
subject to LVD so LVD is applicable and should be listed in RED
equipment DoC.
May be my understanding stand up from that then till now, I have been
reading the RED in Polish version. I have opened English version for
first time when I come to copy citations from RED to this post.
Translating Polish to English it would be something like that:
1.4 Radio devices ... are not subject to LVD, except cases defined in
3,1(a).
The essence of my question is:
Do the 'except' in 1.4 should be understand that what is after 'except':
- describes aspects of LVD in which the RED devices are subject to LVD,
- describes requirements from LVD to be applied to RED devices without
understanding that they are subject to LVD.
Or may be my mistake is that I don't see what parts of LVD are not
covered by 3,1(a).
This leads to reading LVD Annex I and selecting points which should be
not applied to RED devices as being not covered by 3,1(a) (can be the
next question if here the decision would be to go that way).
If I can be sure that at least one of points from LVD Annex I is not
covered by 3,1(a) than I can understand that RED devices are not subject
to LVD and only some points from LVD Annex I should be applied as
requirements of applying RED and not requirements of applying LVD.
I hope you help in my doubts.
Best Regards
Piotr Galka
MicroMade
Poland
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