Oh yeah, sorry.   Not so good then.   :-)

-----Original Message-----
From: Piotr Galka [mailto:[email protected]] 
Sent: 02 August 2017 19:12
To: [email protected]
Subject: Re: [PSES] RED DoC and LVD

Hi Michael,

Thanks, but that means my understanding was not correct :(

Regards,

Piotr


W dniu 2017-08-02 o 16:10, Michael Derby pisze:
> Hi Piotr,
>
> You would not have a situation where the RED and the LVD both apply to a 
> product.
>
> Product safety for radio devices (transmitter, receiver, transceiver) is 
> covered by Article 3.1a of the RED.   So, you assess safety "in a similar way 
> as the LVD", but you do not actually apply the LV Directive.
>
> So, no, you should not list the LVD on your RED DoC.
>
> Therefore, your understanding in your mail is correct.
>
>
> Thanks,
>
> Michael.
>
>
>
> -----Original Message-----
> From: Piotr Galka [mailto:[email protected]]
> Sent: 02 August 2017 14:59
> To: [email protected]
> Subject: [PSES] RED DoC and LVD
>
> 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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