My doubt comes not from less/more specific directive.
I don't consider LVD just from its scope.
But reading RED (devices shall not be subject to LVD, except as...) I
understand that LVD not except some situations when yes.
And these 'some situations' looks as wider scope than LVD.
I know there is common understanding that if RED then no LVD but I don't
like to relay on such sources if I can't understand why it is so.
Do really for native English speakers it is clear that "devices shall
not be subject to LVD, except as..." doesn't mean "except as..... when yes"?
Regards
Piotr Galka
P.S.
If I write ma name with Polish letter (Piotr Gałka) do you see it correctly?
W dniu 2017-08-03 o 04:49, Nyffenegger, Dave pisze:
Similar situation exists with the Machinery Directive. The MD
guideline says not to declare the LVD on the DoC but the directive
requires meeting LVD technical requirements. There is no exclusion in
the LVD for machinery either. I don’t think anyone argues that the
directive that is more specific to the product prevails.
-Dave
*From:*Piotr Galka [mailto:[email protected]]
*Sent:* Wednesday, August 02, 2017 2:39 PM
*To:* [email protected]
*Subject:* Re: [PSES] RED DoC and LVD
Hi Mike,
Thanks for short and long answer :)
Reading RED Guide I understand: If RED than no EMCD and no LVD but it
is _only_ guide.
With EMCD everything is clear - in EMCD RED (R&TTE) devices are
clearly excluded from EMCD scope.
There is no such exclusion in LVD.
Reading RED I'm not sure how to read it to understand it (about LVD)
the same way as the RED Guide.
I really understand 1,4 and 3,1 (a) as RED devices are covered by LVD
(in some aspects but it looks for me as all aspects).
Regards
Piotr
W dniu 2017-08-02 o 16:19, Mike Sherman pisze:
Short answer: no.
Long answer: look at sections 9.5 and 11 of the "RED Guide," the
Guide to the Radio Equipment Directive 2014/53/EU dated 19 May 2017.
Mike Sherman
Graco Inc.
------------------------------------------------------------------------
*From: *"Piotr Galka" <[email protected]>
<mailto:[email protected]>
*To: *"EMC-PSTC" <[email protected]>
<mailto:[email protected]>
*Sent: *Wednesday, August 2, 2017 8:58:54 AM
*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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