Yes an interesting point is that ‘consumer’ use invokes the GPSD and could start to fall in to scope of "BS EN 60335-1:2012+A13:2017 Household and similar electrical appliances. Safety. General requirements" which has no ‘safe low voltage limit in it’ even though this is a LVD harmonised standard. Although the LVD does not apply to the 'audio product' in regards CE marking because of the USB nominal 5V input the general product safety directive (GPSD) does, as you point out.
So what to use in regards due diligence against that GPSD directive? Lurking in the scope of 60335-1 is, " This European Standard deals with the safety of electrical appliances for household environment and commercial purposes, their rated voltage being not more than 250 V for single-phase and 480 V for others. NOTE 1 Battery-operated appliances and other d.c. supplied appliances are within the scope of this standard.". Ah ha, this scope contradicts the LVD supply voltage. So could be applicable to GPSD? For the audio product EN 60335’s scope goes on to exclude ‘audio, video and similar electronic apparatus’ in its wording, pointing to IEC 60065. So EN 60065 or maybe the newer EN 62368-1 and its hazard based class 1 energy source etc are more relevant for the audio product in the original post below. EN 60065 is in the harmonised list for GPSD so why would this not be applied? It’s scope says, “This International Safety Standard applies to electronic apparatus designed to be fed from the MAINS, from a SUPPLY APPARATUS, from batteries or from REMOTE POWER FEEDING and intended for reception, generation, recording or reproduction respectively of audio, video and associated signals. It also applies to apparatus designed to be used exclusively in combination with the above-mentioned apparatus. This standard primarily concerns apparatus intended for household and similar general use but which may also be used in places of public assembly such as schools, theatres, places of worship and the workplace. PROFESSIONAL APPARATUS intended for use as described above is also covered unless falling specifically within the scope of other standards.” So, the scope of the standards extends beyond that of the LVD ‘limits’ to include a nominal 5V D.C. USB powered item. Therefore be careful anyone thinking these ‘LVD’ standards can be ignored and aren’t applicable to USB powered ‘consumer’ items where the GPSD applies – they do. Anyway just a quirk we found when dealing with a ‘consumer’ household item recently. Consumer end users – try and avoid them I would! :-) Matthew Wilson, Technical Director, GB Electronics (UK) Ltd. From: McBurney, Ian <ian.mcbur...@allen-heath.com> Sent: 13 November 2018 09:27 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] NRTL approval Dear colleagues. We are in the process of designing a USB bus powered audio product around 2.5W for professional/consumer use. The product enclosure will be UL94 5VA flammability rated plastic. Will this product have to be NRTL approved for sale in the USA/Canada? The EU LVD doesn’t apply because of the supply voltage is only 5V DC. The GPSD probably will! Many thanks in advance. Ian McBurney Lead Compliance Engineer. Allen & Heath Ltd. Kernick Industrial Estate, Penryn, Cornwall. TR10 9LU. 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