List Member:

I am seeking to gain insight into requirements under the European LVD directive 
to component part used within multimedia products during the transition from 
60950-1 to 62368-1.

Given our understanding that Multimedia products falling under the scope of EN 
62368-1:2014 and intended to be placed on the European market after Dec 20, 
2020 can make use
of a component power supply certified to requirements of EN 60950-1 as 
permitted under Clause 4.1.1 of EN62368-1 which indicates:

"Components and subassemblies that comply with IEC 60950-1 or IEC 60065 are 
acceptable as part of equipment covered by this standard without further 
evaluation other than to give consideration to
the appropriate use of the component or subassembly in the end-product."

the status and declaration requirements of a replacement component part such as 
a component power supply after the 62368-1 DOW date is not in our view well 
defined.

I have reviewed EU guidance document The 'Blue Guide' on the implementation of 
EU product rules 2016" in an effort to gain insight into how harmonized 
standards are apply
with respect to service or replacement parts under the LVD.  Reading section 
"WHEN DOES UNION HARMONISATION LEGISLATION ON PRODUCTS APPLY?" would seem to 
imply
that harmonized standards do not apply to replacement parts since servicing and 
repair activity are not within scope.

The Machinery directive is more definitive indicated that spare and replacement 
parts are excluded from the scope of this Directive under Article 1,  clause 
2(a):

"2. The following are excluded from the scope of this Directive:

  1.  safety components intended to be used as spare parts to replace identical 
components and supplied by the manufacturer of the original machinery;"
Considering the foreseeable case where a replacement component power supply 
original CE marked and conforming to EN60950-1 needs to be imported to service 
62368-1
conforming equipment after the 2020 DOW date, what supporting materials would 
be expected?

>From the guidance documents it does appear that replacement parts fall outside 
>the scope of the directive. I am interested in any members insight or 
>experience managing
replacement parts under the CE rules and whether authorities recognize and 
accepted a statement of exemption for replacement parts.




[cid:[email protected]]
Donald McElheran
Product Compliance Specialist
Ross Video | Production Technology Experts
[email protected]<mailto:[email protected]>
www.rossvideo.com<http://www.rossvideo.com/>
T +1 (613) 652-3011
M +1 (613) 867-3943


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