I do not know anything about this topic, that's why I asked.

I was told by a friend that the Low Voltage Directive in the EN61010 
standard was the right place to look for answers, so I did and found some 
details but I do not understand it all. I found 
this http://www.ni.com/white-paper/2827/en/ which talks about instruments 
and isolation, which is interesting as it also mentions transformers and 
the categories used. So I emailed two transformer manufacturers and the 
Swedish National Electrical Safety Board and asked them about the use of 
transformer winding usage and also asked my insurance company.

One transformer manufacturer answered me that as long as the combined 
voltage of the secondary plus primary winding is within the isolation 
category, and voltage for the primary isolation barrier, it would of course 
work and be within the approval limits but they did not recommend it for a 
few reasons, the foremost reason being that a transformer is not tested for 
this connection and it would probably fail (not due to the voltages used 
but more so because there is no test for this condition) in an approval 
test under this condition and/or at least need an expensive new way of 
testing to be performed for an approval - being within the approval limits 
is not the same as being approved when used in a way that the approval 
testing has not tested nor taken into account they told me. One other 
reason for not using this way of connecting the windings is because the 
heating of the transformer windings in this condition is not taken into 
consideration when the transformer is designed and that could affect 
performance.

When it comes to the insurance question it would not be ok if it did not 
have an approval and was the starting cause for the fire, if it had an 
approval it would be just fine.

So, it will probably work ok but it might be hard to get an approval and 
therefore not good to use if it catches fire, at least in Sweden and with 
my insurance company. So I'll stick with transformer bought from reliable 
transformer manufacturers for now.

/Martin

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