UL6500

1998-08-19 Thread berkley
 Hello All,

 I'm in the process of specifying an external Ac to Dc power Adaptor which 
 will be
 used for one of our products.  The transformer is to be mounted inside an abs
 plastic housing with an Ac supply cord and a Dc output cord. Both cords are
 permanently fixed.  Input voltage will be 120Vac and output will be 12Dc, 
 8Amps.
 Our product (Audio of sorts)can be used with a PC to provide audio or be used 
 as
 home theater audio equipment.  UL has identified UL 6500 as the approriate 
 std to
 evaluate our end product to.  UL has also indicated that off the shelf 
 transformers,
 usually evaluated to UL 1411 (for Xfmrs used in certian types of audio 
 products)
 won't meet the criteria for UL6500.  I've had no luck thus far in locating a 
 power
 adaptor manufacturer that evaluates to UL6500. Plenty have off the shelf 
 product
 evaluated UL1411. What I'm trying to do here is start off my product's UL 6500
 investigation with a Recognized Component power adaptor. This should make my
 product evaluation that much easier.  If any of you knows of a mfgr that has 
 been
 thruogh the UL6500 process, or if you have any suggestions as to what Power 
 Adaptor
 manufacturers have a good reputation in  working with you on this type of 
 issue,
 please contact me via email.  Additional comments regarding this issue also 
 welcome.

 we're all in school, our whole lives through


 Good Health  Good Fortune to YOU,
 George Sparacino - Sr. Compliance Engineer
 Boston Acoustics

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Re: Help with USA EMC-Safety certification

1998-08-19 Thread Paul Chang
Dear Tony,

All Devices connecting to the Public Switch Telephone Network (PSTN) needs
to be tested to FCC Part 68 before it can be sold in the US.  This would be
similar to the testing that I expect you would have tested to, for the
crossed hockey stick mark for Europe.

The US requirements that you met under Part 15 and UL1950 should be enough
for EMC and Safety.

If you don't already have a lab that can do this testing, or if you simply
have more questions, call me at TUV Telecom:

Best Regards,
Paul K. Chang
TUV Telecom
165 Forest Street
Suite 201
Marlboro, MA 01752

(508) 460-0792 x235
(508) 460-9073 fax
-Original Message-
From: TO tonyo_e...@onaustralia.com.au
To: 'emc-p...@ieee.org' emc-p...@ieee.org
List-Post: emc-pstc@listserv.ieee.org
Date: Wednesday, August 19, 1998 6:59 AM
Subject: Help with USA EMC-Safety certification


We have Telecommunication terminal equipment (switch), which has been
tested for European market for EMC and safety in an Australian Test House.
It meets EMC emission limits CISPR22 class A, IEC-1000 series Immunity
limits and IEC950 safety requirements. This is sufficient for CE marking.
Equipment complies with FCC part 15 emission requirements and UL1950.

Could someone put me on the right track regarding EMC and safety
certification in the USA. Can we legally issue certificate of compliance and
export this equipment to USA or is it mandatory to test it again in the USA
test House?

Do we have to register this equipment with Authorities such as FCC?

How do we go formally about it

Regards


Tony Olejnicki
tonyo_e...@onaustralia.com.au



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ultrasonic cleaners

1998-08-19 Thread Richard Cass
 Greetings,
 What CE directives and hence what test standards apply to a small 
 ultrasonic cleaner (sometimes referred to as a jewelry cleaner) when it is 
 included as an accessory to an ITE product?  The ultrasonic cleaner is an 
 off the shelf product from another manufacturer.  As received from the 
 manufacturer it does not appear to be CE marked.  The ITE product that it 
 will accompany is used exclusively in commercial and light industrial 
 environments (i.e. not for home use).  It is a not attached to or in any 
 way physically part of the ITE product.  The ultrasonic cleaner is sold in 
 both 120V/60Hz and 240V/50Hz versions (different part numbers).  I am 
going 
 to have a discussion about certification with our supplier of these and I 
 just want to be armed with some accurate information.
 
 Thanks in advance for the help.
 
 Regards,
 Richard Cass
 Iris Graphics, Inc.
 USA


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RE: ultrasonic cleaners

1998-08-19 Thread WOODS, RICHARD
In my opinion, the cleaner is not an accessory to the ITE since it has no
connections to it whatsoever. Therefore, the cleaner must stand as a product
in its own right. I would consider it to be business equipment, so it must
comply with EN 60950 for safety and EN 50081-1 for emissions and EN 50082-1
for immunity. I strongly recommend that you make the OEM responsible for
performing the compliance tests.  I also recommend that you require the OEM
to provide an agency safety mark such as TUV. That way, the agency will
perform survalence on the product to ensure continued safety compliance. If
you are the importer you will be responsible for the Declaration of
Conformity.


Richard Woods
Sensormatic Electronics
wo...@sensormatic.com
Views expressed by the author do not necessarily represent those of
Sensormatic.


 --
 From: Richard Cass[SMTP:richard_c...@iris.scitex.com]
 Reply To: Richard Cass
 Sent: Wednesday, August 19, 1998 10:33 AM
 To:   emc-p...@majordomo.ieee.org
 Subject:  ultrasonic cleaners
 
  Greetings,
  What CE directives and hence what test standards apply to a small 
  ultrasonic cleaner (sometimes referred to as a jewelry cleaner) when
 it is 
  included as an accessory to an ITE product?  The ultrasonic cleaner
 is an 
  off the shelf product from another manufacturer.  As received from
 the 
  manufacturer it does not appear to be CE marked.  The ITE product
 that it 
  will accompany is used exclusively in commercial and light industrial
 
  environments (i.e. not for home use).  It is a not attached to or in
 any 
  way physically part of the ITE product.  The ultrasonic cleaner is
 sold in 
  both 120V/60Hz and 240V/50Hz versions (different part numbers).  I am
 going 
  to have a discussion about certification with our supplier of these
 and I 
  just want to be armed with some accurate information.
  
  Thanks in advance for the help.
  
  Regards,
  Richard Cass
  Iris Graphics, Inc.
  USA
 
 
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 ri...@sdd.hp.com, or roger.volgst...@compaq.co (the list
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RE: Help with USA EMC-Safety certification

1998-08-19 Thread Bandele
Hello TO,

From your inquiry, it seems as if you have covered almost everything to sell 
your product in the USA - except the network protection requirements. All 
devices connecting to the Public Switch Telephone Network (PSTN) will need to 
meet this requirement. The requirement can be met by complying with FCC Part 
68 in which REGISTRATION of your product with the FCC will be necessary. 
The requirements that you meet under FCC Part 15 and UL1950 should be enough 
for US EMC and Safety.

If you should need additional information, please feel free to contact me at 
011-49-6039-9182-0 (Germany)  or 001-301-855-1375 (USA).

Best Regards,


Bandele Adepoju
Rockford Engineering Services, Inc
Tel:001-301-855-1375 (USA)
011-49-6039-9182-0 (Europe - Germany)
Fax 001-410-586-1460 (USA)
011-49-6039-9182-29 (Europe - Germany)
Email:  band...@resemc.com
Web:www.resemc.com 
--
From:  TO [SMTP:tonyo_e...@onaustralia.com.au]
Sent:  Wednesday, August 19, 1998 5:49 AM
To:  'emc-p...@ieee.org'
Subject:  Help with USA EMC-Safety certification

We have Telecommunication terminal equipment (switch), which has been tested 
for European market for EMC and safety in an Australian Test House. 
It meets EMC emission limits CISPR22 class A, IEC-1000 series Immunity limits 
and IEC950 safety requirements. This is sufficient for CE marking.
Equipment complies with FCC part 15 emission requirements and UL1950.

Could someone put me on the right track regarding EMC and safety certification 
in the USA. Can we legally issue certificate of compliance and export this 
equipment to USA or is it mandatory to test it again in the USA test House?

Do we have to register this equipment with Authorities such as FCC?

How do we go formally about it

Regards


Tony Olejnicki
tonyo_e...@onaustralia.com.au



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Re: Help with USA EMC-Safety certification

1998-08-19 Thread ron_pickard
 Tony,
 
 First, I'm confused. If you know that your product complies with FCC Part 15 
 and UL19050, why are you asking EMC and safety certification guidance in the 
 US? Or, are you just making the statement?
 
 Anyway, compliance with IEC950 does not equate to compliance with UL1950. 
There 
 are a few national deviations to be considered. Making the crossover might be 
a 
 little easier with a CB certificate  report. If this product is indeed truly 
 compliant with UL1950 as indicated, then Listing of your product with an OSHA 
 approved NRTL (Nationally Recognized Test Lab) is required. There is a bit of 
 contractual process involved and testing will likely be required. Any NRTL 
 should be able to get you started. See the following web address for the list 
 of NRTLs for the category your product falls into:
 
 http://www.osha-slc.gov/SLTC/nrtl/index.html
 
 As for FCC Part 15, the FCC accepts data taken to the limits of CISPR22, 
 however, the test must have been performed in accordance with ANSI C63.4 and 
 performed at 120V, not 220V. There are also some requirements for the test lab 
 as well.
 
 For safety, a CofC will not be sufficient. For FCC Part 15, a CofC may be 
 sufficient depending on your target market's environment.
 
 In addition, registering your equipment with the FCC (Part 68) will also be 
 required to connect to the telephone network. This is accomplished by formal 
 testing and an application to the FCC. Formal product marking and manual 
 statements are required.
 
 If you are unsure of how to proceed, enlist the services of a consultant or 
 someone knowledgeable in this area to assist you. You may find that this 
 investment will likely be well worth it.
 
 That's it in a nutshell. And, be advised that the above represents my 
 experiences intermixed with my opinions.
 
 Good luck and best regards,
 Ron Pickard
 ron_pick...@hypercom.com


__ Reply Separator _
Subject: Help with USA EMC-Safety certification 
Author:  TO tonyo_e...@onaustralia.com.au at INTERNET
List-Post: emc-pstc@listserv.ieee.org
Date:8/19/98 7:49 PM


We have Telecommunication terminal equipment (switch), which has been tested for
uropean market for EMC and safety in an Australian Test House. 
It meets EMC emission limits CISPR22 class A, IEC-1000 series Immunity limits an
IEC950 safety requirements. This is sufficient for CE marking.
Equipment complies with FCC part 15 emission requirements and UL1950.
 
Could someone put me on the right track regarding EMC and safety certification i
the USA. Can we legally issue certificate of compliance and export this equipmen
to USA or is it mandatory to test it again in the USA test House?
 
Do we have to register this equipment with Authorities such as FCC?
 
How do we go formally about it
 
Regards
 
 
Tony Olejnicki
tonyo_e...@onaustralia.com.au
 
 
 
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The EMC Directive and Insurance Companies

1998-08-19 Thread Kevin Harris
Hello All,

I work in an industry in which ( in Europe ) we are subject to insurance
regulations as well as the EMC directive. In many countries having your
equipment meet these standards entitles the users of the equipment to a
premium discount with the insurer. In some countries submitting your
equipment for test is optional in others it is required by law. Most, if
not all, of the insurance regulations include EMC tests in their suite
of tests (including some mighty peculiar ones). I've thought up until
now that I would just put up with it until the DOW for our family
product comes around and then I thought all these extra tests would go
away. I have recently hear for a source in Europe that the insurance
industry is exempt from the EMC directive and that they could continue
to impose their tests. Can anyone confirm or deny this exemption.



Regards,



Kevin Harris
Compliance Engineering Manager
Digital Security Controls
1645 Flint Road
Downsview, Ontario
CANADA
M3J 2J6

Tel   +1 416 665 8460 Ext. 378
Fax +1 416 665 7753 


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RE: ultrasonic cleaners

1998-08-19 Thread Mark Briggs
What frequency is the ultrasonic section working at ?  This may well 
classify as ISM equipment if it is intentionally using rf (above 9kHz) to 
perform its intended function (clean jewelry) and so EN 55011 would 
apply.  Choice of Class A or B, as appropriate.  Class A if not used in a 
residential environment, Class B if it is.  I would recommend Class B 
since it could be used in a shop located beneath an apartment.

For immunity I agree with Richard - EN50082-1 and would recommend the 
1997 version of this standard.

Mark
mbri...@elliottlabs.com

In my opinion, the cleaner is not an accessory to the ITE since it has no
connections to it whatsoever. Therefore, the cleaner must stand as a product
in its own right. I would consider it to be business equipment, so it must
comply with EN 60950 for safety and EN 50081-1 for emissions and EN 50082-1
for immunity. I strongly recommend that you make the OEM responsible for
performing the compliance tests.  I also recommend that you require the OEM
to provide an agency safety mark such as TUV. That way, the agency will
perform survalence on the product to ensure continued safety compliance. If
you are the importer you will be responsible for the Declaration of
Conformity.


Richard Woods
Sensormatic Electronics
wo...@sensormatic.com
Views expressed by the author do not necessarily represent those of
Sensormatic.


 --
 From:Richard Cass[SMTP:richard_c...@iris.scitex.com]
 Reply To:Richard Cass
 Sent:Wednesday, August 19, 1998 10:33 AM
 To:  emc-p...@majordomo.ieee.org
 Subject: ultrasonic cleaners
 
  Greetings,
  What CE directives and hence what test standards apply to a small 
  ultrasonic cleaner (sometimes referred to as a jewelry cleaner) when
 it is 
  included as an accessory to an ITE product?  The ultrasonic cleaner
 is an 
  off the shelf product from another manufacturer.  As received from
 the 
  manufacturer it does not appear to be CE marked.  The ITE product
 that it 
  will accompany is used exclusively in commercial and light industrial
 
  environments (i.e. not for home use).  It is a not attached to or in
 any 
  way physically part of the ITE product.  The ultrasonic cleaner is
 sold in 
  both 120V/60Hz and 240V/50Hz versions (different part numbers).  I am
 going 
  to have a discussion about certification with our supplier of these
 and I 
  just want to be armed with some accurate information.
  
  Thanks in advance for the help.
  
  Regards,
  Richard Cass
  Iris Graphics, Inc.
  USA
 


++
+Mark Briggs MSc CEng, MIEE  +
+  Manager, EMC Consulting Services  +
+ Elliott Labs, 684 W Maude Avenue   +
+Sunnyvale,  CA 94086+
++
+   Phone: +1 (408) 245 7800 x238+
+ Fax: +1 (408) 245 3499 +
++ 
+   Email: mbri...@elliottlabs.com   +  
+ http://www.elliottlabs.com +
++


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RE: FDA requirements

1998-08-19 Thread Bandele
Dear Rebeca Chan,

Based on the information that you provided, a device such as your electrode 
device could be classified as a Class I device. A submittal to FDA under a 510k 
plan may or may not be necessary. It is hard to say with the limited 
information provided. The key question here is how does it attach to the skin 
to record electrical signals.  A product type search may be necessary to 
determine if  it is similar to a device that is on the market in the United 
States. The thing to note for design here, is to ensure that your device is 
substantially equivalent in functionality to the device on the market (or 
precursory device).  A function to function comparison must be made to 
determine equivalency.  Your device will be subject to the same requirements as 
the precursory device.  So you will also need to take special note as to what  
the special requirements of the precursory device are.  You may find these to 
be more limited to what you will like to be applied to your device.  

The drawback to this is if a thorough comparison of your device to the 
precursory is not made and you fail to recognize some critical deviations in 
your device functionality, the FDA may by default conclude that your device is 
not substantially equivalent to the precursory device. Your device could  be 
upgraded to where it requires PMA (PreMaket Approval) . If possible, you want 
to avoid the PMA (Class III) or 510k (Class II) route.  It is important to 
understand how the FDA reaches its decisions regarding substantial equivalence.

Manufacturers of devices classified as Class II or Class III (and some Class 
I), are required to register their facilities and conform to the GMP (Good 
manufacturing Practices) regulations.  ISO 9000 will go a long way as a good 
start towards satisfying this requirement.  Please note that some devices 
classified as Class I are exempted from this requirement.  Your device may fall 
in the exempted group.  

I hope this helps in answering your questions.

Best Regards,


Bandele Adepoju
Rockford Engineering Services, Inc.
Tel:001-301-855-1375
Fax:001-410-586-1460
Email:  band...@resemc.com
Web;www.resemc.com

--
From:  becky...@aol.com [SMTP:becky...@aol.com]
Sent:  Thursday, August 13, 1998 4:32 PM
To:  emc-p...@majordomo.ieee.org
Subject:  FDA requirements


I am working on a machine that has electrodes that are attached to the skin to
measure various electrical signals.  This machine is battery powered.  My
question is :  am I required to conform to any FDA design rules in this area ?
When the machine goes into production, do I have to find a manufacturer that
is specifically qualified to produce medical device ?  Is a ISO9000
certification sufficient qualification for a manufacturer to produce this item
?

Rebeca Chan


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RE: Use of Cadmium in ITE product

1998-08-19 Thread Greg Hansen
Here is a little more information that I have on this subject.  I am not
aware of any other national deviations specifically covering Cadmium
batteries:

EN 60950 - European differences
Sweden (Ordinance SFS 1989:974)
Equipment provided with built-in batteries, not replaceable by the user,
shall be marked with the following
{recycle} symbol if the batteries have a content of mercury or cadmium
exceeding 0,025 % by weight.

EN 60950 - European differences
Switzerland (Ordinance on environmentally hazardous substances SR 814.013)
Annex 4.10 of SR 814.013 applies for batteries.

Greg Hansen
OEC Medical Systems, Inc.
ghan...@oecmed.com mailto:ghan...@oecmed.com 



-Original Message-
From:   Peter E. Perkins [SMTP:peperk...@compuserve.com]
mailto:[SMTP:peperk...@compuserve.com] 
Sent:   Friday, August 14, 1998 12:08 AM
To: INTERNET:bharat_s...@logitech.com
Cc: PSNetwork
Subject:Use of Cadmium in ITE product


PSNet

As I remember, the Scandinavians (Sweden, I believe)
first banned
the use of Cadmium in products because the Cadmuim would
leach out in
landfills and contaminate the groundwater...  this was a
large concern to
equipment manufacturers who used Cad plated hardware...
There was pressure
to make this a European requirement, but I'm not sure where
that has lead
(no Pb pun intended)... 

Perhaps someone has later information to flesh this
out...

- - - - -

Peter E Perkins
Principal Product Safety Consultant
Tigard, ORe  97281-3427

+1/503/452-1201 phone/fax

p.perk...@ieee.org mailto:p.perk...@ieee.org
email



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CE marking vs. Annex ZB in EN60950

1998-08-19 Thread JPR3
I am trying to sort out an an apparent contradiction between the main body of
the harmonized EN 60950 and the national deviations that appear in Annex ZB.
I would appreciate some assistance from the safety professionals and
regulatory experts in the emc-pstc and treg forums.

My particular problem has to do with the specified insulation between between
TNV-3 circuits and SELV circuits, although the question about Annex ZB applies
to other national deviations as well.  I will use the TNV/SELV issue as an
example.

Clause 6.2.1.2 of EN 60950 specifies basic insulation between TNV-3 and SELV
circuits.  However, in Annex ZB, it states that Norway and Sweden require
supplementary insulation.  Annex ZB states that for the countries in which
the special national conditions apply, these provisions are normative.  For
other countries they are informative.

I am trying to understand how this distinction is applied for CE marking.  I
thought that the intent of CE marking was that products could be evaluated
against harmonized standards and then have the CE marking applied.  I
thought that products with the CE marking were allowed to move freely among
the member countries in the EU.  Annex ZB seems to complicate this simple
interpretation. 

My tentative conclusions about the above situation are:

1) A manufacturer who intends to market his product in a list of EU countries
that excludes Norway and Sweden can apply the CE marking to a product that has
only basic insulation between TNV-3 and SELV circuits.

2) A manufacturer who intends to market his product in a list of  EU countries
that includes Norway or Sweden can only apply the CE mark if the product
provides supplementary insulation between TNV-3 and SELV circuits.

The above two cases result in products that each bear identical CE marking,
but one of them (case 1) is technically illegal for use in Norway and Sweden.
From looking at the product marking, there is no way to determine that the
product in case 1 should not be used in Norway or Sweden.

I suppose that this distinction could be made in the user manual.  I also
presume that the manufacturer in case 1 would be obligated to ensure that the
product is not offered for sale in Norway or Sweden.  Maybe this is enough to
comply with the letter of the law, but I suspect that it would be easy for the
product in case 1 to find its way into Norway and Sweden.

Prior to the adoption of CTR 21 for analog modems, the above issue was largely
academic, since individual national approvals and the corresponding national
labels were still required for connection to the PSTN.

However, now that CTR 21 has been adopted, I expect there will be a rush
toward full CE marking (including the crossed hockey sticks) of analog
modems.  National approval labels will no longer be required.  I think this
will bring additional attention to the situation I have described above.

Can anyone offer some some insight into how this situation should be handled?
Is my interpretation correct?  Any comments would be welcome.


Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
325 Highland Avenue
Winchester, MA, USA  01890
781-721-2848 (voice)
781-721-0582 (fax)



RE: CE marking vs. Annex ZB in EN60950

1998-08-19 Thread richard . payne
Hi Joe:

An excellent question !

Let me ask one or two of my own here.

1. Are we sure that both Sweden and Norway are currently EU members ?  Not
just IEC members ?

Regardless of that answer the question really remains valid for the other
items in annex ZB

2. Would it be reasonable that these National Requirements are only
applicable when getting a National Approval, and that they are not
applicable to CE marking and compliance with the EN standard ?


I hope to see a lot of opinions, this should be interesting.



Richard Payne
MBD Product Safety Engineering
Tektronix, Inc.
v (503) 627-1820
f (503) 627-3838
e richard.pa...@tek.com



 -Original Message-
 From: j...@aol.com [SMTP:j...@aol.com]
 Sent: Wednesday, August 19, 1998 9:17 AM
 To:   emc-p...@ieee.org
 Cc:   t...@world.std.com
 Subject:  CE marking vs. Annex ZB in EN60950
 
 I am trying to sort out an an apparent contradiction between the main body
 of
 the harmonized EN 60950 and the national deviations that appear in Annex
 ZB.
 I would appreciate some assistance from the safety professionals and
 regulatory experts in the emc-pstc and treg forums.
 
 My particular problem has to do with the specified insulation between
 between
 TNV-3 circuits and SELV circuits, although the question about Annex ZB
 applies
 to other national deviations as well.  I will use the TNV/SELV issue as an
 example.
 
 Clause 6.2.1.2 of EN 60950 specifies basic insulation between TNV-3 and
 SELV
 circuits.  However, in Annex ZB, it states that Norway and Sweden require
 supplementary insulation.  Annex ZB states that for the countries in
 which
 the special national conditions apply, these provisions are normative.
 For
 other countries they are informative.
 
 I am trying to understand how this distinction is applied for CE marking.
 I
 thought that the intent of CE marking was that products could be evaluated
 against harmonized standards and then have the CE marking applied.  I
 thought that products with the CE marking were allowed to move freely
 among
 the member countries in the EU.  Annex ZB seems to complicate this simple
 interpretation. 
 
 My tentative conclusions about the above situation are:
 
 1) A manufacturer who intends to market his product in a list of EU
 countries
 that excludes Norway and Sweden can apply the CE marking to a product that
 has
 only basic insulation between TNV-3 and SELV circuits.
 
 2) A manufacturer who intends to market his product in a list of  EU
 countries
 that includes Norway or Sweden can only apply the CE mark if the product
 provides supplementary insulation between TNV-3 and SELV circuits.
 
 The above two cases result in products that each bear identical CE
 marking,
 but one of them (case 1) is technically illegal for use in Norway and
 Sweden.
 From looking at the product marking, there is no way to determine that the
 product in case 1 should not be used in Norway or Sweden.
 
 I suppose that this distinction could be made in the user manual.  I also
 presume that the manufacturer in case 1 would be obligated to ensure that
 the
 product is not offered for sale in Norway or Sweden.  Maybe this is enough
 to
 comply with the letter of the law, but I suspect that it would be easy for
 the
 product in case 1 to find its way into Norway and Sweden.
 
 Prior to the adoption of CTR 21 for analog modems, the above issue was
 largely
 academic, since individual national approvals and the corresponding
 national
 labels were still required for connection to the PSTN.
 
 However, now that CTR 21 has been adopted, I expect there will be a rush
 toward full CE marking (including the crossed hockey sticks) of analog
 modems.  National approval labels will no longer be required.  I think
 this
 will bring additional attention to the situation I have described above.
 
 Can anyone offer some some insight into how this situation should be
 handled?
 Is my interpretation correct?  Any comments would be welcome.
 
 
 Joe Randolph
 Telecom Design Consultant
 Randolph Telecom, Inc.
 325 Highland Avenue
 Winchester, MA, USA  01890
 781-721-2848 (voice)
 781-721-0582 (fax)
 
 
 
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Re[2]: CE marking vs. Annex ZB in EN60950

1998-08-19 Thread ron_pickard
 Richard et al,
 
 To respond:

 An excellent question!
 
 Yes it was.
 
 Let me ask one or two of my own here.
 
 1. Are we sure that both Sweden and Norway are currently EU members ?  
 Not just IEC members ?
 
 IEC members? Actually, Sweden is a recent member of the EU. Norway is not an 
EU 
 member. The EEA (European Economic Area), also referred to as EFTA I believe, 
 comprises the EU and various neighboring countries around the EU, which 
 includes Norway. The CE requirements are generally accepted throughout all of 
 these countries.
 
 Regardless of that answer the question really remains valid for the other 
 items in annex ZB
 
 Actually, the 6.2.1.2 Norway question and others in Annex ZB are moot if a 
type 
 B plug is used instead of a type A plug.
 
 2. Would it be reasonable that these National Requirements are only 
 applicable when getting a National Approval, and that they are not 
 applicable to CE marking and compliance with the EN standard ?
 
 According to Article 2 of the Low Voltage Directive (LVD) as amended by 
 93/68/EEC, compliance must be proven prior to placing a product on the market.
 
 In accordance with Article 10 of the LVD, the CE marking is the only required 
 product marking. Other markings liable to deceive third parties as to the 
 meaning and form of the CE marking shall be prohibited. Although, I suppose 
 this means that individual NB marks are still allowed, but not required.
 
 Article 12 of the LVD describes that the LVD does not apply to products 
 intended for export to third countries, or outside the EU and EEA. By this 
 definition, the LVD applies to all member states within the EU, and referred 
to 
 by the agreement on the EEA.
 
 I hope to see a lot of opinions, this should be interesting.
 
 Opinions would be nice to see, but the law makers in the EU seem to have made 
 these issues cut and dry. Of course, everything's open to interpretation.
 
 Comments?
 
 Best regards,
 Ron Pickard
 ron_pick...@hypercom.com