Re: [PSES] EU Authorized Representative AR)

[Chris Wordley]

Hi Steve

‘authorised representative’ means any natural or legal person established 
within the Union who has received a written mandate from a manufacturer to act 
on its behalf in relation to specified tasks with regard to the manufacturer's 
obligations under the relevant Union harmonisation legislation or under the 
requirements of this Regulation. 
[from Regulation (EU) 2019/1020]

An AR based in Great Britain is therefore not acceptable. An AR based in 
Northern Ireland would be acceptable, since it's part of the EU single market. 

Best Regards
Chris 

> On 15 Aug 2023, at 16:52, Steve Brody  wrote:
> 
> Is it correct that an AR on an EU DoC cannot be based in the UK, even though 
> the UK is still accepting EU DoCs, and therefore EU ARs?
>  
> Steve Brody
> sgbr...@comcast.net 
> C - 603 617 9116
> This message is from the IEEE Product Safety Engineering Society emc-pstc 
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[PSES] EU Authorized Representative AR)

[Steve Brody]

Is it correct that an AR on an EU DoC cannot be based in the UK, even though 
the UK is still accepting EU DoCs, and therefore EU ARs?
 
Steve Brody
sgbr...@comcast.net mailto:sgbr...@comcast.net
C - 603 617 9116

-

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Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents or via affixed QR

[Scott Xe]

Dear Bernd & Charlie,

Thanks for your advice!!  For the time being, we have to put the safety
instructions with the unit.

Best regards,

Scott


On Tue, 15 Aug 2023 at 15:54, Dürrer Bernd  wrote:

> Dear Scott,
>
>
>
> I agree with Charlie Blackham’s conclusions on instructions in electronic
> format embedded in the device. I am not aware of any plans to amend LVD and
> RED to align their requirements on instructions with the new Machinery
> regulation. However, as the monetary and environmental costs due to
> extensive paper-based documentation has been identified as one of the
> problems of the old Machinery Directive (cf.
> eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0082&rid=3,
> p. 21 and 41ff.), I hope that there will be an initiative to introduce an
> option for digital documentation also in other directives and regulations.
>
>
>
> Currently, you have to follow Charlie’s advice to provide a short printed
> guide with the mandatory instructions and safety information. If you are
> lucky and all mandatory information for your product can be presented
> graphically, you may avoid to translate the document to the 24 official EU
> languages and the additional 3 languages of states in the European Economic
> Area (EEA) and the EU-Turkey Customs Union (DocsRoom - European
> Commission (europa.eu) ,
> p. 246).
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
>
>
>
>
> *Von:* Scott Xe 
> *Gesendet:* Dienstag, 15. August 2023 08:24
> *An:* Dürrer Bernd 
> *Cc:* EMC-PSTC@listserv.ieee.org
> *Betreff:* Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying
> documents or via affixed QR
>
>
>
> [EXTERNAL E-MAIL] This email originated from outside of the organization.
> Do not click links or open attachments unless you recognize the sender.
>
> Dear Bernd,
>
>
>
> Although LVD and RED are modern directives, they are considered old
> compared with MR issued in 2023.  Could the view on instructions in
> electronic format be aligned all together one day?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
>
>
>
>
> On Tue, 15 Aug 2023 at 13:27, Scott Xe  wrote:
>
> Dear Bernd,
>
>
>
> Thanks for your good references!  The LVD and RED do not decline the
> instructions in electronic format.  What about those instructions embedded
> in the ROM as the memory is not expensive as before?  For example, mobile
> phones, TVs, etc.
>
>
>
> Regards,
>
>
>
> Scott
>
>
>
>
>
>
>
> On Mon, 14 Aug 2023 at 15:14, Dürrer Bernd  wrote:
>
> Hi Amund,
>
>
>
> In the European Union, it depends on the Directive that is applicable for
> your product. Both the Low Voltage Directive 2014/35/EU 
> (L_2014096EN.01035701.xml
> (europa.eu)
> ,
> Article 6, Point 7, Article 8, Point 4, and Article 9, Point 2) and the
> Radio Directive 2014/53/EU (Consolidated TEXT: 32014L0053 — EN —
> 27.12.2022 (europa.eu)
> ,
> Article 10, Point 8, Article 12, Point 4, and Article 13, Point 2) require
> that manufacturers, importers, and distributors ensure that the product is
> accompanied by instructions and safety information. Only new regulation
> (EU) 2023/1230 that will replace Machinery Directive in January 2027 allows
> to provide instructions in digital format (L_2023165EN.01000101.xml
> (europa.eu)
> ,
> Article 10, Point 7).
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* John Woodgate 
> *Gesendet:* Sonntag, 13. August 2023 19:14
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] SV: [PSES] User manual by accompanying documents or
> via affixed QR
>
>
>
> [EXTERNAL E-MAIL] This email originated from outside of the organization.
> Do not click links or open attachments unless you recognize the sender.
>
> No. I don't see so many EU documents as others here do, and it is very
> difficult, as you know, to find a document when you don't know a document
> title to look for. I am remembering information posted here quite a long
> time ago.
>
> On 2023-08-13 17:56, Amund Westin wrote:
>
> Yes, I was thinking that a short paper guide would help. URL link is
> important as you say, and QR are actually for advanced mobile users.
>
>
>
> Have you seen this issue been discussed in “Blue Guide” or other EU
> documents?
>
>
>
>
>
>
>
>
>
> *Fra:* John Woodgate
> *Sendt:* 13. august 2023 18:43
> *Til:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Emne:* Re: [PSES] User manual by accompanying documents or via affixed QR
>
>
>
> I believe that in Europe, it is not allowed. Current practice seems to be
> to include with the product a short  'User Guide' or similar, which
> includes the safety information required by the relevant safety standard,
> and the DOC(s), together with a text link of the URL of the full User
> Manual. You coul

[PSES] AW: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents or via affixed QR

[Dürrer Bernd]

Dear Scott,

I agree with Charlie Blackham's conclusions on instructions in electronic 
format embedded in the device. I am not aware of any plans to amend LVD and RED 
to align their requirements on instructions with the new Machinery regulation. 
However, as the monetary and environmental costs due to extensive paper-based 
documentation has been identified as one of the problems of the old Machinery 
Directive (cf. 
eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0082&rid=3,
 p. 21 and 41ff.), I hope that there will be an initiative to introduce an 
option for digital documentation also in other directives and regulations.

Currently, you have to follow Charlie's advice to provide a short printed guide 
with the mandatory instructions and safety information. If you are lucky and 
all mandatory information for your product can be presented graphically, you 
may avoid to translate the document to the 24 official EU languages and the 
additional 3 languages of states in the European Economic Area (EEA) and the 
EU-Turkey Customs Union (DocsRoom - European Commission 
(europa.eu), p. 246).

Kind regards,

Bernd



Von: Scott Xe 
Gesendet: Dienstag, 15. August 2023 08:24
An: Dürrer Bernd 
Cc: EMC-PSTC@listserv.ieee.org
Betreff: Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents 
or via affixed QR

[EXTERNAL E-MAIL] This email originated from outside of the organization. Do 
not click links or open attachments unless you recognize the sender.
Dear Bernd,

Although LVD and RED are modern directives, they are considered old compared 
with MR issued in 2023.  Could the view on instructions in electronic format be 
aligned all together one day?

Thanks and regards,

Scott


On Tue, 15 Aug 2023 at 13:27, Scott Xe 
mailto:scott...@gmail.com>> wrote:
Dear Bernd,

Thanks for your good references!  The LVD and RED do not decline the 
instructions in electronic format.  What about those instructions embedded in 
the ROM as the memory is not expensive as before?  For example, mobile phones, 
TVs, etc.

Regards,

Scott



On Mon, 14 Aug 2023 at 15:14, Dürrer Bernd 
mailto:bernd.duer...@wilo.com>> wrote:
Hi Amund,

In the European Union, it depends on the Directive that is applicable for your 
product. Both the Low Voltage Directive 2014/35/EU (L_2014096EN.01035701.xml 
(europa.eu),
 Article 6, Point 7, Article 8, Point 4, and Article 9, Point 2) and the Radio 
Directive 2014/53/EU (Consolidated TEXT: 32014L0053 - EN - 27.12.2022 
(europa.eu),
 Article 10, Point 8, Article 12, Point 4, and Article 13, Point 2) require 
that manufacturers, importers, and distributors ensure that the product is 
accompanied by instructions and safety information. Only new regulation (EU) 
2023/1230 that will replace Machinery Directive in January 2027 allows to 
provide instructions in digital format (L_2023165EN.01000101.xml 
(europa.eu),
 Article 10, Point 7).

Kind regards,

Bernd

Von: John Woodgate mailto:j...@woodjohn.uk>>
Gesendet: Sonntag, 13. August 2023 19:14
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: Re: [PSES] SV: [PSES] User manual by accompanying documents or via 
affixed QR

[EXTERNAL E-MAIL] This email originated from outside of the organization. Do 
not click links or open attachments unless you recognize the sender.

No. I don't see so many EU documents as others here do, and it is very 
difficult, as you know, to find a document when you don't know a document title 
to look for. I am remembering information posted here quite a long time ago.
On 2023-08-13 17:56, Amund Westin wrote:
Yes, I was thinking that a short paper guide would help. URL link is important 
as you say, and QR are actually for advanced mobile users.

Have you seen this issue been discussed in "Blue Guide" or other EU documents?




Fra: John Woodgate
Sendt: 13. august 2023 18:43
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] User manual by accompanying documents or via affixed QR


I believe that in Europe, it is not allowed. Current practice seems to be to 
include with the product a short  'User Guide' or similar, which includes the 
safety information required by the relevant safety standard, and the DOC(s), 
together with a text link of the URL of the full User Manual. You could include 
a QR code in addition, but not instead of the text link, because about 15 % of 
people don't have a smart phone or don't know much about using it for anything 
but calls, text messages and the camera.
On 2023-08-13 16:57, Amund Westin wrote:
To avoid a lot of pa

[PSES] AW: [PSES] Friday Question - Line Cords in China

[Dürrer Bernd]

Hi Chuck,

my understanding of the Chinese regulation for CCC is that it is only 
applicable to finished products that are listed in the catalogue (like an 
external switch mode power supply that may be brought to market as a separate 
product) or parts of finished products that are accessible to the end user 
(like cord and plug). Therefore I assume that CCC is not required for internal 
switch mode power supplies that are not accessible to the user during normal 
use. In case of doubt, I recommend to check with your local representative or 
distributor/importer in China.

Kind regards,

Bernd

Von: Chuck August-McDowell 
Gesendet: Montag, 14. August 2023 16:26
An: Dürrer Bernd 
Betreff: RE: [PSES] Friday Question - Line Cords in China

[EXTERNAL E-MAIL] This email originated from outside of the organization. Do 
not click links or open attachments unless you recognize the sender.
Thank you, Bernd.
I suspected that is the law but had no citation to refer to.

What about internal switch mode power supplies?
Should they have CCC as it is a requirement for that category code?

Respectfully,

Chuck McDowell
Meyer Sound Laboratories
2832 San Pablo Ave.
Berkeley Ca., 94702 USA
Mobile 510-812-6277
Email chu...@meyersound.com

From: Dürrer Bernd mailto:bernd.duer...@wilo.com>>
Sent: Monday, August 14, 2023 2:58 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AW: [PSES] Friday Question - Line Cords in China


[THIS EMAIL IS FROM AN EXTERNAL SENDER]
Hi Doug,

please be aware that line cords and plugs are subject to mandatory CCC 
certification in the People’s Republic of China (cf. CHINA QUALITY 
CERTIFICATION CENTRE-Notice and Bulletin 
(cqc.com.cn)). 
This means even if your product is exempt from mandatory CCC certification 
(i.e. is not included in the product catalogue cited in the web page), but has 
a cord and plug, these have to be CCC certified. Details on certification rules 
can be found at CHINA QUALITY CERTIFICATION CENTRE-Certification Scope and 
Rules 
(cqc.com.cn) and 
康捷 
(cqc.com.cn),
 that references Chinese standard GB 15934 which is the Chinese adoption of IEC 
60799.

Kind regards,

Bernd

Von: Douglas Powell mailto:doug...@gmail.com>>
Gesendet: Freitag, 11. August 2023 16:00
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: [PSES] Friday Question - Line Cords in China

[EXTERNAL E-MAIL] This email originated from outside of the organization. Do 
not click links or open attachments unless you recognize the sender.
All,

I was talking with a client recently about shipping line cords to various 
countries around the world and how some do not allow the incorrect cords within 
a shipment while others do. Brazil, as far as I know, does not permit incorrect 
cordage. Argentina, Australia, and China (PRC) are all mutually exclusive. 
South Africa and India are mutually exclusive. Japan, Taiwan, and the United 
States are all mutually exclusive. If not prohibited, it is frequently cheaper 
to include multiple cords rather than create multiple regional SKUs when 
products are in low-volume production.

That said, apparently the China market often likes to use US-style receptacles 
(types A or B), even though they use 220 V (😬). The US-style plug has better 
density (twice as many receptacles in the same space as the China receptacle 
(Type C, or I ?), and with the US receptacles, there are many more aftermarket 
cable options available.  So I suppose that's my question: "Is this usage 
typical in China?"

Of course, the big issue is that the US plug is not rated for the higher 
voltages, even though historically some people may say it works.  I even fouind 
a website that shows this, 
https://www.travelchinaguide.com/essential/electricity.htm

I believe it is critical for manufacturers to not condone the use of the US 
plug in this manner, which appears to be common practice. And I usually advise 
that this type of usage should never be described, recommended, or mentioned in 
any manuals, brochures, or other written material produced by a company, either 
externally or internally. If anyone is injured and an investigation reveals 
agreement with this usage, the company may be held liable.

Thoughts??

-Doug


Douglas E Powell
Laporte, Colorado, USA
doug...@gmail.com
LinkedIn

(UTC-06:00, US-MDT)




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