Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[John Woodgate]

There is an article here on the new European safety law: 
https://digital.incompliancemag.com/issue/november-2023/


On 2023-11-02 10:24, Glyn Payne wrote:


There is always the RoHS Directive that demands the CE Mark even if no 
other Directives apply.


Glyn Payne

*From:*John Woodgate 
*Sent:* 01 November 2023 20:20
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] [EXTERNAL] [PSES] General Product Safety 
Directive (GPSD)


Somewhere in all the Byzantine rules, there is a ban on applying the 
CE mark if *no* Directive or Regulation that demands it applies to the 
product.


On 2023-11-01 19:58, Ralph McDiarmid wrote:

Furthermore, I have not found anything document which says that
you cannot CE mark a product having a DofC listing the GPSR.  The
proviso that you can issue a DofC against Directive 2001/95/EC but
cannot CE mark the product is not stated anywhere in the official
website of the EU (Europa.eu) or in the GPSD.  Perhaps it’s just
well hidden.



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Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[Glyn Payne]

There is always the RoHS Directive that demands the CE Mark even if no other 
Directives apply.

Glyn Payne

From: John Woodgate 
Sent: 01 November 2023 20:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)


Somewhere in all the Byzantine rules, there is a ban on applying the CE mark if 
no Directive or Regulation that demands it applies to the product.
On 2023-11-01 19:58, Ralph McDiarmid wrote:
Furthermore, I have not found anything document which says that you cannot CE 
mark a product having a DofC listing the GPSR.  The proviso that you can issue 
a DofC against Directive 2001/95/EC but cannot CE mark the product is not 
stated anywhere in the official website of the EU (Europa.eu) or in the GPSD.  
Perhaps it’s just well hidden.


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[PSES] SV: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[Amund Westin]

Thanks, Ted,

 

I fully support your comments.

 

BR
Amund

 

Fra: John Woodgate 
Sendt: 1. november 2023 20:01
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

 

Precisely. It's utter folly not to carry out, and document, appropriate safety 
tests.

On 2023-11-01 18:35, Ted Eckert wrote:

Hello Amund,

 

The GPSR is not a CE-marking Directive, and products that fall under the GPSR 
can be placed on the market without safety information on the Declaration of 
Conformity if they do not fall under any other Directive that requires a 
declaration for safety. However, that is only related to what is on the 
Declaration of Conformity, affecting the ability to properly import a product 
into the EU.

 

However, regulations on the import of products are not the only regulations 
affecting product safety requirements. Product liability law exists in the 27 
EU member states. If you have a professional product meeting the requirements 
you propose, and there is some allegation of a safety issue, the customer can 
seek remedies from the importer, distributor, and/or manufacturer. Your ability 
to defend your company in court will be significantly diminished if you have no 
documentation showing that a safety analysis has been done. 

 

In general, all of the economic actors involved in selling products carry the 
responsibility of making sure the products they sell meet legal requirements. 
It will be up to your legal department to determine the risk of placing a 
product on the market without a safety evaluation. The need for producing 
safety documentation might not be limited only to the RED, LVD, or GPSR.

 

Best regard,

Ted Eckert

 

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

 

 

From: Amund Westin  <mailto:am...@westin-emission.no> 
 
Sent: Wednesday, November 1, 2023 12:41 AM
To: Ted Eckert  <mailto:ted.eck...@microsoft.com> ; 
EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: SV: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

 

Thanks Ted,

 

As I read your comments and take they into an example - … consider a 
professional electronic product, which can’t be bought or even used by 
consumers, will not under any circumstances be covered by GPSD/GPSR. Right?

And if product is low powered (not within LVD), then maybe only EMC apply. Then 
the product could be put on the market without any safety related tests …. Is 
that correct?

 

 

BR
Amund

 

 

Fra: Ted Eckert 
Sendt: 31. oktober 2023 16:10
Til: Amund Westin < <mailto:am...@westin-emission.no> 
am...@westin-emission.no>;  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
EMC-PSTC@LISTSERV.IEEE.ORG
Emne: RE: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

 

Hello Amund,

 

The GPSR has these definitions. I recommend you use them as the basis to 
determine if you are providing “consumer products” as covered by the scope of 
the GPSR.

  

“‘product’ means any item, whether or not it is interconnected to other items, 
supplied or made available, whether for consideration or not, including in the 
context of providing a service, which is intended for consumers or is likely, 
under reasonably foreseeable conditions, to be used by consumers even if not 
intended for them”.

 

“’consumer’ means any natural person who acts for purposes which are outside 
that person’s trade, bushiness, craft or profession”.

 

There is no clear line drawn between consumer and professional equipment, and 
the GPSR is intended to cover professional equipment that is likely to be 
purchased for personal use by some consumers. Products that fall into this grey 
area may need to be reviewed on a case-by-case basis. I would recommend that if 
you determine a product is not within the scope, your technical file include a 
clear explanation of why it is out of scope.

 

Best regard,

Ted Eckert

 

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

 

 

 

-Original Message-
From: Amund Westin mailto:am...@westin-emission.no> 
> 
Sent: Tuesday, October 31, 2023 7:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

 

General Product Safety Directive ... Do I interpret correct that GPSD only 
apply to consumer products? Not for any professional products?

And the new General Product Safety Regulation (GPSR) do the same?

 

 

BR

Amund

 

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Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[Ted Eckert]

There are many directives that are not CE marking directives, including both 
the GPSD and GPSR. Other examples are WEEE and the energy/ecodesign 
requirements for products. For example, computers must comply with 617/2013, 
but the CE mark is not specified to show compliance. Many energy directives 
have the labels with the A-G ratings as proof of compliance.
Energy label and ecodesign 
(europa.eu)<https://commission.europa.eu/energy-climate-change-environment/standards-tools-and-labels/products-labelling-rules-and-requirements/energy-label-and-ecodesign_en>

Ted Eckert
The opinions expressed in this message are my own and do not necessarily 
reflect those of my employer.

From: Ralph McDiarmid 
Sent: Wednesday, November 1, 2023 2:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

I found that too, but isn’t the GPSD a “new approach” directive ?   I am sure 
it must be; it was certainly published after 1985.  By that criterion alone, it 
seems appropriate to apply the mark.

From: John Mcbain mailto:johnmcb...@ieee.org>>
Sent: Wednesday, November 1, 2023 1:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

Correct. Or more specifically -

https://single-market-economy.ec.europa.eu/single-market/ce-marking_en#:~:text=It%20is%20compulsory%20only%20for,origin%20of%20a%20product%20either.

Best regards,
John McBain


On Wed, Nov 1, 2023 at 1:20 PM John Woodgate 
mailto:j...@woodjohn.uk>> wrote:

Somewhere in all the Byzantine rules, there is a ban on applying the CE mark if 
no Directive or Regulation that demands it applies to the product.
On 2023-11-01 19:58, Ralph McDiarmid wrote:
Furthermore, I have not found anything document which says that you cannot CE 
mark a product having a DofC listing the GPSR.  The proviso that you can issue 
a DofC against Directive 2001/95/EC but cannot CE mark the product is not 
stated anywhere in the official website of the EU (Europa.eu) or in the GPSD.  
Perhaps it’s just well hidden.


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Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[Ralph McDiarmid]

I found that too, but isn’t the GPSD a “new approach” directive ?   I am sure 
it must be; it was certainly published after 1985.  By that criterion alone, it 
seems appropriate to apply the mark.   

 

From: John Mcbain  
Sent: Wednesday, November 1, 2023 1:49 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

 

Correct. Or more specifically - 

 

https://single-market-economy.ec.europa.eu/single-market/ce-marking_en#:~:text=It%20is%20compulsory%20only%20for,origin%20of%20a%20product%20either.




Best regards,

John McBain

 

 

On Wed, Nov 1, 2023 at 1:20 PM John Woodgate mailto:j...@woodjohn.uk> > wrote:

Somewhere in all the Byzantine rules, there is a ban on applying the CE mark if 
no Directive or Regulation that demands it applies to the product.

On 2023-11-01 19:58, Ralph McDiarmid wrote:

Furthermore, I have not found anything document which says that you cannot CE 
mark a product having a DofC listing the GPSR.  The proviso that you can issue 
a DofC against Directive 2001/95/EC but cannot CE mark the product is not 
stated anywhere in the official website of the EU (Europa.eu) or in the GPSD.  
Perhaps it’s just well hidden. 


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Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[John Mcbain]

Correct. Or more specifically -

https://single-market-economy.ec.europa.eu/single-market/ce-marking_en#:~:text=It%20is%20compulsory%20only%20for,origin%20of%20a%20product%20either
.

Best regards,
John McBain


On Wed, Nov 1, 2023 at 1:20 PM John Woodgate  wrote:

> Somewhere in all the Byzantine rules, there is a ban on applying the CE
> mark if *no* Directive or Regulation that demands it applies to the
> product.
> On 2023-11-01 19:58, Ralph McDiarmid wrote:
>
> Furthermore, I have not found anything document which says that you cannot
> CE mark a product having a DofC listing the GPSR.  The proviso that you can
> issue a DofC against Directive 2001/95/EC but cannot CE mark the product is
> not stated anywhere in the official website of the EU (Europa.eu) or in the
> GPSD.  Perhaps it’s just well hidden.
>
> --
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
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Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[John Woodgate]

Somewhere in all the Byzantine rules, there is a ban on applying the CE 
mark if *no* Directive or Regulation that demands it applies to the product.


On 2023-11-01 19:58, Ralph McDiarmid wrote:
Furthermore, I have not found anything document which says that you 
cannot CE mark a product having a DofC listing the GPSR.  The proviso 
that you can issue a DofC against Directive 2001/95/EC but cannot CE 
mark the product is not stated anywhere in the official website of the 
EU (Europa.eu) or in the GPSD.  Perhaps it’s just well hidden. 


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Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[Ralph McDiarmid]

What is meant by “safety information on the Declaration of Conformity”?  A DofC 
contains a list of applicable EU directives and standards.  I’ve never been 
asked to draft a DofC for signature with “safety information” in it.

 

Furthermore, I have not found anything document which says that you cannot CE 
mark a product having a DofC listing the GPSR.  The proviso that you can issue 
a DofC against Directive 2001/95/EC but cannot CE mark the product is not 
stated anywhere in the official website of the EU (Europa.eu) or in the GPSD.  
Perhaps it’s just well hidden. 

 

If you don’t CE mark, you’ll have trouble with a few countries in the EU.  
Customs people seem to look for that mark, even though it is not a formal 
condition of import.  

 

 

Ralph

 

From: John Woodgate  
Sent: Wednesday, November 1, 2023 12:01 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

 

Precisely. It's utter folly not to carry out, and document, appropriate safety 
tests.

On 2023-11-01 18:35, Ted Eckert wrote:

Hello Amund,

 

The GPSR is not a CE-marking Directive, and products that fall under the GPSR 
can be placed on the market without safety information on the Declaration of 
Conformity if they do not fall under any other Directive that requires a 
declaration for safety. However, that is only related to what is on the 
Declaration of Conformity, affecting the ability to properly import a product 
into the EU.

 

However, regulations on the import of products are not the only regulations 
affecting product safety requirements. Product liability law exists in the 27 
EU member states. If you have a professional product meeting the requirements 
you propose, and there is some allegation of a safety issue, the customer can 
seek remedies from the importer, distributor, and/or manufacturer. Your ability 
to defend your company in court will be significantly diminished if you have no 
documentation showing that a safety analysis has been done. 

 

In general, all of the economic actors involved in selling products carry the 
responsibility of making sure the products they sell meet legal requirements. 
It will be up to your legal department to determine the risk of placing a 
product on the market without a safety evaluation. The need for producing 
safety documentation might not be limited only to the RED, LVD, or GPSR.

 

Best regard,

Ted Eckert

 

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

 

 

From: Amund Westin  <mailto:am...@westin-emission.no> 
 
Sent: Wednesday, November 1, 2023 12:41 AM
To: Ted Eckert  <mailto:ted.eck...@microsoft.com> ; 
EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: SV: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

 

Thanks Ted,

 

As I read your comments and take they into an example - … consider a 
professional electronic product, which can’t be bought or even used by 
consumers, will not under any circumstances be covered by GPSD/GPSR. Right?

And if product is low powered (not within LVD), then maybe only EMC apply. Then 
the product could be put on the market without any safety related tests …. Is 
that correct?

 

 

BR
Amund

 

 

Fra: Ted Eckert 
Sendt: 31. oktober 2023 16:10
Til: Amund Westin < <mailto:am...@westin-emission.no> 
am...@westin-emission.no>;  <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
EMC-PSTC@LISTSERV.IEEE.ORG
Emne: RE: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

 

Hello Amund,

 

The GPSR has these definitions. I recommend you use them as the basis to 
determine if you are providing “consumer products” as covered by the scope of 
the GPSR.

  

“‘product’ means any item, whether or not it is interconnected to other items, 
supplied or made available, whether for consideration or not, including in the 
context of providing a service, which is intended for consumers or is likely, 
under reasonably foreseeable conditions, to be used by consumers even if not 
intended for them”.

 

“’consumer’ means any natural person who acts for purposes which are outside 
that person’s trade, bushiness, craft or profession”.

 

There is no clear line drawn between consumer and professional equipment, and 
the GPSR is intended to cover professional equipment that is likely to be 
purchased for personal use by some consumers. Products that fall into this grey 
area may need to be reviewed on a case-by-case basis. I would recommend that if 
you determine a product is not within the scope, your technical file include a 
clear explanation of why it is out of scope.

 

Best regard,

Ted Eckert

 

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

 

 

 

-Original Message-
From: Amund Westin mailto:am...@westin-emission.no> 
> 
Sent: Tuesday, October 31, 2023 7:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@

Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[John Woodgate]

Precisely. It's utter folly not to carry out, and document, appropriate 
safety tests.


On 2023-11-01 18:35, Ted Eckert wrote:


Hello Amund,

The GPSR is not a CE-marking Directive, and products that fall under 
the GPSR can be placed on the market without safety information on the 
Declaration of Conformity if they do not fall under any other 
Directive that requires a declaration for safety. However, that is 
only related to what is on the Declaration of Conformity, affecting 
the ability to properly import a product into the EU.


However, regulations on the import of products are not the only 
regulations affecting product safety requirements. Product liability 
law exists in the 27 EU member states. If you have a professional 
product meeting the requirements you propose, and there is some 
allegation of a safety issue, the customer can seek remedies from the 
importer, distributor, and/or manufacturer. Your ability to defend 
your company in court will be significantly diminished if you have no 
documentation showing that a safety analysis has been done.


In general, all of the economic actors involved in selling products 
carry the responsibility of making sure the products they sell meet 
legal requirements. It will be up to your legal department to 
determine the risk of placing a product on the market without a safety 
evaluation. The need for producing safety documentation might not be 
limited only to the RED, LVD, or GPSR.


Best regard,

Ted Eckert

/The opinions expressed are my own and do not necessarily reflect 
those of my employer./


*From:*Amund Westin 
*Sent:* Wednesday, November 1, 2023 12:41 AM
*To:* Ted Eckert ; EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* SV: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

Thanks Ted,

As I read your comments and take they into an example - … consider a 
professional electronic product, which can’t be bought or even used by 
consumers, will not under any circumstances be covered by GPSD/GPSR. 
Right?


And if product is low powered (not within LVD), then maybe only EMC 
apply. Then the product could be put on the market without any safety 
related tests …. Is that correct?


BR
Amund

*Fra:*Ted Eckert
*Sendt:* 31. oktober 2023 16:10
*Til:* Amund Westin >; EMC-PSTC@LISTSERV.IEEE.ORG 


*Emne:* RE: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

Hello Amund,

The GPSR has these definitions. I recommend you use them as the basis 
to determine if you are providing “consumer products” as covered by 
the scope of the GPSR.


“‘product’ means any item, whether or not it is interconnected to 
other items, supplied or made available, whether for consideration or 
not, including in the context of providing a service, which is 
intended for consumers or is likely, under reasonably foreseeable 
conditions, to be used by consumers even if not intended for them”.


“’consumer’ means any natural person who acts for purposes which are 
outside that person’s trade, bushiness, craft or profession”.


There is no clear line drawn between consumer and professional 
equipment, and the GPSR is intended to cover professional equipment 
that is likely to be purchased for personal use by some consumers. 
Products that fall into this grey area may need to be reviewed on a 
case-by-case basis. I would recommend that if you determine a product 
is not within the scope, your technical file include a clear 
explanation of why it is out of scope.


Best regard,

Ted Eckert

/The opinions expressed are my own and do not necessarily reflect 
those of my employer./


-Original Message-
From: Amund Westin 
Sent: Tuesday, October 31, 2023 7:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

General Product Safety Directive ... Do I interpret correct that GPSD 
only apply to consumer products? Not for any professional products?


And the new General Product Safety Regulation (GPSR) do the same?

BR

Amund

-



This message is from the IEEE Product Safety Engineering Society 
emc-pstc discussion list. To post a message to the list, send your 
e-mail to mailto:emc-p...@ieee.org>>


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Website: 

Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[Ted Eckert]

Hello Amund,

The GPSR is not a CE-marking Directive, and products that fall under the GPSR 
can be placed on the market without safety information on the Declaration of 
Conformity if they do not fall under any other Directive that requires a 
declaration for safety. However, that is only related to what is on the 
Declaration of Conformity, affecting the ability to properly import a product 
into the EU.

However, regulations on the import of products are not the only regulations 
affecting product safety requirements. Product liability law exists in the 27 
EU member states. If you have a professional product meeting the requirements 
you propose, and there is some allegation of a safety issue, the customer can 
seek remedies from the importer, distributor, and/or manufacturer. Your ability 
to defend your company in court will be significantly diminished if you have no 
documentation showing that a safety analysis has been done.

In general, all of the economic actors involved in selling products carry the 
responsibility of making sure the products they sell meet legal requirements. 
It will be up to your legal department to determine the risk of placing a 
product on the market without a safety evaluation. The need for producing 
safety documentation might not be limited only to the RED, LVD, or GPSR.

Best regard,
Ted Eckert

The opinions expressed are my own and do not necessarily reflect those of my 
employer.


From: Amund Westin 
Sent: Wednesday, November 1, 2023 12:41 AM
To: Ted Eckert ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

Thanks Ted,

As I read your comments and take they into an example - ... consider a 
professional electronic product, which can't be bought or even used by 
consumers, will not under any circumstances be covered by GPSD/GPSR. Right?
And if product is low powered (not within LVD), then maybe only EMC apply. Then 
the product could be put on the market without any safety related tests  Is 
that correct?


BR
Amund


Fra: Ted Eckert
Sendt: 31. oktober 2023 16:10
Til: Amund Westin mailto:am...@westin-emission.no>>; 
EMC-PSTC@LISTSERV.IEEE.ORG
Emne: RE: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)


Hello Amund,



The GPSR has these definitions. I recommend you use them as the basis to 
determine if you are providing "consumer products" as covered by the scope of 
the GPSR.



"'product' means any item, whether or not it is interconnected to other items, 
supplied or made available, whether for consideration or not, including in the 
context of providing a service, which is intended for consumers or is likely, 
under reasonably foreseeable conditions, to be used by consumers even if not 
intended for them".



"'consumer' means any natural person who acts for purposes which are outside 
that person's trade, bushiness, craft or profession".



There is no clear line drawn between consumer and professional equipment, and 
the GPSR is intended to cover professional equipment that is likely to be 
purchased for personal use by some consumers. Products that fall into this grey 
area may need to be reviewed on a case-by-case basis. I would recommend that if 
you determine a product is not within the scope, your technical file include a 
clear explanation of why it is out of scope.

Best regard,
Ted Eckert

The opinions expressed are my own and do not necessarily reflect those of my 
employer.






-Original Message-
From: Amund Westin mailto:am...@westin-emission.no>>
Sent: Tuesday, October 31, 2023 7:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)



General Product Safety Directive ... Do I interpret correct that GPSD only 
apply to consumer products? Not for any professional products?

And the new General Product Safety Regulation (GPSR) do the same?





BR

Amund



-



This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>



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Website:  

Re: [PSES] [EXTERNAL] [PSES] General Product Safety Directive (GPSD)

[Ted Eckert]

Hello Amund,



The GPSR has these definitions. I recommend you use them as the basis to 
determine if you are providing "consumer products" as covered by the scope of 
the GPSR.



"'product' means any item, whether or not it is interconnected to other items, 
supplied or made available, whether for consideration or not, including in the 
context of providing a service, which is intended for consumers or is likely, 
under reasonably foreseeable conditions, to be used by consumers even if not 
intended for them".



"'consumer' means any natural person who acts for purposes which are outside 
that person's trade, bushiness, craft or profession".



There is no clear line drawn between consumer and professional equipment, and 
the GPSR is intended to cover professional equipment that is likely to be 
purchased for personal use by some consumers. Products that fall into this grey 
area may need to be reviewed on a case-by-case basis. I would recommend that if 
you determine a product is not within the scope, your technical file include a 
clear explanation of why it is out of scope.

Best regard,
Ted Eckert

The opinions expressed are my own and do not necessarily reflect those of my 
employer.






-Original Message-
From: Amund Westin 
Sent: Tuesday, October 31, 2023 7:54 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [EXTERNAL] [PSES] General Product Safety Directive (GPSD)



General Product Safety Directive ... Do I interpret correct that GPSD only 
apply to consumer products? Not for any professional products?

And the new General Product Safety Regulation (GPSR) do the same?





BR

Amund



-



This message is from the IEEE Product Safety Engineering Society emc-pstc 
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