Re: [PSES] HAR factories for marked cable
Looking at the LVD guidance, (and of course it's guidance not law) http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , page 28 Products Scope of LVD Examples of productsComments Cables Yes [picture of cable] Marked with HAR to increase tractability Regards Charlie -Original Message- From: Cortland Richmond [mailto:k...@earthlink.net] Sent: 26 April 2013 06:36 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] HAR factories for marked cable It looks very much as if this is a NGO, an association of firms who have trademarked a useful indicator of compliance, but one that is in no way required for entry to the EU marketplace If it were to become a required mark, however, that could compare to the situation of some decades ago, when localities and States in the US sometimes required a UL (tm) mark on electrical equipment, thus restricting testing to that one firm's labs. This was eventually ruled an unlawful barrier to competition, and we now use the term Nationally Recognized Test Laboratory (NRTL) to describe all the recognized labs whose marks are acceptable. I suspect a similar logic might then apply, were a non-EU cable manufacturer to find his product denied entry for lack of the HAR mark. Could be wrong: I am not a lawyer. Cortland Richmond - 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 emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald: dhe...@gmail.commailto:dhe...@gmail.com - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
In message 3f0347ac6ed9504191f91f07629fbb0c0155b...@thhsle14mbx2.hslive.net, dated Fri, 26 Apr 2013, Charlie Blackham char...@sulisconsultants.com writes: Looking at the LVD guidance, (and of course it's guidance not law) http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , page 28 Products Scope of LVD Examples of products Comments Cables Yes [picture of cable] Marked with HAR to increase tractability 'tractability' - the quality of being easily managed I suspect weasel wording here. The Commission has no business apparently elevating a private marking scheme to a requirement under a Directive. So using a confusing word may be a way to 'fog' the issue. Some people will assume it's a typo for 'traceability'. Participation in the HAR scheme is *effectively* restricted to certification bodies (it's not a manufacturers' organization) in Europe because ENs and HDs must be in force in the country - from the HAR site: QUOTE Within the country of the applicant, the European ENs and HDs must have formally entered into force; any conflicting national standards must have been withdrawn. Assessment of capability and qualification of the candidate by a HAR assessment team, according to harmonised requirements; positive results to be formally endorsed by the HAR Group. ENDQUOTE This restriction must, in fact, bear some responsibility for the widespread presence of dangerous fake 'HAR' marked cables. I have a sample alleged to have 0.75 mm^2 conductors, which are barely 0.3 mm^2 in fact, fitted with a fake British 13 A plug marked '10 A' but without a fuse. The point is that if you use a test house and the cable isn't HAR marked, the test house may well want to test the cable to whichever of HD 21, HD 22, EN 50525, EN 50143, EN 50214, EN 60702 or EN 61138 applies, and that is extremely costly. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk They took me to a specialist burns unit - and made me learn 'To a haggis'. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
Something seems to have got lost along the way here: The original question was not who can grant the HAR mark?, but (paraphrased) must the cable factory be in the EU? The answer to the factory question is No, as millions of consumer products made outside the EU with HAR marked cable shows. (and yes there is falsely marked cable too) John C. -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 26 April 2013 09:06 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] HAR factories for marked cable In message 3f0347ac6ed9504191f91f07629fbb0c0155b...@thhsle14mbx2.hslive.net, dated Fri, 26 Apr 2013, Charlie Blackham char...@sulisconsultants.com writes: Looking at the LVD guidance, (and of course it's guidance not law) http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , page 28 Products Scope of LVD Examples of products Comments Cables Yes [picture of cable] Marked with HAR to increase tractability 'tractability' - the quality of being easily managed I suspect weasel wording here. The Commission has no business apparently elevating a private marking scheme to a requirement under a Directive. So using a confusing word may be a way to 'fog' the issue. Some people will assume it's a typo for 'traceability'. Participation in the HAR scheme is *effectively* restricted to certification bodies (it's not a manufacturers' organization) in Europe because ENs and HDs must be in force in the country - from the HAR site: QUOTE Within the country of the applicant, the European ENs and HDs must have formally entered into force; any conflicting national standards must have been withdrawn. Assessment of capability and qualification of the candidate by a HAR assessment team, according to harmonised requirements; positive results to be formally endorsed by the HAR Group. ENDQUOTE This restriction must, in fact, bear some responsibility for the widespread presence of dangerous fake 'HAR' marked cables. I have a sample alleged to have 0.75 mm^2 conductors, which are barely 0.3 mm^2 in fact, fitted with a fake British 13 A plug marked '10 A' but without a fuse. The point is that if you use a test house and the cable isn't HAR marked, the test house may well want to test the cable to whichever of HD 21, HD 22, EN 50525, EN 50143, EN 50214, EN 60702 or EN 61138 applies, and that is extremely costly. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk They took me to a specialist burns unit - and made me learn 'To a haggis'. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
In message 7878A08362FE46DCBD64C291ACE4BA2F@LENVOR61iJOHN, dated Fri, 26 Apr 2013, John Cotman john.cot...@conformance.co.uk writes: Something seems to have got lost along the way here: The original question was not who can grant the HAR mark?, but (paraphrased) must the cable factory be in the EU? The answer to the factory question is No, as millions of consumer products made outside the EU with HAR marked cable shows. (and yes there is falsely marked cable too) The original question was 'A cable supplier has mentioned that cables cannot bear the HAR marking if they are not manufactured within an EU country. This seems to be buried in HAR agreement documents that are out of my reach. Can anyone confirm this? ' Note 'Cannot bear the HAR marking'. I don't think anything much has been lost. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk They took me to a specialist burns unit - and made me learn 'To a haggis'. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
Thank you, Art. I had visited the wwpca.eu web site earlier yesterday. There is a statement under ABOUT THE HAR MARK, “The HAR Mark was established and is operating with the full support of the cable manufacturers located in the CENELEC countries, represented by the European cable manufacturers association EUROPACABLE,” but it falls short of limiting manufacturing locations to CENELEC countries. Under HOW THE HAR MARK WORKS, there are similar inferences, but again fall short of an overt statement. I suppose one of the contacts on the site will be able to elucidate on this further. Regards, Peter Tarver *From:* safetyl...@gmail.com [mailto:safetyl...@gmail.com] *On Behalf Of *Arthur Michael *Sent:* Wednesday, April 24, 2013 20:14 *To:* Peter Tarver *Cc:* EMC-PSTC@listserv.ieee.org *Subject:* Re: [PSES] HAR factories for marked cable Hi Peter et al, Here is a link to the official HAR Fact Sheet [as found on Safetylink.com]; http://www.eepca.eu/dev/page.php?p=203 Best regards, Art Product Safety Int'l Middletown, CT 06457 www.safetylink.com = On Wed, Apr 24, 2013 at 7:38 PM, Peter Tarver ptar...@enphaseenergy.com wrote: Good afternoon. A cable supplier has mentioned that cables cannot bear the HAR marking if they are not manufactured within an EU country. This seems to be buried in HAR agreement documents that are out of my reach. Can anyone confirm this? Regards, Peter L. Tarver This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
It looks very much as if this is a NGO, an association of firms who have trademarked a useful indicator of compliance, but one that is in no way required for entry to the EU marketplace If it were to become a required mark, however, that could compare to the situation of some decades ago, when localities and States in the US sometimes required a UL (tm) mark on electrical equipment, thus restricting testing to that one firm's labs. This was eventually ruled an unlawful barrier to competition, and we now use the term Nationally Recognized Test Laboratory (NRTL) to describe all the recognized labs whose marks are acceptable. I suspect a similar logic might then apply, were a non-EU cable manufacturer to find his product denied entry for lack of the HAR mark. Could be wrong: I am not a lawyer. Cortland Richmond - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] HAR factories for marked cable
Good afternoon. A cable supplier has mentioned that cables cannot bear the HAR marking if they are not manufactured within an EU country. This seems to be buried in HAR agreement documents that are out of my reach. Can anyone confirm this? Regards, Peter L. Tarver This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
Have never heard this. Note this link: http://www.interpower.com/ic/news/infopower/harmonized-cable/ Most of my EU-bound stuff that include input power cord assembly is not made in EU, and have had no import problems. yet. If this is true, I would also really appreciate an advisory on the reference. Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Peter Tarver Sent: Wednesday, April 24, 2013 4:38 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: HAR factories for marked cable Good afternoon. A cable supplier has mentioned that cables cannot bear the HAR marking if they are not manufactured within an EU country. This seems to be buried in HAR agreement documents that are out of my reach. Can anyone confirm this? Regards, Peter L. Tarver - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
Hi Peter et al, Here is a link to the official HAR Fact Sheet [as found on Safetylink.com]; http://www.eepca.eu/dev/page.php?p=203 Best regards, Art Product Safety Int'l Middletown, CT 06457 www.safetylink.com = On Wed, Apr 24, 2013 at 7:38 PM, Peter Tarver ptar...@enphaseenergy.comwrote: Good afternoon. A cable supplier has mentioned that cables cannot bear the HAR marking if they are not manufactured within an EU country. This seems to be buried in HAR agreement documents that are out of my reach. Can anyone confirm this? Regards, Peter L. Tarver This email message is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. If you are not an intended recipient, you may not review, use, copy, disclose or distribute this message. If you received this message in error, please contact the sender by reply email and destroy all copies of the original message. - - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] HAR factories for marked cable
In message CAHZd_TyKnhZKQdcUkkX5YFnFw7d4aZY874Ae+m=ing9h_7-...@mail.gmail.com, dated Wed, 24 Apr 2013, Arthur Michael amich...@safetylink.com writes: Here is a link to the official HAR Fact Sheet [as found on Safetylink.com]; http://www.eepca.eu/dev/page.php?p=203 All the public pages on that site have important information. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk They took me to a specialist burns unit - and made me learn 'To a haggis'. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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 emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
