Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-12-03 Thread John Woodgate
In message , 
dated Mon, 3 Dec 2012, "ce-test, qualified testing bv - Gert Gremmen" 
 writes:


3. Member States shall ensure that the manufacturer or the person 
responsible for placing the apparatus on the market provides 
information for the user on the intended use of the apparatus, together 
with the declaration of conformity to the essential requirements.



Let me rephrase that citation, and interpret it again:

3. Member States shall ensure that the manufacturer or the person 
responsible for placing the apparatus on the market provides 
information for the user on the intended use of the apparatus, together 
with the check of USD 100.--.


How  would you understand the word together then,  John?

The information to the user and the check to the Prince William ?


No, the cheque to me, of course. Unless it's a US 'check', i.e. an 
invoice.(;-)


The point is not about WHO the data are provided to, but what 'provided' 
means.


But the thread has moved on a lot. This morning I posted what has been 
semi-officially (i.e. from an organ of the Commission but not 
necessarily a statement of the law) advised for inclusion in user 
manuals:


Hereby, [Name of manufacturer], declares that this [type of equipment] 
is in compliance with the essential requirements and other relevant 
provisions of Directive 1999/5/EC.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-12-03 Thread ce-test, qualified testing bv - Gert Gremmen
John Woodgate wrote (actually cited):

Article 6 3. of the RTTED says:

  3. Member States shall ensure that the manufacturer or the person responsible 
for placing the apparatus on the market provides information for the user on 
the intended use of the apparatus, together with the declaration of conformity 
to the essential requirements.


Let me rephrase that citation, and interpret it again:

3. Member States shall ensure that the manufacturer or the person responsible 
for placing the apparatus on the market provides information for the user on 
the intended use of the apparatus, together with the check of USD 100.--.

How  would you understand the word together then,  John?

The information to the user and the check to the Prince William ?


Regards,

Ing.  Gert Gremmen, BSc



g.grem...@cetest.nl
www.cetest.nl

Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953

 Before printing, think about the environment. 



-Oorspronkelijk bericht-
Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate
Verzonden: Monday, December 03, 2012 9:43 AM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] Language Translations for EU Declarations of Conformity 
(DOCs)

In message
<3f0347ac6ed9504191f91f07629fbb0c01503...@thhsle14mbx2.hslive.net>,
dated Mon, 3 Dec 2012, Charlie Blackham 
writes:

>
>It?s covered in the Europa Interpretation of the R&TTE Directive:
>
>http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/in
>d
>ex_en.htm#h2-23
>
> 
You mean it's politically fudged there. Having 'interpreted' the word 'the' to 
mean that every item has to have the DoC with it (!), it settles for something 
quite different to be included in the user
instructions:

Hereby, [Name of manufacturer], declares that this [type of equipment] is in 
compliance with the essential requirements and other relevant provisions of 
Directive 1999/5/EC.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a 
point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-12-03 Thread Michael Derby
Hello,

 

I think that in the past, there was always the general understanding that a
full copy of the DoC must be supplied with each device sold.

 

However, more and more people are simply adding a statement to their user
manual to state something like:   "This device complies with the relevant
provisions of Directive 1999/5/EC"  and then making sure that their full DoC
is available online, or something like that.

If you're going to do that, it's recommended to make sure the statement is
in every language, or at least in the language of the country it's arriving
into.

 

This document is very useful..

http://ec.europa.eu/enterprise/sectors/rtte/files/guidance/guidance_en.pdf

 

I have known people to have their product stopped at customs because the
package did not include the full DoC in, for example, Polish.   However, the
manufacturer quickly got one translated and supplied, so their product was
allowed in.

 

I know that some people still insist that the full DoC must be supplied with
each device but I think it's generally considered acceptable to just make
sure the 'statement of compliance' is provided and that the full DoC is at
least available.   Online is good.

I believe that the proposed new R&TTE Directive text should officially allow
this approach, I hope.

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Charlie Blackham [mailto:char...@sulisconsultants.com] 
Sent: 03 December 2012 08:25
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

 

 

It's covered in the Europa Interpretation of the R&TTE Directive:

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm#h2-23 

 

regards

Charlie

 

 

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 30 November 2012 19:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

 

In message < <mailto:3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk>
3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk>,

dated Thu, 29 Nov 2012, Nick Williams <
<mailto:nick.willi...@conformance.co.uk> nick.willi...@conformance.co.uk>

writes:

 

>AIUI, the R+TTE Directive also requires this, and there are others 

>which do the same.

 

Article 6 3. of the RTTED says:

 

  3. Member States shall ensure that the manufacturer or the person
responsible for placing the apparatus on the market provides information for
the user on the intended use of the apparatus, together with the declaration
of conformity to the essential requirements.

 

Nowhere that I can find does it say a DoC has to accompany every unit.

--

OOO - Own Opinions Only. See  <http://www.jmwa.demon.co.uk>
www.jmwa.demon.co.uk The longer it takes to make a point, the more obtuse it
proves to be.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

 

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-12-03 Thread John Woodgate
In message 
<3f0347ac6ed9504191f91f07629fbb0c01503...@thhsle14mbx2.hslive.net>, 
dated Mon, 3 Dec 2012, Charlie Blackham  
writes:




It?s covered in the Europa Interpretation of the R&TTE Directive:

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/ind
ex_en.htm#h2-23

 
You mean it's politically fudged there. Having 'interpreted' the word 
'the' to mean that every item has to have the DoC with it (!), it 
settles for something quite different to be included in the user 
instructions:


Hereby, [Name of manufacturer], declares that this [type of equipment] 
is in compliance with the essential requirements and other relevant 
provisions of Directive 1999/5/EC.


--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-12-03 Thread Charlie Blackham


It's covered in the Europa Interpretation of the R&TTE Directive:

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_en.htm#h2-23



regards

Charlie





-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk]
Sent: 30 November 2012 19:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Language Translations for EU Declarations of Conformity 
(DOCs)



In message 
<3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk<mailto:3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk>>,

dated Thu, 29 Nov 2012, Nick Williams 
mailto:nick.willi...@conformance.co.uk>>

writes:



>AIUI, the R+TTE Directive also requires this, and there are others

>which do the same.



Article 6 3. of the RTTED says:



  3. Member States shall ensure that the manufacturer or the person responsible 
for placing the apparatus on the market provides information for the user on 
the intended use of the apparatus, together with the declaration of conformity 
to the essential requirements.



Nowhere that I can find does it say a DoC has to accompany every unit.

--

OOO - Own Opinions Only. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> 
The longer it takes to make a point, the more obtuse it proves to be.

John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK



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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-30 Thread John Woodgate
In message , 
dated Fri, 30 Nov 2012, Nick Williams  
writes:


Surely 'information for the user..' has to accompany every unit and if 
the DofC has to accompany the information then it does not seem to me 
there is much room for doubt  that the Directive requires a Declaration 
to accompany every unit. Can you explain the basis on which you think 
this is not the case?


The information and DoC can be provided with the invoice for a whole 
shipment (a necessity, I think, because that's what border control 
officers will look at) or in a catalogue or technical information sheet, 
or, these days, on a web site. As long as the user can freely see and 
read it, that is 'provided'.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-30 Thread Nick Williams
Surely 'information for the user..' has to accompany every unit and if the DofC 
has to accompany the information then it does not seem to me there is much room 
for doubt  that the Directive requires a Declaration to accompany every unit. 
Can you explain the basis on which you think this is not the case?


On 30 Nov 2012, at 19:01, John Woodgate  wrote:

> In message <3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk>, dated 
> Thu, 29 Nov 2012, Nick Williams  writes:
> 
>> AIUI, the R+TTE Directive also requires this, and there are others which do 
>> the same.
> 
> Article 6 3. of the RTTED says:
> 
> 3. Member States shall ensure that the manufacturer or
> the person responsible for placing the apparatus on the
> market provides information for the user on the intended
> use of the apparatus, together with the declaration of
> conformity to the essential requirements.
> 
> Nowhere that I can find does it say a DoC has to accompany every unit.

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-30 Thread John Woodgate
In message <3a33c563-1637-4755-b1ef-8247792e6...@conformance.co.uk>, 
dated Thu, 29 Nov 2012, Nick Williams  
writes:


AIUI, the R+TTE Directive also requires this, and there are others 
which do the same.


Article 6 3. of the RTTED says:

 3. Member States shall ensure that the manufacturer or
the person responsible for placing the apparatus on the
market provides information for the user on the intended
use of the apparatus, together with the declaration of
conformity to the essential requirements.

Nowhere that I can find does it say a DoC has to accompany every unit.
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] SV: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-30 Thread Amund Westin
Thanks Helge 
I only looked through the RTTE directive text. The interpretations are
important stuff, of course.

Best regards
Amund



-Opprinnelig melding-
Fra: Helge Knudsen [mailto:hknud...@mail.tele.dk] 
Sendt: 30. november 2012 08:58
Til: amund; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG
Emne: RE: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

Hello Amund,

Yes it does, see

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm#h2-23

Best regards

Helge Knudsen
Denmark

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Amund Westin
Sent: 30. november 2012 08:44
To: 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

RTTE does not say anything about the language of the DOC, right?

#Amund


-Opprinnelig melding-
Fra: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sendt: 29. november 2012 18:06
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

A DofC must go with every unit. 

AIUI, the R+TTE Directive also requires this, and there are others which do
the same. 

Nick. 


On 29 Nov 2012, at 16:18, Jim Hulbert  wrote:

> From article 5 of the Machinery Directive, the manufacturer or 
> authorized
representative shall, among other things:
> "(e) draw up the EC declaration of conformity in accordance with Annex 
> II,
part 1, Section A and ensure that it accompanies the machinery;"
> 
> Does the above mean the DoC must be supplied with each piece of 
> equipment,
or as John stated:  "One full copy should go with every shipment that
crosses an EU border, or a Member State border..."?
> 
> Jim Hulbert
> 

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-30 Thread Helge Knudsen
Hello Amund,

Yes it does, see

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm#h2-23

Best regards

Helge Knudsen
Denmark

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Amund Westin
Sent: 30. november 2012 08:44
To: 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

RTTE does not say anything about the language of the DOC, right?

#Amund


-Opprinnelig melding-
Fra: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sendt: 29. november 2012 18:06
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

A DofC must go with every unit. 

AIUI, the R+TTE Directive also requires this, and there are others which do
the same. 

Nick. 


On 29 Nov 2012, at 16:18, Jim Hulbert  wrote:

> From article 5 of the Machinery Directive, the manufacturer or 
> authorized
representative shall, among other things:
> "(e) draw up the EC declaration of conformity in accordance with Annex 
> II,
part 1, Section A and ensure that it accompanies the machinery;"
> 
> Does the above mean the DoC must be supplied with each piece of 
> equipment,
or as John stated:  "One full copy should go with every shipment that
crosses an EU border, or a Member State border..."?
> 
> Jim Hulbert
> 

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[PSES] SV: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-29 Thread Amund Westin
RTTE does not say anything about the language of the DOC, right?

#Amund


-Opprinnelig melding-
Fra: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sendt: 29. november 2012 18:06
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

A DofC must go with every unit. 

AIUI, the R+TTE Directive also requires this, and there are others which do
the same. 

Nick. 


On 29 Nov 2012, at 16:18, Jim Hulbert  wrote:

> From article 5 of the Machinery Directive, the manufacturer or authorized
representative shall, among other things:
> "(e) draw up the EC declaration of conformity in accordance with Annex II,
part 1, Section A and ensure that it accompanies the machinery;"
> 
> Does the above mean the DoC must be supplied with each piece of equipment,
or as John stated:  "One full copy should go with every shipment that
crosses an EU border, or a Member State border..."?
> 
> Jim Hulbert
> 

-

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-29 Thread Pete Perkins
Monrad, et al,

Lot's of discussion trying to determine how many ways the pie could
be cut.  

From what little I know about all of this I will continue to
recommend that my clients reproduce the text of the MDoC in the instruction
manual in such a way that it will be translated into whatever languages are
needed to sell the product locally within the EU.  This seems to get by
fretting about the details - and puts the burden on a correct translation
upon the (EU local) translator hired to do the work.  

Interesting discussion tho...  

:>) br, Pete

 

Peter E Perkins, PE

Principal Product Safety Engineer

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201 fone/fax

p.perk...@ieee.org

 

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-29 Thread Nick Williams
A DofC must go with every unit. 

AIUI, the R+TTE Directive also requires this, and there are others which do the 
same. 

Nick. 


On 29 Nov 2012, at 16:18, Jim Hulbert  wrote:

> From article 5 of the Machinery Directive, the manufacturer or authorized 
> representative shall, among other things:
> "(e) draw up the EC declaration of conformity in accordance with Annex II, 
> part 1, Section A and ensure that it accompanies the machinery;"
> 
> Does the above mean the DoC must be supplied with each piece of equipment, or 
> as John stated:  "One full copy should go with every shipment that crosses an 
> EU border, or a Member State border..."?
> 
> Jim Hulbert
> 

-

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-29 Thread John Woodgate
In message <01cdce54$56fabca0$04f035e0$@tele.dk>, dated Thu, 29 Nov 
2012, Helge Knudsen  writes:


If the directive defines that a full DoC shall  be delivered with the 
product, I will deliver one in English and a sheet with a general in 
the EU languages as set up for the R&TTE directive:


Hereby, [Name of manufacturer], declares that this [type of equipment] 
is in compliance with the essential requirements and other relevant 
provisions of Directive /Number/EC. (repeated in the 10 other EU 
languages)


If more than one directive shall be met, simply write Directives 
/Number/EC , /Number/EC&&&.


All harmonized standards applied must also be listed, as DATED 
references, e.g. EN 5:2012

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] SV: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-29 Thread John Woodgate
In message 
<7b9d892f88f070469771832d78b3086e0f6...@013-br1mpn1-011.mgdpbi.global.pvt

>, dated Thu, 29 Nov 2012, Jim Hulbert  writes:

Does the above mean the DoC must be supplied with each piece of 
equipment, or as John stated:  "One full copy should go with every 
shipment that crosses an EU border, or a Member State border..."?


No-one knows until a court has decided what that terribly vague wording 
means.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-29 Thread Helge Knudsen
Hello group,

 

I would still use the model which is suggested for the R&TTE directive, see:

 

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm#h2-23

 

If the directive defines that a full DoC shall  be delivered with the
product, I will deliver one in English and a sheet with a general in the EU
languages as set up for the R&TTE directive:

Hereby, [Name of manufacturer], declares that this [type of equipment] is in
compliance with the essential requirements and other relevant provisions of
Directive /Number/EC. (repeated in the 10 other EU languages)

If more than one directive shall be met, simply write Directives
/Number/EC , /Number/EC……….

 

And deliver one full DoC for each directive if needed.

 

Best regards

 

Helge Knudsen

Denmark

 

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Amund Westin
Sent: 29. november 2012 15:38
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: SV: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

 

Some of ours DoC contain references to RTTE, MED and even CPD. Now ROHS must
be included as well.

With EUT product and manufacture information the DoC will be a full A4 page.

With the new language requirements, we have to attach to each EUT approx 25
pages A4 sheets? …. or what? …

 

Best regards

Amund 

 

Fra: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sendt: 29. november 2012 15:27
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

 

EU DOCs are not what you would call a wordy document. Most of the text would
not get translated anyway, such as manufacturer name, address, product
models, references to directives and standards, etc..

 

There would only be a few lines of text that would need to be translated in
23 to 26 languages, such as

 

“Declares that the product:”

“Conforms to the following”

“The product herewith fulfils all relevant provisions of the ……”

 

It would seem likely that these translations have already been made by
people out there if they would be willing to share it.

 

The Other Brian

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick
Williams
Sent: Wednesday, November 28, 2012 7:24 PM
To: Monrad Monsen
Cc: emc-p...@ieee.org
Subject: Re: Language Translations for EU Declarations of Conformity (DOCs)

 

There is a list of the official languages in the Commission Guide to the
Machinery Directive, available here:

 

http://ec.europa.eu/enterprise/sectors/mechanical/machinery/

 

See §246. 

 

English will not suffice - if the Directive says the Declaration needs to be
translated, then it needs to be in one of the official languages of each
state in which the product is sold. 

 

I'm pretty sure that failure to deliver the Declaration in the correct
language(s) has been cited as a non-compliance in enforcement actions in the
past, although only as one item among several - I'v e never seen it cited as
sole reason for rejection. 

 

Nick. 

 

 

 

 

 

On 28 Nov 2012, at 20:43, Monrad Monsen  wrote:

 

RoHS Directive 2011/65/EU, Article 13 (EU Declaration of Conformity) section
2 states:  "The EU declaration of conformity ... shall be translated into
the language or languages required by the Member State on the market of
which the product is placed or made available."

This raises some questions:
1.  What languages are required by the member states for translating
declarations of conformity (DOCs)?  

2.  Would English suffice for a DOC?  I would hope that any one language
within the community would be acceptable for the DOC, and English would be
the easiest language for American companies to use.

3.  If a member state does want a DOC in a language other than English,
would they the English version immediately and then allow the manufacturer
time to translate the DOC like a period of two months?

RoHS Directive 2011/65/EU becomes mandatory on 1 January 2013, so these
questions are urgent.

Monrad Monsen
+1.303.272.9612

-


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David Heald  

 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

-

Conf

Re: [PSES] SV: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-29 Thread Jim Hulbert
>From article 5 of the Machinery Directive, the manufacturer or authorized 
>representative shall, among other things:
"(e) draw up the EC declaration of conformity in accordance with Annex II, part 
1, Section A and ensure that it accompanies the machinery;"

Does the above mean the DoC must be supplied with each piece of equipment, or 
as John stated:  "One full copy should go with every shipment that crosses an 
EU border, or a Member State border..."?

Jim Hulbert

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate
Sent: Thursday, November 29, 2012 10:46 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: SV: [PSES] Language Translations for EU Declarations of Conformity 
(DOCs)

In message <01cdce3f$1e74e050$5b5ea0f0$@no>, dated Thu, 29 Nov 2012, Amund 
Westin  writes:

>Some of ours DoC contain references to RTTE, MED and even CPD. Now ROHS
>must be included as well.
>
>With EUT product and manufacture information the DoC will be a full A4
>page.

Not really; that's about 15 lines of text, and you can use quite a small font 
size. You could also adopt the way calculator instructions are printed - on 
both sides of an A3 or larger sheet, which is then folded up.
>
>With the new language requirements, we have to attach to each EUT
>approx 25 pages A4 sheets? &. or what? &

Most Directives do not require a full DoC to be supplied with every item. Is 
there any Directive that does? One full copy should go with every shipment that 
crosses an EU border, or a Member State border (because spurious shipments are 
coming in through some EU countries, which have been found in Germany and 
Austria).
--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk The longer it takes to make a 
point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Mike Cantwell 

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Jim Bacher:  
David Heald: 




-

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Website:  http://www.ieee-pses.org/
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For help, send mail to the list administrators:
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For policy questions, send mail to:
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David Heald: 


Re: [PSES] SV: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-29 Thread John Woodgate
In message <01cdce3f$1e74e050$5b5ea0f0$@no>, dated Thu, 29 Nov 2012, 
Amund Westin  writes:


Some of ours DoC contain references to RTTE, MED and even CPD. Now ROHS 
must be included as well.


With EUT product and manufacture information the DoC will be a full A4 
page.


Not really; that's about 15 lines of text, and you can use quite a small 
font size. You could also adopt the way calculator instructions are 
printed - on both sides of an A3 or larger sheet, which is then folded 
up.


With the new language requirements, we have to attach to each EUT 
approx 25 pages A4 sheets? &. or what? &


Most Directives do not require a full DoC to be supplied with every 
item. Is there any Directive that does? One full copy should go with 
every shipment that crosses an EU border, or a Member State border 
(because spurious shipments are coming in through some EU countries, 
which have been found in Germany and Austria).

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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list. To post a message to the list, send your e-mail to 

All emc-pstc postings are archived and searchable on the web at:
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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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 


[PSES] SV: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-29 Thread Amund Westin
Some of ours DoC contain references to RTTE, MED and even CPD. Now ROHS must
be included as well.

With EUT product and manufacture information the DoC will be a full A4 page.

With the new language requirements, we have to attach to each EUT approx 25
pages A4 sheets? …. or what? …

 

Best regards

Amund 

 

Fra: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sendt: 29. november 2012 15:27
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] Language Translations for EU Declarations of Conformity
(DOCs)

 

EU DOCs are not what you would call a wordy document. Most of the text would
not get translated anyway, such as manufacturer name, address, product
models, references to directives and standards, etc..

 

There would only be a few lines of text that would need to be translated in
23 to 26 languages, such as

 

“Declares that the product:”

“Conforms to the following”

“The product herewith fulfils all relevant provisions of the ……”

 

It would seem likely that these translations have already been made by
people out there if they would be willing to share it.

 

The Other Brian

 

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick
Williams
Sent: Wednesday, November 28, 2012 7:24 PM
To: Monrad Monsen
Cc: emc-p...@ieee.org
Subject: Re: Language Translations for EU Declarations of Conformity (DOCs)

 

There is a list of the official languages in the Commission Guide to the
Machinery Directive, available here:

 

http://ec.europa.eu/enterprise/sectors/mechanical/machinery/

 

See §246. 

 

English will not suffice - if the Directive says the Declaration needs to be
translated, then it needs to be in one of the official languages of each
state in which the product is sold. 

 

I'm pretty sure that failure to deliver the Declaration in the correct
language(s) has been cited as a non-compliance in enforcement actions in the
past, although only as one item among several - I'v e never seen it cited as
sole reason for rejection. 

 

Nick. 

 

 

 

 

 

On 28 Nov 2012, at 20:43, Monrad Monsen  wrote:

 

RoHS Directive 2011/65/EU, Article 13 (EU Declaration of Conformity) section
2 states:  "The EU declaration of conformity ... shall be translated into
the language or languages required by the Member State on the market of
which the product is placed or made available."

This raises some questions:
1.  What languages are required by the member states for translating
declarations of conformity (DOCs)?  

2.  Would English suffice for a DOC?  I would hope that any one language
within the community would be acceptable for the DOC, and English would be
the easiest language for American companies to use.

3.  If a member state does want a DOC in a language other than English,
would they the English version immediately and then allow the manufacturer
time to translate the DOC like a period of two months?

RoHS Directive 2011/65/EU becomes mandatory on 1 January 2013, so these
questions are urgent.

Monrad Monsen
+1.303.272.9612

-


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Nick Williams
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Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646 

 

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  _  


LEC

Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-29 Thread Kunde, Brian
EU DOCs are not what you would call a wordy document. Most of the text would 
not get translated anyway, such as manufacturer name, address, product models, 
references to directives and standards, etc..

There would only be a few lines of text that would need to be translated in 23 
to 26 languages, such as

"Declares that the product:"
"Conforms to the following"
"The product herewith fulfils all relevant provisions of the .."

It would seem likely that these translations have already been made by people 
out there if they would be willing to share it.

The Other Brian

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams
Sent: Wednesday, November 28, 2012 7:24 PM
To: Monrad Monsen
Cc: emc-p...@ieee.org
Subject: Re: Language Translations for EU Declarations of Conformity (DOCs)

There is a list of the official languages in the Commission Guide to the 
Machinery Directive, available here:

http://ec.europa.eu/enterprise/sectors/mechanical/machinery/

See §246.

English will not suffice - if the Directive says the Declaration needs to be 
translated, then it needs to be in one of the official languages of each state 
in which the product is sold.

I'm pretty sure that failure to deliver the Declaration in the correct 
language(s) has been cited as a non-compliance in enforcement actions in the 
past, although only as one item among several - I'v e never seen it cited as  
sole reason for rejection.

Nick.





On 28 Nov 2012, at 20:43, Monrad Monsen 
mailto:monrad.mon...@oracle.com>> wrote:


RoHS Directive 2011/65/EU, Article 13 (EU Declaration of Conformity) section 2 
states:  "The EU declaration of conformity ... shall be translated into the 
language or languages required by the Member State on the market of which the 
product is placed or made available."

This raises some questions:
1.  What languages are required by the member states for translating 
declarations of conformity (DOCs)?

2.  Would English suffice for a DOC?  I would hope that any one language within 
the community would be acceptable for the DOC, and English would be the easiest 
language for American companies to use.

3.  If a member state does want a DOC in a language other than English, would 
they the English version immediately and then allow the manufacturer time to 
translate the DOC like a period of two months?

RoHS Directive 2011/65/EU becomes mandatory on 1 January 2013, so these 
questions are urgent.

Monrad Monsen
+1.303.272.9612

-


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discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

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Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, 
www.conformance.co.uk
Registered in England, Company No. 3478646

-


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discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

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LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destr

Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-28 Thread Knighten, Jim L
To the best of my knowledge the Commission has provided no guidance as to 
specific languages required relative to the RoHS Directive.

__
James L. Knighten, Ph.D.
EMC Engineer
Teradata Corporation
17095 Via Del Campo
San Diego, CA 92127
858-485-2537 - phone
858-485-3788 - fax (unattended)


From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sent: Wednesday, November 28, 2012 4:24 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Language Translations for EU Declarations of Conformity 
(DOCs)

There is a list of the official languages in the Commission Guide to the 
Machinery Directive, available here:

http://ec.europa.eu/enterprise/sectors/mechanical/machinery/

See §246.

English will not suffice - if the Directive says the Declaration needs to be 
translated, then it needs to be in one of the official languages of each state 
in which the product is sold.

I'm pretty sure that failure to deliver the Declaration in the correct 
language(s) has been cited as a non-compliance in enforcement actions in the 
past, although only as one item among several - I'v e never seen it cited as  
sole reason for rejection.

Nick.





On 28 Nov 2012, at 20:43, Monrad Monsen 
mailto:monrad.mon...@oracle.com>> wrote:


RoHS Directive 2011/65/EU, Article 13 (EU Declaration of Conformity) section 2 
states:  "The EU declaration of conformity ... shall be translated into the 
language or languages required by the Member State on the market of which the 
product is placed or made available."

This raises some questions:
1.  What languages are required by the member states for translating 
declarations of conformity (DOCs)?

2.  Would English suffice for a DOC?  I would hope that any one language within 
the community would be acceptable for the DOC, and English would be the easiest 
language for American companies to use.

3.  If a member state does want a DOC in a language other than English, would 
they the English version immediately and then allow the manufacturer time to 
translate the DOC like a period of two months?

RoHS Directive 2011/65/EU becomes mandatory on 1 January 2013, so these 
questions are urgent.

Monrad Monsen
+1.303.272.9612

-


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>>

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 mailto:emcp...@radiusnorth.net>>
Mike Cantwell mailto:mcantw...@ieee.org>>

For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org>>
David Heald mailto:dhe...@gmail.com>>

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk<mailto:nick.willi...@conformance.co.uk>

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, 
www.conformance.co.uk<http://www.conformance.co.uk>
Registered in England, Company No. 3478646

-


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>>

All emc-pstc postings are archived and searchable on the web at: 
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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
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For help, send mail to the list administrators:
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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 


All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communiti

Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-28 Thread Nick Williams
There is a list of the official languages in the Commission Guide to the 
Machinery Directive, available here:

http://ec.europa.eu/enterprise/sectors/mechanical/machinery/

See §246. 

English will not suffice - if the Directive says the Declaration needs to be 
translated, then it needs to be in one of the official languages of each state 
in which the product is sold. 

I'm pretty sure that failure to deliver the Declaration in the correct 
language(s) has been cited as a non-compliance in enforcement actions in the 
past, although only as one item among several - I'v e never seen it cited as  
sole reason for rejection. 

Nick. 





On 28 Nov 2012, at 20:43, Monrad Monsen  wrote:

> RoHS Directive 2011/65/EU, Article 13 (EU Declaration of Conformity) section 
> 2 states:  "The EU declaration of conformity ... shall be translated into the 
> language or languages required by the Member State on the market of which the 
> product is placed or made available."
> 
> This raises some questions:
> 1.  What languages are required by the member states for translating 
> declarations of conformity (DOCs)?  
> 
> 2.  Would English suffice for a DOC?  I would hope that any one language 
> within the community would be acceptable for the DOC, and English would be 
> the easiest language for American companies to use.
> 
> 3.  If a member state does want a DOC in a language other than English, would 
> they the English version immediately and then allow the manufacturer time to 
> translate the DOC like a period of two months?
> 
> RoHS Directive 2011/65/EU becomes mandatory on 1 January 2013, so these 
> questions are urgent.
> 
> Monrad Monsen
> +1.303.272.9612
> -
> 
> 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 
> 
> 
> 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 
> Mike Cantwell 
> 
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
> 

Nick Williams
Director
Direct line: +44 1298 873811
Mobile: +44 7702 995135
email: nick.willi...@conformance.co.uk

-

Conformance Ltd - Product safety, approvals and CE-marking consultants
The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England
Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk
Registered in England, Company No. 3478646


-

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 


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 
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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:
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Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 


Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-28 Thread Knighten, Jim L
Monrad,


1.   To the best of my knowledge there is no definition as to which 
specific languages are required.  My company has taken the position to provide 
the DoC in English plus four European languages (German, French, Italian, & 
Spanish).  If more languages become required, we will deal with it then. 
Practically, the DoC text must be translated.  The list of Directives and 
Standards largely unchanged product to product and do not require much effort 
to translate.  In other words, we have DoC templates in each language.

2.   We have accepted that the implied position of the Directive is that 
English only is not sufficient for DoCs.

3.   Will your approach be sufficient?  I think it is unknown, but clearly 
the intent of the Directive is to provide the DoC in European languages.

P.S.: Our products are not consumer products, so user expectations may be 
different than for consumer products.

Jim

__
James L. Knighten, Ph.D.
EMC Engineer
Teradata Corporation
17095 Via Del Campo
San Diego, CA 92127
858-485-2537 – phone
858-485-3788 – fax (unattended)


From: Monrad Monsen [mailto:monrad.mon...@oracle.com]
Sent: Wednesday, November 28, 2012 12:43 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

RoHS Directive 2011/65/EU, Article 13 (EU Declaration of Conformity) section 2 
states:  "The EU declaration of conformity ... shall be translated into the 
language or languages required by the Member State on the market of which the 
product is placed or made available."

This raises some questions:
1.  What languages are required by the member states for translating 
declarations of conformity (DOCs)?

2.  Would English suffice for a DOC?  I would hope that any one language within 
the community would be acceptable for the DOC, and English would be the easiest 
language for American companies to use.

3.  If a member state does want a DOC in a language other than English, would 
they the English version immediately and then allow the manufacturer time to 
translate the DOC like a period of two months?

RoHS Directive 2011/65/EU becomes mandatory on 1 January 2013, so these 
questions are urgent.

Monrad Monsen
+1.303.272.9612

-


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>>

All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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formats), large files, etc.

Website: http://www.ieee-pses.org/
Instructions: http://listserv.ieee.org/request/user-guide.html
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Jim Bacher mailto:j.bac...@ieee.org>>
David Heald mailto:dhe...@gmail.com>>

-

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discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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For policy questions, send mail to:
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Re: [PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-28 Thread Peter_Kelleher
Some good questions there:

What language is 'required' is up to each member state to decide. Some may well 
accept English (as they have done for many years) but the new wording does 
offer them some additional flexibility. There are precedents for certain 
countries requesting localised DoCs.

The wording does say "shall be translated" rather than "shall be provided" or 
made available.

The timing of the "translation" or how it should be presented is not specified. 
These aspects may be dealt with in future guidance documents. E.g an updated 
Blue Guide or directive specific guide.

Unfortunately we cannot expect to see a revised Blue Guide before the new RoHS 
directive comes into force and I don't think the RoHS FAQ deals with these 
matters either.

Regards

Peter

-



-Original Message-
From: Monrad Monsen [monrad.mon...@oracle.com]
Sent: Wednesday, November 28, 2012 08:41 PM GMT Standard Time
To: emc-p...@ieee.org
Subject: Language Translations for EU Declarations of Conformity (DOCs)

RoHS Directive 2011/65/EU, Article 13 (EU Declaration of Conformity) section 2 
states:  "The EU declaration of conformity ... shall be translated into the 
language or languages required by the Member State on the market of which the 
product is placed or made available."

This raises some questions:
1.  What languages are required by the member states for translating 
declarations of conformity (DOCs)?

2.  Would English suffice for a DOC?  I would hope that any one language within 
the community would be acceptable for the DOC, and English would be the easiest 
language for American companies to use.

3.  If a member state does want a DOC in a language other than English, would 
they the English version immediately and then allow the manufacturer time to 
translate the DOC like a period of two months?

RoHS Directive 2011/65/EU becomes mandatory on 1 January 2013, so these 
questions are urgent.

Monrad Monsen
+1.303.272.9612
-


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 
>

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 >
Mike Cantwell >

For policy questions, send mail to:
Jim Bacher >
David Heald >

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
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All emc-pstc postings are archived and searchable on the web at:
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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:
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Mike Cantwell 

For policy questions, send mail to:
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[PSES] Language Translations for EU Declarations of Conformity (DOCs)

2012-11-28 Thread Monrad Monsen
RoHS Directive 2011/65/EU, Article 13 (EU Declaration of Conformity) 
section 2 states:  "The EU declaration of conformity ... shall be 
translated into the language or languages required by the Member State 
on the market of which the product is placed or made available."


This raises some questions:
1.  What languages are required by the member states for translating 
declarations of conformity (DOCs)?


2.  Would English suffice for a DOC?  I would hope that any one language 
within the community would be acceptable for the DOC, and English would 
be the easiest language for American companies to use.


3.  If a member state does want a DOC in a language other than English, 
would they the English version immediately and then allow the 
manufacturer time to translate the DOC like a period of two months?


RoHS Directive 2011/65/EU becomes mandatory on 1 January 2013, so these 
questions are urgent.


Monrad Monsen
+1.303.272.9612

-

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 

All emc-pstc postings are archived and searchable on the web at:
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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formats), large files, etc.

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List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
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