Re: [PSES] New EU Directives

2014-06-09 Thread Scott Xe
Hi Tony,

Thanks for useful info.  Highly recommended!

Noticeable changes are that all radio receivers including broadcast radio
and TV receivers now fall into RED.  TTE is now within the scope of the EMC
Directive and LVD.  The safety requirements set out in LVD with no voltage
limit applying...

Regards,

Scott

On 9/6/14 4:30 pm, "Anthony Thomson"  wrote:

>  
> Scott,
>  
> TUV have this free Webinar, it might be useful.
> http://www.tuv-sud.co.uk/uk-en/resource-centre/webinars/webinar-downloads
>  
> I can't comment because I haven't watched it yet, but I will do. Let me know
> if it's a 'must see'.
>  
> Regards,
> Tony
> Sent: Friday, June 06, 2014 at 4:20 PM From: "Scott Xe" 
> To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New EU Directives
> Thanks! What is the major impact on own brand labelers? Regards, Scott On
> 6/6/14 5:53 am, "T.Sato"  wrote: > On Fri, 6 Jun 2014
> 00:49:58 +0800, > Scott Xe  wrote: > >> Is there any
> reason behind to have LVD, EMC and R&TTE directives updated in >> similar
> time? > > To align them with NLF, all the new approach directives which were >
> not aligned with NLF were/will be updated even if no other changes > were
> necessary. > > For some directives such as R&TTED (RED), other significant
> changes > were also made. > > NLF itself have big impact, and I guess own
> brand labelers who supplied > completed product from OEMs may have hard time.
> > > Regards, > Tom > > - >
>  > This
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Re: [PSES] New EU Directives

2014-06-09 Thread Michael Derby
Hello,

Yes, the RED is just like the R&TTED in that sense.

Presently:   If a device has a radio in it (such as a laptop with WiFi, or
other digital device with Bluetooth, etc.), then the R&TTE Directive applies
to that device.   The R&TTE Directive includes EMC and Safety, so the EMC
and Safety (LV) Directives do not apply to that device.

Similarly with the RED, it includes EMC and Safety, so the EMC Directive and
the Safety Directive will continue not to apply to radio products.

However, the EMC and Safety requirements within the R&TTE and RE Directives
are equivalent to the requirements of the EMC and Safety Directives, with a
few noteworthy exceptions.   (For example, there is no minimum voltage limit
for radio equipment, so all battery powered equipment would need a safety
assessment)


Michael.


Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: 09 June 2014 10:07
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New EU Directives

In message <20af01cf83c0$8988ff10$9c9afd30$@acbcert.com>, dated Mon, 9 Jun
2014, Michael Derby  writes:

>
>"When deemed appropriate with regard to the risks presented by radio 
>equipment, importers shall, to protect the health and safety of 
>end-users,

So the RED, unlike the EMCD, includes provisions for electrical safety?
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk Quid
faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] New EU Directives

2014-06-09 Thread John Woodgate
In message <20af01cf83c0$8988ff10$9c9afd30$@acbcert.com>, dated Mon, 9 
Jun 2014, Michael Derby  writes:




"When deemed appropriate with regard to the risks presented by radio 
equipment, importers shall, to protect the health and safety of 
end-users,


So the RED, unlike the EMCD, includes provisions for electrical safety?
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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Re: [PSES] New EU Directives

2014-06-09 Thread Michael Derby
Hi Scott,

I think that two important points to consider for anyone re-branding a
product is this:

The new Radio Equipment Directive states:

"The manufacturer, having detailed knowledge of the design and production
process, is best placed to carry out the conformity assessment procedure.
Conformity assessment should therefore remain solely the obligation of the
manufacturer. "

It then states:

"Any economic operator that either places radio equipment on the market
under his own name or trade mark or modifies radio equipment in such a way
that compliance with this Directive may be affected should be considered to
be the manufacturer and should assume the obligations of the manufacturer. "


The Directive effectively also states that any importer who has concerns
about the compliance of the device they import, should get it tested.

"When deemed appropriate with regard to the risks presented by radio
equipment, importers shall, to protect the health and safety of end-users,
carry out sample testing of radio equipment made available on the market,
investigate, and, if necessary, keep a register of complaints, of
non-conforming radio equipment and radio equipment recalls, and shall keep
distributors informed of any such monitoring.

Importers who consider or have reason to believe that radio equipment which
they have placed on the market is not in conformity with this Directive
shall immediately take the corrective measures necessary to bring that radio
equipment into conformity, to withdraw it or recall it, if appropriate.
Furthermore, where the radio equipment presents a risk, importers shall
immediately inform the competent national authorities of the Member  states
in which they made the radio equipment available on the market to that
effect, giving details, in particular, of the non-compliance and of any
corrective measures taken. "


Thanks,   Michael.



Michael Derby
Regulatory Engineer
ACB Europe


-Original Message-
From: Scott Xe [mailto:scott...@gmail.com] 
Sent: 06 June 2014 16:20
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New EU Directives

Thanks!  What is the major impact on own brand labelers?

Regards,

Scott


On 6/6/14 5:53 am, "T.Sato"  wrote:

> On Fri, 6 Jun 2014 00:49:58 +0800,
>   Scott Xe  wrote:
> 
>> Is there any reason behind to have LVD, EMC and R&TTE directives 
>> updated in similar time?
> 
> To align them with NLF, all the new approach directives which were not 
> aligned with NLF were/will be updated even if no other changes were 
> necessary.
> 
> For some directives such as R&TTED (RED), other significant changes 
> were also made.
> 
> NLF itself have big impact, and I guess own brand labelers who 
> supplied completed product from OEMs may have hard time.
> 
> Regards,
> Tom
> 
> -
> 
> 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

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Re: [PSES] New EU Directives

2014-06-09 Thread Anthony Thomson
 

Scott,

 

TUV have this free Webinar, it might be useful.

http://www.tuv-sud.co.uk/uk-en/resource-centre/webinars/webinar-downloads

 

I can't comment because I haven't watched it yet, but I will do. Let me know if it's a 'must see'.

 

Regards,

Tony


Sent: Friday, June 06, 2014 at 4:20 PM
From: "Scott Xe" 
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] New EU Directives

Thanks! What is the major impact on own brand labelers?

Regards,

Scott


On 6/6/14 5:53 am, "T.Sato"  wrote:

> On Fri, 6 Jun 2014 00:49:58 +0800,
> Scott Xe  wrote:
>
>> Is there any reason behind to have LVD, EMC and R&TTE directives updated in
>> similar time?
>
> To align them with NLF, all the new approach directives which were
> not aligned with NLF were/will be updated even if no other changes
> were necessary.
>
> For some directives such as R&TTED (RED), other significant changes
> were also made.
>
> NLF itself have big impact, and I guess own brand labelers who supplied
> completed product from OEMs may have hard time.
>
> Regards,
> Tom
>
> -
> 
> 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

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Re: [PSES] New EU Directives

2014-06-06 Thread Scott Xe
The NLF requires the importer and/or manufacturer name and address on the
product.  It is effective for the market surveillance to track the
responsible party rather than previous trade name/mark that must be
registered in EU.  In terms of responsibility, the local importer still
holds the legal responsibility as before.  I am in doubt that the market
surveillance will trace the manufactures who most are located in Far East or
overseas.

Regards,

Scott


On 7/6/14 6:08 am, "T.Sato"  wrote:

> On Fri, 06 Jun 2014 23:20:06 +0800,
>   Scott Xe  wrote:
> 
>> Thanks!  What is the major impact on own brand labelers?
> 
> NLF directives such as 2014/30/EU defines "manufacturer" as
> "any natural or legal person who manufactures apparatus or
> **has apparatus designed or manufactured, and markets that apparatus
> under his name or trade mark** ;"
> 
> The new Blue Guide has some additional explanation on this:
> "The manufacturer may design and manufacture the product himself.
> As an alternative, he may have it designed, manufactured, assembled,
> packed, processed or labelled with a view to placing it on the market
> under his own name or trademark, and thus presenting himself as a
> manufacturer (footnote 78).
> ...
> (footnote 78) Those manufacturers are often referred to as 'own brand
> labellers' or 'private labellers'."
> 
> 
> So, I think they will be required to take all the responsibility as
> the manufacturer.
> 
> Regards,
> Tom

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Re: [PSES] New EU Directives

2014-06-06 Thread T.Sato
On Fri, 06 Jun 2014 23:20:06 +0800,
  Scott Xe  wrote:

> Thanks!  What is the major impact on own brand labelers?

NLF directives such as 2014/30/EU defines "manufacturer" as
"any natural or legal person who manufactures apparatus or
**has apparatus designed or manufactured, and markets that apparatus
under his name or trade mark** ;"

The new Blue Guide has some additional explanation on this:
"The manufacturer may design and manufacture the product himself.
As an alternative, he may have it designed, manufactured, assembled,
packed, processed or labelled with a view to placing it on the market
under his own name or trademark, and thus presenting himself as a
manufacturer (footnote 78).
...
(footnote 78) Those manufacturers are often referred to as 'own brand
labellers' or 'private labellers'."


So, I think they will be required to take all the responsibility as
the manufacturer.

Regards,
Tom

-- 
Tomonori Sato  
URL: http://homepage3.nifty.com/tsato/

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Re: [PSES] New EU Directives

2014-06-06 Thread John Woodgate
In message , dated Fri, 6 Jun 2014, 
Scott Xe  writes:



Thanks!  What is the major impact on own brand labelers?


Either the original manufacturer's name and address must be on the 
product label or the own-brand company has to accept the full 
responsibility as if it were the manufacturer (at least, I think that 
would work, but it's not very clear). In either case, its name and 
address must also be on the product label.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] New EU Directives

2014-06-06 Thread Scott Xe
Yes, we need to study the new RED and its impact.

Thanks and regards,

Scott


On 6/6/14 1:27 am, "John Woodgate"  wrote:

> In message , dated Fri, 6 Jun 2014,
> Scott Xe  writes:
> 
>> Is there any reason behind to have LVD, EMC and R&TTE directives
>> updated in similar time? On R&TTE, the changes are quite significant.
> 
> There are more than those being updated. This is for complicated legal
> reasons, and in some cases the Commission has found that the Directives
> were not effective in keeping non-compliant products out of the EU.
> 
> But the change to the RTTED is special. Its scope was found to need
> revising because it included some products that it shouldn't, but
> excluded some products, such as broadcast receivers, that it should
> include.

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Re: [PSES] New EU Directives

2014-06-06 Thread Scott Xe
Thanks!  What is the major impact on own brand labelers?

Regards,

Scott


On 6/6/14 5:53 am, "T.Sato"  wrote:

> On Fri, 6 Jun 2014 00:49:58 +0800,
>   Scott Xe  wrote:
> 
>> Is there any reason behind to have LVD, EMC and R&TTE directives updated in
>> similar time?
> 
> To align them with NLF, all the new approach directives which were
> not aligned with NLF were/will be updated even if no other changes
> were necessary.
> 
> For some directives such as R&TTED (RED), other significant changes
> were also made.
> 
> NLF itself have big impact, and I guess own brand labelers who supplied
> completed product from OEMs may have hard time.
> 
> Regards,
> Tom
> 
> -
> 
> 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

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Re: [PSES] New EU Directives

2014-06-05 Thread T.Sato
On Fri, 6 Jun 2014 00:49:58 +0800,
  Scott Xe  wrote:

> Is there any reason behind to have LVD, EMC and R&TTE directives updated in
> similar time?

To align them with NLF, all the new approach directives which were
not aligned with NLF were/will be updated even if no other changes
were necessary.

For some directives such as R&TTED (RED), other significant changes
were also made.

NLF itself have big impact, and I guess own brand labelers who supplied
completed product from OEMs may have hard time.

Regards,
Tom

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Re: [PSES] New EU Directives

2014-06-05 Thread John Woodgate
In message , dated Fri, 6 Jun 2014, 
Scott Xe  writes:


Is there any reason behind to have LVD, EMC and R&TTE directives 
updated in similar time? On R&TTE, the changes are quite significant.


There are more than those being updated. This is for complicated legal 
reasons, and in some cases the Commission has found that the Directives 
were not effective in keeping non-compliant products out of the EU.


But the change to the RTTED is special. Its scope was found to need 
revising because it included some products that it shouldn't, but 
excluded some products, such as broadcast receivers, that it should 
include.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] New EU Directives

2014-06-05 Thread Scott Xe
Is there any reason behind to have LVD, EMC and R&TTE directives updated in
similar time? On R&TTE, the changes are quite significant.

Thanks and regards,

Scott


On 27/5/14 5:08 pm, "Michael Derby"  wrote:

> The EMC and LV Directives are Œre-casts¹, so there should not be much in the
> way of technical changes.
>  
> For the R&TTE Directive, that is being phased out and replaced with the Radio
> Equipment Directive which was published last week.
> There should be plenty of changes for radio products, including:
> · Which devices are in or out of scope.
> 
> · Frequency range applicable.
> 
> · Assessment procedure and use of Notified Bodies.
> 
> · Notified Body actions and responsibilities.
> 
> · Labelling and user manuals.
> 
> · Declaration of Conformity.
> 
> · Responsible parties.
> 
> · Market surveillance.
> 
> · Process for Class 2 devices.
> 
>  
> Š.to name but a few.
>  
>  
> Michael.
>  
> 
>  
> Michael Derby
> Regulatory Engineer
> ACB Europe
>  
> 
> From: Jim Hulbert [mailto:jim.hulb...@pb.com]
> Sent: 23 May 2014 18:24
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] New EU Directives
>  
> I will of course investigate on my own.  But is anything shockingly changed in
> the new EMC, LVD, and RTTE Directives?  Or for most of us will it simply mean
> updating our Declarations of Conformity?
>  
> Jim Hulbert
> Pitney Bowes
>  
>  
> 
> 
>  
> -
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc
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> -
> 
> 
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> 
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Re: [PSES] New EU Directives

2014-05-27 Thread Michael Derby
The EMC and LV Directives are 're-casts', so there should not be much in the
way of technical changes.

 

For the R&TTE Directive, that is being phased out and replaced with the
Radio Equipment Directive which was published last week.

There should be plenty of changes for radio products, including:

. Which devices are in or out of scope.

. Frequency range applicable.

. Assessment procedure and use of Notified Bodies.

. Notified Body actions and responsibilities.

. Labelling and user manuals.

. Declaration of Conformity.

. Responsible parties.

. Market surveillance.

. Process for Class 2 devices.

 

..to name but a few.

 

 

Michael.

 

 

Michael Derby

Regulatory Engineer

ACB Europe

 

From: Jim Hulbert [mailto:jim.hulb...@pb.com] 
Sent: 23 May 2014 18:24
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] New EU Directives

 

I will of course investigate on my own.  But is anything shockingly changed
in the new EMC, LVD, and RTTE Directives?  Or for most of us will it simply
mean updating our Declarations of Conformity?

 

Jim Hulbert

Pitney Bowes

 

 

  _  

 

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Re: [PSES] New EU Directives

2014-05-23 Thread John Woodgate
In message 
<7B9D892F88F070469771832D78B3086E282CFB68@013-BR1MPN1-011.MGDPBI.global.p

vt>, dated Fri, 23 May 2014, Jim Hulbert  writes:

I will of course investigate on my own.  But is anything shockingly 
changed in the new EMC, LVD, and RTTE Directives? 


Depends what you are doing. For EMC and LVD, the products should be OK, 
but what you may do with them has changed. You need to do your homework, 
as you say.


Or for most of us will it simply mean updating our Declarations of 
Conformity?


No, it's not limited to that, in fact for EMC the new Directive aliases 
old DoCs that cite the previous Directive so as to be valid under the 
new one. You need to look at labelling, and if you export to EU, your 
importers ALSO need to look at labelling.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Nondum ex silvis sumus
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] New EU Directives

2014-05-23 Thread Jim Hulbert
I will of course investigate on my own.  But is anything shockingly changed in 
the new EMC, LVD, and RTTE Directives?  Or for most of us will it simply mean 
updating our Declarations of Conformity?

Jim Hulbert
Pitney Bowes





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