Re: [PSES] Product Declaration of Conformity with external PSU...

[Scott Xe]

Hi Matthew,

 

See below inline comments.

 

From: Matthew Wilson | GBE  
Sent: Wednesday, 10 April 2019 11:51 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Product Declaration of Conformity with external PSU...

 

A consumer product is powered by AA cells but also can derive its power from a 
'wall wart' mains-DC PSU via a DC jack input on the product. The client who is 
the manufacturer of the product (as per the EU directive) has decided to supply 
a third-party wall-wart PSU in the box with the product. The PSU does not carry 
the product manufacturer's logo but that of the PSU manufacturer (or possibly 
its importer/distributor assuming the responsibility of manufacturer because it 
will inevitably be made in Far East).

Scott: If the EPS is supplied together with the main unit, LVD is applicable.  
On main unit, add a marking “ Use only power supply x” as a best 
practice.



Should the product's EU Declaration of Conformity list the LVD directive? If so 
is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' 
PSU as a clause in the DoC? I've not ever seen that done but don't see why that 
couldn't be the case.



Scott: As power supply is part of unit, one DoC is sufficient to cover and you 
are the manufacturer/importer in the EU.  If outside EU, AR is required to 
include.


Should the product's EU Declaration of Conformity also list the 2009/125/EC 
Ecodesign directive in respect of the PSU implementing measures?



Scott: Yes, EPS falls into the product group of Eco-design regulation but no 
energy label required.  It is a common practice to use one DoC for all 
applicable harmonised directives/regulations.  You are accountable for the EPS 
so you have to ensure it is safe unless the EPS is sold separately.


Maybe there should be two Declarations of Conformity in the box? One for the 
product and one for the PSU, where the latter is a copy of the PSU 
manufacturer's DoC?

Any thoughts welcome thanks.

Regards all.











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​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.

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Re: [PSES] Product Declaration of Conformity with external PSU...

[Matthew Larkin]

Irrespective of the voltage the product needs to be safe. So the LVD may not apply but you still need to meet GPSD.
Best Regards 
Matthew


Sent from Knox Portal Mobile

- Original Message -
Sender : John Woodgate 
Date : 2019-04-10 20:54 (GMT+1)
Title : Re: [PSES] Product Declaration of Conformity with external PSU...


  

  
  

I still don't see why having a power supply in
the same box causes a battery-operated product to be subject to
the LVD. It just doesn't seem sufficient reason to justify the
cost of producing a test report form  that has about 1000 'not
applicable' entries.


I agree with you about having lower voltage
limits in the LVD being inappropriate, but I think there is a
case for retaining the limits that justify 'Low Voltage' being
in the title. It was probably OK to have lower voltage limits
when the first edition was being drafted but even at the time of
first publication we had products with lead-acid batteries on
board that could readily burn under fault conditions. Now we
have Li-ion, and maybe even more energetic batteries soon.



Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-04-10 20:15, Gert Gremmen
  wrote:



  
  
The message was also for the group, my mistake...

  

  
It depends,

  
If the product is sold with a manufacturer provided adapter,
then the product has a mains connection. -> LVD

  
(it is not because there is a connector between power supply
and equipment that it becomes safe)

  

  
If the product is sold without, it has only the ELV DC
connection. -> No LVD

  
LVD is about more than just insulation from the mains.

  
The whole concept of voltage limits in the LVD is wrong, the
idea that a device is inherently safe if supplied by 24 volts
(for example)  is evidently wrong; this is also why those limits
has been removed in the RED.

  

  
Gert

  

  On 10-4-2019 19:32, John Woodgate
wrote:

  
  


Hello, Gert. Did you mean to reply only to
me or to the mailing list? I don't understand your
reasoning. The product itself runs from ELV DC, so, even
though there is a power supply next to it in the box, 
surely the LVD doesn't apply? It does, of course, apply to
the power supply that is supplied with it.



Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-04-10 17:51, Gert Gremmen /
  Ce-test wrote:



  
  It depends..
  If the power supply is an inherent part of the product as
“put on the market” then the lvd should apply. If not, so
the customer is supposed to buy an adapter himself , then
the product is supposed to be a dc supplied product and if
this supply voltage is outside the limits for the lvd, such
as 5 or 12 voltDC , then the lvd does not apply
  

Gert

Verstuurd vanaf mijn
  iPhone


  Op 10 apr. 2019 om 18:03 heeft John Woodgate <j...@woodjohn.uk>
  het volgende geschreven:

  



  


I think:


Should the product's EU Declaration of Conformity
list the LVD directive? If so is it acceptable to
list 'LVD only with specific 'manufacturer ABC'
'model XYZ' PSU as a clause in the DoC? I've not
ever seen that done but don't see why that couldn't
be the case.


The product is outside the LVD.

  


Should the product's EU Declaration of Conformity
also list the 2009/125/EC Ecodesign directive in
respect of the PSU implementing measures?


The ECO Directive applies to the power supply, not
  the product.




Maybe there should be two Declarations of
Conformity in the box? One for the product and one
for the PSU, where the latter is a copy of the PSU
manufacturer's DoC?


It seems a logical solution, and I doubt that it is
  explicitly prohibited.



Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate an

Re: [PSES] Product Declaration of Conformity with external PSU...

[John Woodgate]

I still don't see why having a power supply in the same box causes a 
battery-operated product to be subject to the LVD. It just doesn't seem 
sufficient reason to justify the cost of producing a test report form  
that has about 1000 'not applicable' entries.


I agree with you about having lower voltage limits in the LVD being 
inappropriate, but I think there is a case for retaining the limits that 
justify 'Low Voltage' being in the title. It was probably OK to have 
lower voltage limits when the first edition was being drafted but even 
at the time of first publication we had products with lead-acid 
batteries on board that could readily burn under fault conditions. Now 
we have Li-ion, and maybe even more energetic batteries soon.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-04-10 20:15, Gert Gremmen wrote:


The message was also for the group, my mistake...

It depends,

If the product is sold with a manufacturer provided adapter, then the 
product has a mains connection. -> LVD


(it is not because there is a connector between power supply and 
equipment that it becomes safe)


If the product is sold without, it has only the ELV DC connection. -> 
No LVD


LVD is about more than just insulation from the mains.

The whole concept of voltage limits in the LVD is wrong, the idea that 
a device is inherently safe if supplied by 24 volts (for example)  is 
evidently wrong; this is also why those limits has been removed in the 
RED.


Gert

On 10-4-2019 19:32, John Woodgate wrote:


Hello, Gert. Did you mean to reply only to me or to the mailing list? 
I don't understand your reasoning. The product itself runs from ELV 
DC, so, even though there is a power supply next to it in the box, 
surely the LVD doesn't apply? It does, of course, apply to the power 
supply that is supplied with it.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-04-10 17:51, Gert Gremmen / Ce-test wrote:

It depends..
If the power supply is an inherent part of the product as “put on 
the market” then the lvd should apply. If not, so the customer is 
supposed to buy an adapter himself , then the product is supposed to 
be a dc supplied product and if this supply voltage is outside the 
limits for the lvd, such as 5 or 12 voltDC , then the lvd does not apply


Gert
Verstuurd vanaf mijn iPhone

Op 10 apr. 2019 om 18:03 heeft John Woodgate > het volgende geschreven:



I think:

/Should the product's EU Declaration of Conformity list the LVD 
directive? If so is it acceptable to list 'LVD only with specific 
'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not 
ever seen that done but don't see why that couldn't be the case./


The product is outside the LVD/.//
/

/Should the product's EU Declaration of Conformity also list the 
2009/125/EC Ecodesign directive in respect of the PSU implementing 
measures?/


The ECO Directive applies to the power supply, not the product.

/Maybe there should be two Declarations of Conformity in the box? 
One for the product and one for the PSU, where the latter is a copy 
of the PSU manufacturer's DoC?/


It seems a logical solution, and I doubt that it is explicitly 
prohibited.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-04-10 16:51, Matthew Wilson | GBE wrote:
A consumer product is powered by AA cells but also can derive its 
power from a 'wall wart' mains-DC PSU via a DC jack input on the 
product. The client who is the manufacturer of the product (as per 
the EU directive) has decided to supply a third-party wall-wart 
PSU in the box with the product. The PSU does not carry the 
product manufacturer's logo but that of the PSU manufacturer (or 
possibly its importer/distributor assuming the responsibility of 
manufacturer because it will inevitably be made in Far East).


Should the product's EU Declaration of Conformity list the LVD 
directive? If so is it acceptable to list 'LVD only with specific 
'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've 
not ever seen that done but don't see why that couldn't be the case.


Should the product's EU Declaration of Conformity also list the 
2009/125/EC Ecodesign directive in respect of the PSU implementing 
measures?


Maybe there should be two Declarations of Conformity in the box? 
One for the product and one for the PSU, where the latter is a 
copy of the PSU manufacturer's DoC?


Any thoughts welcome thanks.

Regards all.



Disclaimer:​This email and any files transmitted with it are 
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entity to whom they are addressed. If you have received this email 
in error please delete it from your system, do not use or disclose 
the information in any way and notify the sender immediately. The 
contents of this message 

Re: [PSES] Product Declaration of Conformity with external PSU...

[Gert Gremmen]

The message was also for the group, my mistake...

It depends,

If the product is sold with a manufacturer provided adapter, then the 
product has a mains connection. -> LVD


(it is not because there is a connector between power supply and 
equipment that it becomes safe)


If the product is sold without, it has only the ELV DC connection. -> No LVD

LVD is about more than just insulation from the mains.

The whole concept of voltage limits in the LVD is wrong, the idea that a 
device is inherently safe if supplied by 24 volts (for example)  is 
evidently wrong; this is also why those limits has been removed in the RED.


Gert

On 10-4-2019 19:32, John Woodgate wrote:


Hello, Gert. Did you mean to reply only to me or to the mailing list? 
I don't understand your reasoning. The product itself runs from ELV 
DC, so, even though there is a power supply next to it in the box,  
surely the LVD doesn't apply? It does, of course, apply to the power 
supply that is supplied with it.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-04-10 17:51, Gert Gremmen / Ce-test wrote:

It depends..
If the power supply is an inherent part of the product as “put on the 
market” then the lvd should apply. If not, so the customer is 
supposed to buy an adapter himself , then the product is supposed to 
be a dc supplied product and if this supply voltage is outside the 
limits for the lvd, such as 5 or 12 voltDC , then the lvd does not apply


Gert
Verstuurd vanaf mijn iPhone

Op 10 apr. 2019 om 18:03 heeft John Woodgate > het volgende geschreven:



I think:

/Should the product's EU Declaration of Conformity list the LVD 
directive? If so is it acceptable to list 'LVD only with specific 
'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not 
ever seen that done but don't see why that couldn't be the case./


The product is outside the LVD/.//
/

/Should the product's EU Declaration of Conformity also list the 
2009/125/EC Ecodesign directive in respect of the PSU implementing 
measures?/


The ECO Directive applies to the power supply, not the product.

/Maybe there should be two Declarations of Conformity in the box? 
One for the product and one for the PSU, where the latter is a copy 
of the PSU manufacturer's DoC?/


It seems a logical solution, and I doubt that it is explicitly 
prohibited.


Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2019-04-10 16:51, Matthew Wilson | GBE wrote:
A consumer product is powered by AA cells but also can derive its 
power from a 'wall wart' mains-DC PSU via a DC jack input on the 
product. The client who is the manufacturer of the product (as per 
the EU directive) has decided to supply a third-party wall-wart PSU 
in the box with the product. The PSU does not carry the product 
manufacturer's logo but that of the PSU manufacturer (or possibly 
its importer/distributor assuming the responsibility of 
manufacturer because it will inevitably be made in Far East).


Should the product's EU Declaration of Conformity list the LVD 
directive? If so is it acceptable to list 'LVD only with specific 
'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not 
ever seen that done but don't see why that couldn't be the case.


Should the product's EU Declaration of Conformity also list the 
2009/125/EC Ecodesign directive in respect of the PSU implementing 
measures?


Maybe there should be two Declarations of Conformity in the box? 
One for the product and one for the PSU, where the latter is a copy 
of the PSU manufacturer's DoC?


Any thoughts welcome thanks.

Regards all.



Disclaimer:​This email and any files transmitted with it are 
confidential and intended solely for the use of the individual or 
entity to whom they are addressed. If you have received this email 
in error please delete it from your system, do not use or disclose 
the information in any way and notify the sender immediately. The 
contents of this message may contain personal views which are not 
the views of the company, unless specifically stated.


​GB Electronics (UK) Ltd is a company registered in England and 
Wales under number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring 
By Sea, West Sussex, BN12 4QY.


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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: 

Re: [PSES] Product Declaration of Conformity with external PSU...

[John Woodgate]

I think:

/Should the product's EU Declaration of Conformity list the LVD 
directive? If so is it acceptable to list 'LVD only with specific 
'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever 
seen that done but don't see why that couldn't be the case./


The product is outside the LVD/.//
/

/Should the product's EU Declaration of Conformity also list the 
2009/125/EC Ecodesign directive in respect of the PSU implementing 
measures?/


The ECO Directive applies to the power supply, not the product.

/Maybe there should be two Declarations of Conformity in the box? One 
for the product and one for the PSU, where the latter is a copy of the 
PSU manufacturer's DoC?/


It seems a logical solution, and I doubt that it is explicitly prohibited.
//

Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2019-04-10 16:51, Matthew Wilson | GBE wrote:
A consumer product is powered by AA cells but also can derive its 
power from a 'wall wart' mains-DC PSU via a DC jack input on the 
product. The client who is the manufacturer of the product (as per the 
EU directive) has decided to supply a third-party wall-wart PSU in the 
box with the product. The PSU does not carry the product 
manufacturer's logo but that of the PSU manufacturer (or possibly its 
importer/distributor assuming the responsibility of manufacturer 
because it will inevitably be made in Far East).


Should the product's EU Declaration of Conformity list the LVD 
directive? If so is it acceptable to list 'LVD only with specific 
'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not 
ever seen that done but don't see why that couldn't be the case.


Should the product's EU Declaration of Conformity also list the 
2009/125/EC Ecodesign directive in respect of the PSU implementing 
measures?


Maybe there should be two Declarations of Conformity in the box? One 
for the product and one for the PSU, where the latter is a copy of the 
PSU manufacturer's DoC?


Any thoughts welcome thanks.

Regards all.


Disclaimer:​This email and any files transmitted with it are 
confidential and intended solely for the use of the individual or 
entity to whom they are addressed. If you have received this email in 
error please delete it from your system, do not use or disclose the 
information in any way and notify the sender immediately. The contents 
of this message may contain personal views which are not the views of 
the company, unless specifically stated.


​GB Electronics (UK) Ltd is a company registered in England and Wales 
under number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By 
Sea, West Sussex, BN12 4QY.


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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:
http://www.ieee-pses.org/emc-pstc.html

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formats), large files, etc.

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[PSES] Product Declaration of Conformity with external PSU...

[Matthew Wilson | GBE]

A consumer product is powered by AA cells but also can derive its power from a 
'wall wart' mains-DC PSU via a DC jack input on the product.  The client who is 
the manufacturer of the product (as per the EU directive) has decided to supply 
a third-party wall-wart PSU in the box with the product.  The PSU does not 
carry the product manufacturer's logo but that of the PSU manufacturer (or 
possibly its importer/distributor assuming the responsibility of manufacturer 
because it will inevitably be made in Far East).

Should the product's EU Declaration of Conformity list the LVD directive?  If 
so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model 
XYZ' PSU as a clause in the DoC?  I've not ever seen that done but don't see 
why that couldn't be the case.

Should the product's EU Declaration of Conformity also list the 2009/125/EC 
Ecodesign directive in respect of the PSU implementing measures?

Maybe there should be two Declarations of Conformity in the box? One for the 
product and one for the PSU, where the latter is a copy of the PSU 
manufacturer's DoC?

Any thoughts welcome thanks.

Regards all.



Matthew Wilson
Technical Director
GB Electronics (UK) Ltd
matthew.wil...@gbelectronics.com
https://gbelectronics.uk
+44 (0)1903 244 500
Ascot House//Mulberry Close//Woods Way
Goring-by-Sea//West Sussex//BN12 4QY//UK

Disclaimer: This email and any files transmitted with it are confidential and 
intended solely for the use of the individual or entity to whom they are 
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system, do not use or disclose the information in any way and notify the sender 
immediately. The contents of this message may contain personal views which are 
not the views of the company, unless specifically stated.
​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.

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


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