Re: [PSES] EU DoC on Thumb Drive?
Thanks to all for your responses. They are very helpful. Best regards, Carl On 5/14/2021 4:54 PM, Richard Nute wrote: The symbol ISO 7000-3500 "Electronic instructions for use" is for medical equipment. The related EU regulation is: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:072:0028:0031:EN:PDF <https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:072:0028:0031:EN:PDF> This regulation specifies, among other requirements, “exclusive use by professional users” and requires a risk assessment. If your equipment is not medical equipment, you cannot (or should not) use the symbol. I know of no regulation that prohibits electronic instructions, but standards and regulations specify statements which are traditionally printed on paper and which must accompany the equipment. Stay safe, and best regards, Rich *From:*Chuck August-McDowell *Sent:* Friday, May 14, 2021 11:42 AM *To:* EMC-PSTC@LISTSERV.IEEE.ORG *Subject:* Re: [PSES] EU DoC on Thumb Drive? Seconding Brian’s motion to allow the QR Code as an approved method to provide DoC information. We recently Include Symbol ISO 7000-3500 "Electronic instructions for use" and the QR Code in the Symbol table in the basic safety information provided on paper with each product. Currently provide paper DoC also. Symbol ISO 7000-3500 Function/description : To indicate on product or product packaging that relevant information for use of the product is available in electronic form rather than, or in addition to, printed paper form. Link https://www.iso.org/obp/ui#iso:grs:7000:3500 <https://www.iso.org/obp/ui#iso:grs:7000:3500> Respectfully, Chuck August-McDowell *From:*Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org <mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org>> *Sent:* Friday, May 14, 2021 10:51 AM *To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> *Subject:* Re: [PSES] EU DoC on Thumb Drive? [EXTERNAL EMAIL] Brian, This is another method that needs to be on the list of accepted paths to show compliance, in my opinion. Of course, the acceptance for any such methods need to come from the Euro Commission, meeting Euro legal requirements and having the buy-in of all the interested parties – such as the Customs Officers who are charged with either clearing or refusing entry to CE marked items and are looking for further justification (MDoC in particular). I see this as a long slog to get anywhere unless some very influential group that the EU folks admire takes it on with a passion. Do you know anyone at the WTO? I guess, if your company is gutsy enough you can try it and see how it goes; sometimes changes are made in fact and later the paperwork catches up. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 1067 Albany, ORe 97321-0413 503/452-1201 IEEE Life Fellow IEEE PSES 2020 Distinguished Lecturer www.researchgate.net <http://www.researchgate.net/Peter%20Perkins>search my name p.perk...@ieee.org <mailto:p.perk...@ieee.org> Entropy ain’t what it used to be *From:*Brian Ceresney <mailto:bceres...@delta-q.com>> *Sent:* Friday, May 14, 2021 10:40 AM *To:* Pete Perkins mailto:peperkin...@cs.com>>; EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> *Subject:* RE: [PSES] EU DoC on Thumb Drive? Hello All, Apologies for “hijacking the thread”, but we’ve been considering the now-ubiquitous(post pandemic) QR Code as a method of delivering information about the product – user manual, declarations for the EU, MC documentation, etc. A small accessible code label could really help make information accessible to the customer, using the cell phone. Does this also still fall under the “not-yet” category? Best Regards, Brian C. *From:*Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org <mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org>> *Sent:* Friday, May 14, 2021 10:34 AM *To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> *Subject:* Re: [PSES] EU DoC on Thumb Drive? CAUTION:This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Carl et al, This question has been asked before and the official answer seems to still be ‘not yet’. Some folks in the IEEE PSES TAC/ITE interest group have been working to put together a draft proposal that would allow digital documentation (thumb drive or even website) to meet the requirements. As noted, there are many interests in this way outside our usual working circle. Nothing has developed from this yet; maybe sometime in the future. Keep your hopes up though; pie in the sky is what keeps us going some time. :
Re: [PSES] EU DoC on Thumb Drive?
The symbol ISO 7000-3500 "Electronic instructions for use" is for medical equipment. The related EU regulation is: https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2012:072:0028:0031:EN:PDF This regulation specifies, among other requirements, “exclusive use by professional users” and requires a risk assessment. If your equipment is not medical equipment, you cannot (or should not) use the symbol. I know of no regulation that prohibits electronic instructions, but standards and regulations specify statements which are traditionally printed on paper and which must accompany the equipment. Stay safe, and best regards, Rich From: Chuck August-McDowell Sent: Friday, May 14, 2021 11:42 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU DoC on Thumb Drive? Seconding Brian’s motion to allow the QR Code as an approved method to provide DoC information. We recently Include Symbol ISO 7000-3500 "Electronic instructions for use" and the QR Code in the Symbol table in the basic safety information provided on paper with each product. Currently provide paper DoC also. Symbol ISO 7000-3500 Function/description : To indicate on product or product packaging that relevant information for use of the product is available in electronic form rather than, or in addition to, printed paper form. Link <https://www.iso.org/obp/ui#iso:grs:7000:3500> https://www.iso.org/obp/ui#iso:grs:7000:3500 Respectfully, Chuck August-McDowell From: Pete Perkins < <mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org> 0061f3f32d0c-dmarc-requ...@listserv.ieee.org> Sent: Friday, May 14, 2021 10:51 AM To: <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU DoC on Thumb Drive? [EXTERNAL EMAIL] Brian,This is another method that needs to be on the list of accepted paths to show compliance, in my opinion. Of course, the acceptance for any such methods need to come from the Euro Commission, meeting Euro legal requirements and having the buy-in of all the interested parties – such as the Customs Officers who are charged with either clearing or refusing entry to CE marked items and are looking for further justification (MDoC in particular). I see this as a long slog to get anywhere unless some very influential group that the EU folks admire takes it on with a passion. Do you know anyone at the WTO? I guess, if your company is gutsy enough you can try it and see how it goes; sometimes changes are made in fact and later the paperwork catches up. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 1067 Albany, ORe 97321-0413 503/452-1201 IEEE Life Fellow IEEE PSES 2020 Distinguished Lecturer <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my name <mailto:p.perk...@ieee.org> p.perk...@ieee.org Entropy ain’t what it used to be From: Brian Ceresney < <mailto:bceres...@delta-q.com> bceres...@delta-q.com> Sent: Friday, May 14, 2021 10:40 AM To: Pete Perkins < <mailto:peperkin...@cs.com> peperkin...@cs.com>; <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EU DoC on Thumb Drive? Hello All, Apologies for “hijacking the thread”, but we’ve been considering the now-ubiquitous(post pandemic) QR Code as a method of delivering information about the product – user manual, declarations for the EU, MC documentation, etc. A small accessible code label could really help make information accessible to the customer, using the cell phone. Does this also still fall under the “not-yet” category? Best Regards, Brian C. From: Pete Perkins < <mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org> 0061f3f32d0c-dmarc-requ...@listserv.ieee.org> Sent: Friday, May 14, 2021 10:34 AM To: <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU DoC on Thumb Drive? CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Carl et al, This question has been asked before and the official answer seems to still be ‘not yet’. Some folks in the IEEE PSES TAC/ITE interest group have been working to put together a draft proposal that would allow digital documentation (thumb drive or even website) to meet the requirements. As noted, there are many interests in this way outside our usual working circle. Nothing has developed from this yet; maybe sometime in the future. Keep your hopes up though; pie in the sky is what keeps us going some time. :>) br,
Re: [PSES] EU DoC on Thumb Drive?
Seconding Brian’s motion to allow the QR Code as an approved method to provide DoC information. We recently Include Symbol ISO 7000-3500 "Electronic instructions for use" and the QR Code in the Symbol table in the basic safety information provided on paper with each product. Currently provide paper DoC also. Symbol ISO 7000-3500 Function/description : To indicate on product or product packaging that relevant information for use of the product is available in electronic form rather than, or in addition to, printed paper form. Link https://www.iso.org/obp/ui#iso:grs:7000:3500 Respectfully, Chuck August-McDowell From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org> Sent: Friday, May 14, 2021 10:51 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU DoC on Thumb Drive? [EXTERNAL EMAIL] Brian,This is another method that needs to be on the list of accepted paths to show compliance, in my opinion. Of course, the acceptance for any such methods need to come from the Euro Commission, meeting Euro legal requirements and having the buy-in of all the interested parties – such as the Customs Officers who are charged with either clearing or refusing entry to CE marked items and are looking for further justification (MDoC in particular). I see this as a long slog to get anywhere unless some very influential group that the EU folks admire takes it on with a passion. Do you know anyone at the WTO? I guess, if your company is gutsy enough you can try it and see how it goes; sometimes changes are made in fact and later the paperwork catches up. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 1067 Albany, ORe 97321-0413 503/452-1201 IEEE Life Fellow IEEE PSES 2020 Distinguished Lecturer www.researchgate.net<http://www.researchgate.net/Peter%20Perkins> search my name p.perk...@ieee.org<mailto:p.perk...@ieee.org> Entropy ain’t what it used to be From: Brian Ceresney mailto:bceres...@delta-q.com>> Sent: Friday, May 14, 2021 10:40 AM To: Pete Perkins mailto:peperkin...@cs.com>>; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: RE: [PSES] EU DoC on Thumb Drive? Hello All, Apologies for “hijacking the thread”, but we’ve been considering the now-ubiquitous(post pandemic) QR Code as a method of delivering information about the product – user manual, declarations for the EU, MC documentation, etc. A small accessible code label could really help make information accessible to the customer, using the cell phone. Does this also still fall under the “not-yet” category? Best Regards, Brian C. From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org<mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org>> Sent: Friday, May 14, 2021 10:34 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] EU DoC on Thumb Drive? CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Carl et al, This question has been asked before and the official answer seems to still be ‘not yet’. Some folks in the IEEE PSES TAC/ITE interest group have been working to put together a draft proposal that would allow digital documentation (thumb drive or even website) to meet the requirements. As noted, there are many interests in this way outside our usual working circle. Nothing has developed from this yet; maybe sometime in the future. Keep your hopes up though; pie in the sky is what keeps us going some time. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 1067 Albany, ORe 97321-0413 503/452-1201 IEEE Life Fellow IEEE PSES 2020 Distinguished Lecturer www.researchgate.net<http://www.researchgate.net/Peter%20Perkins> search my name p.perk...@ieee.org<mailto:p.perk...@ieee.org> Entropy ain’t what it used to be From: Charlie Blackham mailto:char...@sulisconsultants.com>> Sent: Friday, May 14, 2021 1:17 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] EU DoC on Thumb Drive? Carl A number of other Directives such as RED and Machinery also require DoC to be provided with equipment In the absence of Guidance that says you can provide it electronically it is best to work on the basis that you must not – Customs / Market enforcement will expect to be able to find the DoC if they inspect the product, and if it’s not in print format they won’t be able to as they’re not going to load up a CD or USB stick, and you will be considered to be shipping “non-compliant” product Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https:/
Re: [PSES] EU DoC on Thumb Drive?
Brian,This is another method that needs to be on the list of accepted paths to show compliance, in my opinion. Of course, the acceptance for any such methods need to come from the Euro Commission, meeting Euro legal requirements and having the buy-in of all the interested parties – such as the Customs Officers who are charged with either clearing or refusing entry to CE marked items and are looking for further justification (MDoC in particular). I see this as a long slog to get anywhere unless some very influential group that the EU folks admire takes it on with a passion. Do you know anyone at the WTO? I guess, if your company is gutsy enough you can try it and see how it goes; sometimes changes are made in fact and later the paperwork catches up. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 1067 Albany, ORe 97321-0413 503/452-1201 IEEE Life Fellow IEEE PSES 2020 Distinguished Lecturer <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my name <mailto:p.perk...@ieee.org> p.perk...@ieee.org Entropy ain’t what it used to be From: Brian Ceresney Sent: Friday, May 14, 2021 10:40 AM To: Pete Perkins ; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EU DoC on Thumb Drive? Hello All, Apologies for “hijacking the thread”, but we’ve been considering the now-ubiquitous(post pandemic) QR Code as a method of delivering information about the product – user manual, declarations for the EU, MC documentation, etc. A small accessible code label could really help make information accessible to the customer, using the cell phone. Does this also still fall under the “not-yet” category? Best Regards, Brian C. From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org <mailto:0061f3f32d0c-dmarc-requ...@listserv.ieee.org> > Sent: Friday, May 14, 2021 10:34 AM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] EU DoC on Thumb Drive? CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Carl et al, This question has been asked before and the official answer seems to still be ‘not yet’. Some folks in the IEEE PSES TAC/ITE interest group have been working to put together a draft proposal that would allow digital documentation (thumb drive or even website) to meet the requirements. As noted, there are many interests in this way outside our usual working circle. Nothing has developed from this yet; maybe sometime in the future. Keep your hopes up though; pie in the sky is what keeps us going some time. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 1067 Albany, ORe 97321-0413 503/452-1201 IEEE Life Fellow IEEE PSES 2020 Distinguished Lecturer <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my name <mailto:p.perk...@ieee.org> p.perk...@ieee.org Entropy ain’t what it used to be From: Charlie Blackham mailto:char...@sulisconsultants.com> > Sent: Friday, May 14, 2021 1:17 AM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] EU DoC on Thumb Drive? Carl A number of other Directives such as RED and Machinery also require DoC to be provided with equipment In the absence of Guidance that says you can provide it electronically it is best to work on the basis that you must not – Customs / Market enforcement will expect to be able to find the DoC if they inspect the product, and if it’s not in print format they won’t be able to as they’re not going to load up a CD or USB stick, and you will be considered to be shipping “non-compliant” product Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Carl Newton mailto:emcl...@gmail.com> > Sent: 13 May 2021 20:36 To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] EU DoC on Thumb Drive? Group, I've not been able to find anything that suggests that the EU DoC can be provided with the product electronically for a medical device. I sent an inquiry to the commission and received no response. The MDD and MDR require that the DoC is shipped with each product and I have a customer that would like to include it on a thumb drive document package that will ship with the device rather than a paper hard-copy. Do any of you have experience with this question that you can share? Thanks in advance, Carl - --
Re: [PSES] EU DoC on Thumb Drive?
Hello All, Apologies for “hijacking the thread”, but we’ve been considering the now-ubiquitous(post pandemic) QR Code as a method of delivering information about the product – user manual, declarations for the EU, MC documentation, etc. A small accessible code label could really help make information accessible to the customer, using the cell phone. Does this also still fall under the “not-yet” category? Best Regards, Brian C. From: Pete Perkins <0061f3f32d0c-dmarc-requ...@listserv.ieee.org> Sent: Friday, May 14, 2021 10:34 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU DoC on Thumb Drive? CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe. Carl et al, This question has been asked before and the official answer seems to still be ‘not yet’. Some folks in the IEEE PSES TAC/ITE interest group have been working to put together a draft proposal that would allow digital documentation (thumb drive or even website) to meet the requirements. As noted, there are many interests in this way outside our usual working circle. Nothing has developed from this yet; maybe sometime in the future. Keep your hopes up though; pie in the sky is what keeps us going some time. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 1067 Albany, ORe 97321-0413 503/452-1201 IEEE Life Fellow IEEE PSES 2020 Distinguished Lecturer www.researchgate.net<http://www.researchgate.net/Peter%20Perkins> search my name p.perk...@ieee.org<mailto:p.perk...@ieee.org> Entropy ain’t what it used to be From: Charlie Blackham mailto:char...@sulisconsultants.com>> Sent: Friday, May 14, 2021 1:17 AM To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: Re: [PSES] EU DoC on Thumb Drive? Carl A number of other Directives such as RED and Machinery also require DoC to be provided with equipment In the absence of Guidance that says you can provide it electronically it is best to work on the basis that you must not – Customs / Market enforcement will expect to be able to find the DoC if they inspect the product, and if it’s not in print format they won’t be able to as they’re not going to load up a CD or USB stick, and you will be considered to be shipping “non-compliant” product Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Carl Newton mailto:emcl...@gmail.com>> Sent: 13 May 2021 20:36 To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] EU DoC on Thumb Drive? Group, I've not been able to find anything that suggests that the EU DoC can be provided with the product electronically for a medical device. I sent an inquiry to the commission and received no response. The MDD and MDR require that the DoC is shipped with each product and I have a customer that would like to include it on a thumb drive document package that will ship with the device rather than a paper hard-copy. Do any of you have experience with this question that you can share? Thanks in advance, Carl - 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://www.ieee-pses.org/list.html (including how to unsubscribe)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> 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>> - 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://www.ieee-pses.org/lis
Re: [PSES] EU DoC on Thumb Drive?
Carl et al, This question has been asked before and the official answer seems to still be ‘not yet’. Some folks in the IEEE PSES TAC/ITE interest group have been working to put together a draft proposal that would allow digital documentation (thumb drive or even website) to meet the requirements. As noted, there are many interests in this way outside our usual working circle. Nothing has developed from this yet; maybe sometime in the future. Keep your hopes up though; pie in the sky is what keeps us going some time. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 1067 Albany, ORe 97321-0413 503/452-1201 IEEE Life Fellow IEEE PSES 2020 Distinguished Lecturer <http://www.researchgate.net/Peter%20Perkins> www.researchgate.net search my name <mailto:p.perk...@ieee.org> p.perk...@ieee.org Entropy ain’t what it used to be From: Charlie Blackham Sent: Friday, May 14, 2021 1:17 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU DoC on Thumb Drive? Carl A number of other Directives such as RED and Machinery also require DoC to be provided with equipment In the absence of Guidance that says you can provide it electronically it is best to work on the basis that you must not – Customs / Market enforcement will expect to be able to find the DoC if they inspect the product, and if it’s not in print format they won’t be able to as they’re not going to load up a CD or USB stick, and you will be considered to be shipping “non-compliant” product Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Carl Newton mailto:emcl...@gmail.com> > Sent: 13 May 2021 20:36 To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] EU DoC on Thumb Drive? Group, I've not been able to find anything that suggests that the EU DoC can be provided with the product electronically for a medical device. I sent an inquiry to the commission and received no response. The MDD and MDR require that the DoC is shipped with each product and I have a customer that would like to include it on a thumb drive document package that will ship with the device rather than a paper hard-copy. Do any of you have experience with this question that you can share? Thanks in advance, Carl - 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://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org> > 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> > - 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://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org> > 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> > - 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 On
Re: [PSES] EU DoC on Thumb Drive?
Carl A number of other Directives such as RED and Machinery also require DoC to be provided with equipment In the absence of Guidance that says you can provide it electronically it is best to work on the basis that you must not – Customs / Market enforcement will expect to be able to find the DoC if they inspect the product, and if it’s not in print format they won’t be able to as they’re not going to load up a CD or USB stick, and you will be considered to be shipping “non-compliant” product Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Carl Newton Sent: 13 May 2021 20:36 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] EU DoC on Thumb Drive? Group, I've not been able to find anything that suggests that the EU DoC can be provided with the product electronically for a medical device. I sent an inquiry to the commission and received no response. The MDD and MDR require that the DoC is shipped with each product and I have a customer that would like to include it on a thumb drive document package that will ship with the device rather than a paper hard-copy. Do any of you have experience with this question that you can share? Thanks in advance, Carl - 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://www.ieee-pses.org/list.html (including how to unsubscribe)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> 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>> - 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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] EU DoC on Thumb Drive?
Group, I've not been able to find anything that suggests that the EU DoC can be provided with the product electronically for a medical device. I sent an inquiry to the commission and received no response. The MDD and MDR require that the DoC is shipped with each product and I have a customer that would like to include it on a thumb drive document package that will ship with the device rather than a paper hard-copy. Do any of you have experience with this question that you can share? Thanks in advance, Carl - 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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:
Re: [PSES] EU-DoC - list of applied standards with full title
I think this all begs the question, has anyone experienced any problems with their EU DOC by not providing the Standard's Title? If so, what was the objection and what was necessary to resolve it? The official titles of directives and standards are often way too long and often more confusing then descriptive. We reference directives and standards on our EU DOC by their number and date and follow it with a brief description and sometimes additional useful information. Such as: EN 61010-1:2010 Safety of Laboratory Equipment Or EN55011:2007+A2:2007RF EmissionsGroup 1, Class A The directives requirements are, a reference to the harmonized standards used, so I would think as long as you provide enough information so it is clear what the standards are you should be ok. We think about what information our customers and others might want to see in the DOC and include it if we can. The more descriptive we are the less questions we get from the field, which saves us time and money. We have used this approach for over 16 years and have not had any problems or holdups, so far. The Other Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge Knudsen Sent: Sunday, November 18, 2012 9:22 AM To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Hello Kris, About 10 years ago my company Niros Telecommunication was contacted by the Belgium Authority whom told that the DoC should be written in Dutch as well as in French and German. At that time we had a DoC written in English, German, French and Italian. We changed to a combination of a short form DoC and one complete DoC written in English. Short form in English: 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. The short form DoC can be found at the link below: http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e n.htm See 23. Form of the manufacturers' declaration to be put into the user's manual We used this form for DoC for the ATEX directive as well. Best regards Helge Knudsen Former Test Approval manager Niros Telecommunication Denmark -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier Kristiaan Sent: 18. november 2012 14:13 To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Nick, My country, Belgium, has 3 official national languages, Dutch, French and German. The most recent draft of the Belgian transposition proposal of the RoHS Directive states now that the EU DoC should be drawn up in a language easily understandable by authorities. While the authorities have the right to request a translation in one of the official languages, it allows the use of English. Hopefull other countries follow that example as it worked well for 20 years. Best regards, Kris Carpentier -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: zondag 18 november 2012 11:14 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: EU-DoC - list of applied standards with full title It's actually a requirement of some of the directives, not just an addition brought in by transposition in certain countries. Generally, where the Directive requires the Declaration to accompany the product, it must be translated in to the language of the country of the end user. I guess the Commissiion's logic is that the instructions will need to be translated into the same language(s) so it's not a significant additional burden to require the DofC to be translated as well. Nick. On 18 Nov 2012, at 07:56, John Woodgate j...@jmwa.demon.co.uk wrote: In message 867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com, dated Sat, 17 Nov 2012, Carpentier Kristiaan kristiaan.carpent...@technicolor.com writes: Some countries require in their national transposition that the EU DoC is issued in the local language. Although most are still in draft: France in French, Portugal in Portuguese, Germany in German, etc.. In worst case, we have some 24 languages in EU, so lots of fun for translation. Now that IS a hardship for manufacturers. The way to deal with it is for manufacturers' associations to petition the Commission for a clarification of the 'reference' requirement to mean just EN X: - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online
Re: [PSES] EU-DoC - list of applied standards with full title
I'm also just curious what countries don't use Arabic numerals? I would have been able to understand what standard was in play from what you sent below if you had sent it in Dutch, or Spanish. Group and class Groep 1, klasse A and Grupo 1, clase A, took about 30 seconds to actually translate and I suspect that I can remember them the next time I see them in this form. Requiring the name in the local language is killing a fly with a sledgehammer. Gary -Original Message- From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Monday, November 19, 2012 6:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU-DoC - list of applied standards with full title I think this all begs the question, has anyone experienced any problems with their EU DOC by not providing the Standard's Title? If so, what was the objection and what was necessary to resolve it? The official titles of directives and standards are often way too long and often more confusing then descriptive. We reference directives and standards on our EU DOC by their number and date and follow it with a brief description and sometimes additional useful information. Such as: EN 61010-1:2010 Safety of Laboratory Equipment Or EN55011:2007+A2:2007RF EmissionsGroup 1, Class A The directives requirements are, a reference to the harmonized standards used, so I would think as long as you provide enough information so it is clear what the standards are you should be ok. We think about what information our customers and others might want to see in the DOC and include it if we can. The more descriptive we are the less questions we get from the field, which saves us time and money. We have used this approach for over 16 years and have not had any problems or holdups, so far. The Other Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge Knudsen Sent: Sunday, November 18, 2012 9:22 AM To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Hello Kris, About 10 years ago my company Niros Telecommunication was contacted by the Belgium Authority whom told that the DoC should be written in Dutch as well as in French and German. At that time we had a DoC written in English, German, French and Italian. We changed to a combination of a short form DoC and one complete DoC written in English. Short form in English: 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. The short form DoC can be found at the link below: http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e n.htm See 23. Form of the manufacturers' declaration to be put into the user's manual We used this form for DoC for the ATEX directive as well. Best regards Helge Knudsen Former Test Approval manager Niros Telecommunication Denmark -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier Kristiaan Sent: 18. november 2012 14:13 To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Nick, My country, Belgium, has 3 official national languages, Dutch, French and German. The most recent draft of the Belgian transposition proposal of the RoHS Directive states now that the EU DoC should be drawn up in a language easily understandable by authorities. While the authorities have the right to request a translation in one of the official languages, it allows the use of English. Hopefull other countries follow that example as it worked well for 20 years. Best regards, Kris Carpentier -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: zondag 18 november 2012 11:14 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: EU-DoC - list of applied standards with full title It's actually a requirement of some of the directives, not just an addition brought in by transposition in certain countries. Generally, where the Directive requires the Declaration to accompany the product, it must be translated in to the language of the country of the end user. I guess the Commissiion's logic is that the instructions will need to be translated into the same language(s) so it's not a significant additional burden to require the DofC to be translated as well. Nick. On 18 Nov 2012, at 07:56, John Woodgate j...@jmwa.demon.co.uk wrote: In message 867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com, dated Sat, 17 Nov 2012, Carpentier Kristiaan kristiaan.carpent...@technicolor.com writes: Some countries require in their national transposition that the EU DoC is issued in the local language. Although most are still in draft: France in French, Portugal in Portuguese, Germany in German, etc
Re: [PSES] EU-DoC - list of applied standards with full title
In the realm of industrial use products on the DoC or Do we had the number and name of the standard(s) that were used to confirm conformance to the Directive. While market surveillance was never a problem for us, and customs in one EU Member State only questioned our product once, and that due to their misinterpretation of the product type, we found that more often it was the customer who asked what the standards were when we only used the number. The question usually came from someone in Purchasing or Quality when they got their copy of the DoC or DoI when the product arrived on their doorstep. From then on it was decided to use name in conjunction with the number. And since we had templates for the DoC or DoI and only changed the variables (serial number, date, DoC or DoI document number, etc.) it was not a problem. Steve Brody sgbr...@comcast.net stev...@productehsconsultng.com www.ProductEHSConsulting.com -Original Message- From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Monday, November 19, 2012 9:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU-DoC - list of applied standards with full title I think this all begs the question, has anyone experienced any problems with their EU DOC by not providing the Standard's Title? If so, what was the objection and what was necessary to resolve it? The official titles of directives and standards are often way too long and often more confusing then descriptive. We reference directives and standards on our EU DOC by their number and date and follow it with a brief description and sometimes additional useful information. Such as: EN 61010-1:2010 Safety of Laboratory Equipment Or EN55011:2007+A2:2007RF EmissionsGroup 1, Class A The directives requirements are, a reference to the harmonized standards used, so I would think as long as you provide enough information so it is clear what the standards are you should be ok. We think about what information our customers and others might want to see in the DOC and include it if we can. The more descriptive we are the less questions we get from the field, which saves us time and money. We have used this approach for over 16 years and have not had any problems or holdups, so far. The Other Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge Knudsen Sent: Sunday, November 18, 2012 9:22 AM To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Hello Kris, About 10 years ago my company Niros Telecommunication was contacted by the Belgium Authority whom told that the DoC should be written in Dutch as well as in French and German. At that time we had a DoC written in English, German, French and Italian. We changed to a combination of a short form DoC and one complete DoC written in English. Short form in English: 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. The short form DoC can be found at the link below: http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e n.htm See 23. Form of the manufacturers' declaration to be put into the user's manual We used this form for DoC for the ATEX directive as well. Best regards Helge Knudsen Former Test Approval manager Niros Telecommunication Denmark -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier Kristiaan Sent: 18. november 2012 14:13 To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Nick, My country, Belgium, has 3 official national languages, Dutch, French and German. The most recent draft of the Belgian transposition proposal of the RoHS Directive states now that the EU DoC should be drawn up in a language easily understandable by authorities. While the authorities have the right to request a translation in one of the official languages, it allows the use of English. Hopefull other countries follow that example as it worked well for 20 years. Best regards, Kris Carpentier -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: zondag 18 november 2012 11:14 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: EU-DoC - list of applied standards with full title It's actually a requirement of some of the directives, not just an addition brought in by transposition in certain countries. Generally, where the Directive requires the Declaration to accompany the product, it must be translated in to the language of the country of the end user. I guess the Commissiion's logic is that the instructions will need to be translated into the same language(s) so it's not a significant additional burden to require the DofC to be translated as well. Nick. On 18 Nov 2012
Re: [PSES] EU-DoC - list of applied standards with full title
While I was with HP and Agilent, we always listed the standard (as IEC/EN), the applicable annexes, the date of issue, an abbreviated title and the abbreviated test limits. Never had a problem, as far as I know. ___ Kenneth Wyatt Wyatt Technical Services LLC Woodland Park, CO Email Me! | Web Site | Blog The EMC Blog (TM World) Subscribe to Newsletter Connect with me on LinkedIn On Nov 19, 2012, at 9:30 AM, McInturff, Gary wrote: I'm also just curious what countries don't use Arabic numerals? I would have been able to understand what standard was in play from what you sent below if you had sent it in Dutch, or Spanish. Group and class Groep 1, klasse A and Grupo 1, clase A, took about 30 seconds to actually translate and I suspect that I can remember them the next time I see them in this form. Requiring the name in the local language is killing a fly with a sledgehammer. Gary -Original Message- From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Monday, November 19, 2012 6:10 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU-DoC - list of applied standards with full title I think this all begs the question, has anyone experienced any problems with their EU DOC by not providing the Standard's Title? If so, what was the objection and what was necessary to resolve it? The official titles of directives and standards are often way too long and often more confusing then descriptive. We reference directives and standards on our EU DOC by their number and date and follow it with a brief description and sometimes additional useful information. Such as: EN 61010-1:2010 Safety of Laboratory Equipment Or EN55011:2007+A2:2007RF EmissionsGroup 1, Class A The directives requirements are, a reference to the harmonized standards used, so I would think as long as you provide enough information so it is clear what the standards are you should be ok. We think about what information our customers and others might want to see in the DOC and include it if we can. The more descriptive we are the less questions we get from the field, which saves us time and money. We have used this approach for over 16 years and have not had any problems or holdups, so far. The Other Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge Knudsen Sent: Sunday, November 18, 2012 9:22 AM To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Hello Kris, About 10 years ago my company Niros Telecommunication was contacted by the Belgium Authority whom told that the DoC should be written in Dutch as well as in French and German. At that time we had a DoC written in English, German, French and Italian. We changed to a combination of a short form DoC and one complete DoC written in English. Short form in English: 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. The short form DoC can be found at the link below: http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e n.htm See 23. Form of the manufacturers' declaration to be put into the user's manual We used this form for DoC for the ATEX directive as well. Best regards Helge Knudsen Former Test Approval manager Niros Telecommunication Denmark -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier Kristiaan Sent: 18. november 2012 14:13 To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Nick, My country, Belgium, has 3 official national languages, Dutch, French and German. The most recent draft of the Belgian transposition proposal of the RoHS Directive states now that the EU DoC should be drawn up in a language easily understandable by authorities. While the authorities have the right to request a translation in one of the official languages, it allows the use of English. Hopefull other countries follow that example as it worked well for 20 years. Best regards, Kris Carpentier -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: zondag 18 november 2012 11:14 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: EU-DoC - list of applied standards with full title It's actually a requirement of some of the directives, not just an addition brought in by transposition in certain countries. Generally, where the Directive requires the Declaration to accompany the product, it must be translated in to the language of the country of the end user. I guess the Commissiion's logic is that the instructions will need to be translated
Re: [PSES] EU-DoC - list of applied standards with full title
In fact, the Note 3 at the bottom of the OJ listing itself provides a hint as to what is expected in referencing the standard: Note 3: In case of amendments, the referenced standard is EN C:, its previous amendments, if any, and the new, quoted amendment... While the Note is there to offer guidance on how to handle amendments, it seems reasonable to infer that the same format would apply to the base standard as well. The important point is to make an unambiguous reference so that the reader of the DoC knows exactly what standard you applied. If the standard numbers and amendments are listed along with their respective years of publication* on the DoC, that will constitute an unambiguous reference. The title of the standard is not necessary (and may not even be helpful) to make an unambiguous reference. So: EN 60950-1:2006 + A11:2009 + A12:2011 is an unambiguous reference. Examples of ambiguous references would be: 'EN 60950' 'EN 60950-1 +applicable amendments' I have never seen a case where an authority challenged an unambiguous reference such as the above with or without the title of the standard listed. Regards Peter. *One could probably argue that the year of the amendments is not necessary if the base standard is correctly identified. i.e. There will only ever by one 'A11' to EN 60950-1:2006 irrespective of what year it is published. -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Kunde, Brian Sent: 19 November 2012 14:10 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title I think this all begs the question, has anyone experienced any problems with their EU DOC by not providing the Standard's Title? If so, what was the objection and what was necessary to resolve it? The official titles of directives and standards are often way too long and often more confusing then descriptive. We reference directives and standards on our EU DOC by their number and date and follow it with a brief description and sometimes additional useful information. Such as: EN 61010-1:2010 Safety of Laboratory Equipment Or EN55011:2007+A2:2007RF EmissionsGroup 1, Class A The directives requirements are, a reference to the harmonized standards used, so I would think as long as you provide enough information so it is clear what the standards are you should be ok. We think about what information our customers and others might want to see in the DOC and include it if we can. The more descriptive we are the less questions we get from the field, which saves us time and money. We have used this approach for over 16 years and have not had any problems or holdups, so far. The Other Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge Knudsen Sent: Sunday, November 18, 2012 9:22 AM To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Hello Kris, About 10 years ago my company Niros Telecommunication was contacted by the Belgium Authority whom told that the DoC should be written in Dutch as well as in French and German. At that time we had a DoC written in English, German, French and Italian. We changed to a combination of a short form DoC and one complete DoC written in English. Short form in English: 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. The short form DoC can be found at the link below: http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e n.htm See 23. Form of the manufacturers' declaration to be put into the user's manual We used this form for DoC for the ATEX directive as well. Best regards Helge Knudsen Former Test Approval manager Niros Telecommunication Denmark -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier Kristiaan Sent: 18. november 2012 14:13 To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Nick, My country, Belgium, has 3 official national languages, Dutch, French and German. The most recent draft of the Belgian transposition proposal of the RoHS Directive states now that the EU DoC should be drawn up in a language easily understandable by authorities. While the authorities have the right to request a translation in one of the official languages, it allows the use of English. Hopefull other countries follow that example as it worked well for 20 years. Best regards, Kris Carpentier -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: zondag 18 november 2012 11:14
Re: [PSES] EU-DoC - list of applied standards with full title
In message d250d01e39356a4e9cc3b4b459d6655094d92...@ms-cda-01.advanced-input.com, dated Mon, 19 Nov 2012, McInturff, Gary gary.mcintu...@esterline.com writes: I'm also just curious what countries don't use Arabic numerals? Almost all countries that are not Arabic, in fact! 'Our' numerals are a corrupted version of true Arabic numerals. -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EU-DoC - list of applied standards with full title
In message 867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com, dated Sat, 17 Nov 2012, Carpentier Kristiaan kristiaan.carpent...@technicolor.com writes: Some countries require in their national transposition that the EU DoC is issued in the local language. Although most are still in draft: France in French, Portugal in Portuguese, Germany in German, etc.. In worst case, we have some 24 languages in EU, so lots of fun for translation. Now that IS a hardship for manufacturers. The way to deal with it is for manufacturers' associations to petition the Commission for a clarification of the 'reference' requirement to mean just EN X: -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EU-DoC - list of applied standards with full title
It's actually a requirement of some of the directives, not just an addition brought in by transposition in certain countries. Generally, where the Directive requires the Declaration to accompany the product, it must be translated in to the language of the country of the end user. I guess the Commissiion's logic is that the instructions will need to be translated into the same language(s) so it's not a significant additional burden to require the DofC to be translated as well. Nick. On 18 Nov 2012, at 07:56, John Woodgate j...@jmwa.demon.co.uk wrote: In message 867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com, dated Sat, 17 Nov 2012, Carpentier Kristiaan kristiaan.carpent...@technicolor.com writes: Some countries require in their national transposition that the EU DoC is issued in the local language. Although most are still in draft: France in French, Portugal in Portuguese, Germany in German, etc.. In worst case, we have some 24 languages in EU, so lots of fun for translation. Now that IS a hardship for manufacturers. The way to deal with it is for manufacturers' associations to petition the Commission for a clarification of the 'reference' requirement to mean just EN X: - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EU-DoC - list of applied standards with full title
In message b186fb02-da44-4d60-969a-ae6ee3015...@conformance.co.uk, dated Sun, 18 Nov 2012, Nick Williams nick.willi...@conformance.co.uk writes: I guess the Commissiion's logic is that the instructions will need to be translated into the same language(s) so it's not a significant additional burden to require the DofC to be translated as well. The titles of standards MUST NOT be translated, they must be the official titles in each language, and it may not be easy to find these. -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EU-DoC - list of applied standards with full title
Nick, My country, Belgium, has 3 official national languages, Dutch, French and German. The most recent draft of the Belgian transposition proposal of the RoHS Directive states now that the EU DoC should be drawn up in a language easily understandable by authorities. While the authorities have the right to request a translation in one of the official languages, it allows the use of English. Hopefull other countries follow that example as it worked well for 20 years. Best regards, Kris Carpentier -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: zondag 18 november 2012 11:14 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: EU-DoC - list of applied standards with full title It's actually a requirement of some of the directives, not just an addition brought in by transposition in certain countries. Generally, where the Directive requires the Declaration to accompany the product, it must be translated in to the language of the country of the end user. I guess the Commissiion's logic is that the instructions will need to be translated into the same language(s) so it's not a significant additional burden to require the DofC to be translated as well. Nick. On 18 Nov 2012, at 07:56, John Woodgate j...@jmwa.demon.co.uk wrote: In message 867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com, dated Sat, 17 Nov 2012, Carpentier Kristiaan kristiaan.carpent...@technicolor.com writes: Some countries require in their national transposition that the EU DoC is issued in the local language. Although most are still in draft: France in French, Portugal in Portuguese, Germany in German, etc.. In worst case, we have some 24 languages in EU, so lots of fun for translation. Now that IS a hardship for manufacturers. The way to deal with it is for manufacturers' associations to petition the Commission for a clarification of the 'reference' requirement to mean just EN X: - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EU-DoC - list of applied standards with full title
Hello Kris, About 10 years ago my company Niros Telecommunication was contacted by the Belgium Authority whom told that the DoC should be written in Dutch as well as in French and German. At that time we had a DoC written in English, German, French and Italian. We changed to a combination of a short form DoC and one complete DoC written in English. Short form in English: 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. The short form DoC can be found at the link below: http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e n.htm See 23. Form of the manufacturers' declaration to be put into the user's manual We used this form for DoC for the ATEX directive as well. Best regards Helge Knudsen Former Test Approval manager Niros Telecommunication Denmark -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier Kristiaan Sent: 18. november 2012 14:13 To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: EU-DoC - list of applied standards with full title Nick, My country, Belgium, has 3 official national languages, Dutch, French and German. The most recent draft of the Belgian transposition proposal of the RoHS Directive states now that the EU DoC should be drawn up in a language easily understandable by authorities. While the authorities have the right to request a translation in one of the official languages, it allows the use of English. Hopefull other countries follow that example as it worked well for 20 years. Best regards, Kris Carpentier -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: zondag 18 november 2012 11:14 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: EU-DoC - list of applied standards with full title It's actually a requirement of some of the directives, not just an addition brought in by transposition in certain countries. Generally, where the Directive requires the Declaration to accompany the product, it must be translated in to the language of the country of the end user. I guess the Commissiion's logic is that the instructions will need to be translated into the same language(s) so it's not a significant additional burden to require the DofC to be translated as well. Nick. On 18 Nov 2012, at 07:56, John Woodgate j...@jmwa.demon.co.uk wrote: In message 867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com, dated Sat, 17 Nov 2012, Carpentier Kristiaan kristiaan.carpent...@technicolor.com writes: Some countries require in their national transposition that the EU DoC is issued in the local language. Although most are still in draft: France in French, Portugal in Portuguese, Germany in German, etc.. In worst case, we have some 24 languages in EU, so lots of fun for translation. Now that IS a hardship for manufacturers. The way to deal with it is for manufacturers' associations to petition the Commission for a clarification of the 'reference' requirement to mean just EN X: - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] EU-DoC - list of applied standards with full title
Hello, I have my personal opion but different experiences with market surveillance authorities with respect to the following question: Decision 768/2008/EC (Annex III) or all existing new approach directives specifies the content of an EU-DoC as follows. References to the relevant harmonised standards used or references to the specifications in relation to which conformity is declared What does references mean? · EN :year/month AND · the title? ISO/IEC 17050-1 requires the title but a standard is not a legal requirement. Best regards Dipl.-Ing. Michael Loerzer Managing Director Regulatory Affairs Specialist Globalnorm GmbH Kurfürstenstr. 112 10787 Berlin Phone +49 30 3229027-51 Cell +49 170 3229027 Fax +49 30 3229027-59 Mail mailto:michael.loer...@globalnorm.de michael.loer...@globalnorm.de http://www.globalnorm.de/ » globalnorm.de Globalnorm GmbH, Sitz der Gesellschaft: Kurfürstenstr. 112, 10787 Berlin Geschäftsführer: Dipl.-Ing. Michael Loerzer Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EU-DoC - list of applied standards with full title
In message 001901cdc4ff$a4da0ab0$ee8e2010$@globalnorm.de, dated Sat, 17 Nov 2012, Michael Loerzer loerzer_mob...@globalnorm.de writes: I have my personal opion but different experiences with market surveillance authorities with respect to the following question: Is there any difficulty in including the title? If not, it is better not to risk an objection by not including it. -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] AW: EU-DoC - list of applied standards with full title
Comments from some manufacturers: too much work (costs time and money)... I also RECOMMEND to state the whole reference including the title but some of my customers (managing directors...) ask me: is that LEGAL required? Best regards Dipl.-Ing. Michael Loerzer Managing Director Regulatory Affairs Specialist Globalnorm GmbH Kurfürstenstr. 112 10787 Berlin Phone +49 30 3229027-51 Cell +49 170 3229027 Fax +49 30 3229027-59 Mailmichael.loer...@globalnorm.de » globalnorm.de Globalnorm GmbH, Sitz der Gesellschaft: Kurfürstenstr. 112, 10787 Berlin Geschäftsführer: Dipl.-Ing. Michael Loerzer Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448 -Ursprüngliche Nachricht- Von: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Im Auftrag von John Woodgate Gesendet: Samstag, 17. November 2012 22:03 An: EMC-PSTC@LISTSERV.IEEE.ORG Betreff: Re: EU-DoC - list of applied standards with full title In message 001901cdc4ff$a4da0ab0$ee8e2010$@globalnorm.de, dated Sat, 17 Nov 2012, Michael Loerzer loerzer_mob...@globalnorm.de writes: I have my personal opion but different experiences with market surveillance authorities with respect to the following question: Is there any difficulty in including the title? If not, it is better not to risk an objection by not including it. -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] AW: EU-DoC - list of applied standards with full title
In message 002201cdc508$a3e81a80$ebb84f80$@globalnorm.de, dated Sat, 17 Nov 2012, Michael Loerzer loerzer_mob...@globalnorm.de writes: Comments from some manufacturers: too much work (costs time and money)... They are just being stupid. The cost and time are utterly trivial. How much more time and money does a rejection of the DoC and the impounding of the shipment cost? I also RECOMMEND to state the whole reference including the title but some of my customers (managing directors...) ask me: is that LEGAL required? What you are asking for is the legal interpretation of the word 'references'. Ask 10 lawyers and you will get 10 different opinions, none definitive and all very costly. Until the meaning is tested in a court (or maybe a succession of appeal courts), no-one knows for certain. -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] AW: AW: EU-DoC - list of applied standards with full title
I agree. Dipl.-Ing. Michael Loerzer Managing Director Regulatory Affairs Specialist Globalnorm GmbH Kurfürstenstr. 112 10787 Berlin Phone +49 30 3229027-51 Cell +49 170 3229027 Fax +49 30 3229027-59 Mailmichael.loer...@globalnorm.de » globalnorm.de Globalnorm GmbH, Sitz der Gesellschaft: Kurfürstenstr. 112, 10787 Berlin Geschäftsführer: Dipl.-Ing. Michael Loerzer Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448 -Ursprüngliche Nachricht- Von: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Im Auftrag von John Woodgate Gesendet: Samstag, 17. November 2012 22:41 An: EMC-PSTC@LISTSERV.IEEE.ORG Betreff: Re: AW: EU-DoC - list of applied standards with full title In message 002201cdc508$a3e81a80$ebb84f80$@globalnorm.de, dated Sat, 17 Nov 2012, Michael Loerzer loerzer_mob...@globalnorm.de writes: Comments from some manufacturers: too much work (costs time and money)... They are just being stupid. The cost and time are utterly trivial. How much more time and money does a rejection of the DoC and the impounding of the shipment cost? I also RECOMMEND to state the whole reference including the title but some of my customers (managing directors...) ask me: is that LEGAL required? What you are asking for is the legal interpretation of the word 'references'. Ask 10 lawyers and you will get 10 different opinions, none definitive and all very costly. Until the meaning is tested in a court (or maybe a succession of appeal courts), no-one knows for certain. -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] AW: EU-DoC - list of applied standards with full title
If the title and number were not linked together one-on-one, Yes, I would suggest adding the title. But as they are linked, I do not see the need ! or There cannot bany standard be mistaken for another by referencing number and year. Or Adding the title would not resolve the disambiguity caused by the national standardization bodies in adapting the year's reference of a standard to the year of local publication. Gert Gremmen Ce-test Owner LinkedIN EMC-experts group -Oorspronkelijk bericht- Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Michael Loerzer Verzonden: zaterdag 17 november 2012 22:54 Aan: 'John Woodgate'; EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: AW: AW: EU-DoC - list of applied standards with full title I agree. Dipl.-Ing. Michael Loerzer Managing Director Regulatory Affairs Specialist Globalnorm GmbH Kurfürstenstr. 112 10787 Berlin Phone +49 30 3229027-51 Cell +49 170 3229027 Fax +49 30 3229027-59 Mailmichael.loer...@globalnorm.de » globalnorm.de Globalnorm GmbH, Sitz der Gesellschaft: Kurfürstenstr. 112, 10787 Berlin Geschäftsführer: Dipl.-Ing. Michael Loerzer Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448 -Ursprüngliche Nachricht- Von: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Im Auftrag von John Woodgate Gesendet: Samstag, 17. November 2012 22:41 An: EMC-PSTC@LISTSERV.IEEE.ORG Betreff: Re: AW: EU-DoC - list of applied standards with full title In message 002201cdc508$a3e81a80$ebb84f80$@globalnorm.de, dated Sat, 17 Nov 2012, Michael Loerzer loerzer_mob...@globalnorm.de writes: Comments from some manufacturers: too much work (costs time and money)... They are just being stupid. The cost and time are utterly trivial. How much more time and money does a rejection of the DoC and the impounding of the shipment cost? I also RECOMMEND to state the whole reference including the title but some of my customers (managing directors...) ask me: is that LEGAL required? What you are asking for is the legal interpretation of the word 'references'. Ask 10 lawyers and you will get 10 different opinions, none definitive and all very costly. Until the meaning is tested in a court (or maybe a succession of appeal courts), no-one knows for certain. -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp
Re: [PSES] EU-DoC - list of applied standards with full title
Michael, You may also know that the RoHS Recast Directive 2011/65/EU is the first Directive using the NLF, coming into force in Jan. 2013. Some countries require in their national transposition that the EU DoC is issued in the local language. Although most are still in draft: France in French, Portugal in Portuguese, Germany in German, etc. In worst case, we have some 24 languages in EU, so lots of fun for translation. One good point: ETSI has all titles of its standards translated online, see last pages of each standard. Best regards, Kris Carpentier From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Michael Loerzer Sent: zaterdag 17 november 2012 21:11 To: IEEE PSES Subject: EU-DoC - list of applied standards with full title Hello, I have my personal opion but different experiences with market surveillance authorities with respect to the following question: Decision 768/2008/EC (Annex III) or all existing new approach directives specifies the content of an EU-DoC as follows. References to the relevant harmonised standards used or references to the specifications in relation to which conformity is declared What does references mean? · EN :year/month AND · the title? ISO/IEC 17050-1 requires the title but a standard is not a legal requirement. Best regards Dipl.-Ing. Michael Loerzer Managing Director Regulatory Affairs Specialist Globalnorm GmbH Kurfürstenstr. 112 10787 Berlin Phone +49 30 3229027-51 Cell +49 170 3229027 Fax +49 30 3229027-59 Mailmichael.loer...@globalnorm.demailto:michael.loer...@globalnorm.de » globalnorm.dehttp://www.globalnorm.de/ Globalnorm GmbH, Sitz der Gesellschaft: Kurfürstenstr. 112, 10787 Berlin Geschäftsführer: Dipl.-Ing. Michael Loerzer Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.orgmailto:emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto:dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] AW: EU-DoC - list of applied standards with full title
In message FCA549BE3ECF9D4CB8CB8576837EA489140B07@ZEUS.cetest.local, dated Sat, 17 Nov 2012, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: If the title and number were not linked together one-on-one, Yes, I would suggest adding the title. But as they are linked, I do not see the need ! The number might be incorrectly printed, e.g. EN 60056 instead of EN 60065 (I have actually seen this). But the real reason for adding the title is that some people can make big trouble if it isn't added, whether they should or not. or There cannot bany standard be mistaken for another by referencing number and year. Or Adding the title would not resolve the disambiguity caused by the national standardization bodies in adapting the year's reference of a standard to the year of local publication. The standard should be cited as 'EN X:', not as 'DIN EN' or 'BS EN'. -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: [PSES] Updating EU DoC
This seems to have become unnecessarily complicated. If a standard changes, and you do some new testing or evaluation, then updating the D of C to reflect that is quite sensible. Your TF will show the new work done to support it. If a standard changes, and you have a quick look at the differences and decide that it is unimportant (as plenty of amendments are) and there’s nothing you need to do, then there’s no technical reason to amend the D of C. Yes, the presumption of conformity may have gone by not referencing the change, but since you’ve concluded that the actual conformity isn’t affected, then there’s no risk of any enforcement action succeeding. It’s making work to update every D of C to track every standards change, as you’ll also have to put a justification in the TF. You might want a nice new D of C to keep your customers happy, but that’s a marketing matter, not one that you must follow. John From: Robert Heller [mailto:rehel...@mmm.com] Sent: 12 October 2010 10:32 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Updating EU DoC Bear in mind that under the latest EMC Directive, the DoC must contain dated references (i.e., the standards tested to and their dates)(see note). If the dates of the standards change then the DoC must be updated. Note: Reference Directive 2004/108/EC, Annex IV, paragraph 2, fourth item. Bob Heller 3M EMC Laboratory, 76-1-01 St. Paul, MN 55107-1208 Tel: 651- 778-6336 Fax: 651-778-6252 = emc-p...@ieee.org wrote on 10/11/2010 12:49:27 PM: From: Kunde, Brian brian_ku...@lecotc.com To: emc-p...@ieee.org Date: 10/11/2010 12:51 PM Subject: RE: Updating EU DoC Sent by: emc-p...@ieee.org Power is control and control is power and once someone has the power it is difficult for them to give it up. I fought like crazy to not have our DOCs controlled through our Documentation Control department to avoid many of the problems you are having. They have to be control somehow but I keep track of them within our Compliance Department. How I was able to avoid ECN control of the DOC is on the DOC itself I reworded the statement to say; “The product herewith displaying the CE marking complies with the requirements of the……” So I argued that the CE compliance is not based on the DOC but on the CE Marking which is ECN controlled. The DOC just shows what the CE marking means at the time it was generated. As far as the DOC generation, we keep the information on all products in a database which includes the last audit date and other information that would appear on the DOC. When we pull up a DOC for any product, the DOC is dynamically generated with all the appropriate dates and information. We just print/save it to a .pdf file and store it in an archive area on our Intranet/network Page where the Sales/Marketing and Manuals departments have READ access. I’m the only one in the company with WRITE access to these folder so only I can change the DOCs. We also archive all the old DOCs incase someone wants to pull a copy of an old version. I hope this was helpful. The Other Brian From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Monday, October 11, 2010 11:38 AM To: emc-p...@ieee.org Subject: Updating EU DoC Hello group, I am looking to see how you folks generate and update your EU DOC. We use the typical MS Word template and every time there is a need for an update, we update this document and have to go through ECO (Engineering Change Order) since it is a controlled document and I found this process to be very time consuming and not really efficient in particular when you have over 100 DOC's to maintain. Is there any easier way? Is there an automated process out there? Do we really need to have it under control revision? Thank you Peter - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com _ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us
RE: [PSES] Updating EU DoC
I agree with this, but for completeness I would add that to the sentence that “the DoC must be updated if you want to maintain a ‘presumption of conformity’ with the EMC Directive.” Strictly speaking the DoC does not have to be updated if there is some technical justification for not doing so. But then the ‘presumption of conformity’ is lost, which is not the ideal situation to be in, so “the DoC ought to be updated” is another way of putting it. Best Regards, John From: Robert Heller [mailto:rehel...@mmm.com] Sent: 12 October 2010 10:32 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Updating EU DoC Bear in mind that under the latest EMC Directive, the DoC must contain dated references (i.e., the standards tested to and their dates)(see note). If the dates of the standards change then the DoC must be updated. Note: Reference Directive 2004/108/EC, Annex IV, paragraph 2, fourth item. Bob Heller 3M EMC Laboratory, 76-1-01 St. Paul, MN 55107-1208 Tel: 651- 778-6336 Fax: 651-778-6252 = emc-p...@ieee.org wrote on 10/11/2010 12:49:27 PM: From: Kunde, Brian brian_ku...@lecotc.com To: emc-p...@ieee.org Date: 10/11/2010 12:51 PM Subject: RE: Updating EU DoC Sent by: emc-p...@ieee.org Power is control and control is power and once someone has the power it is difficult for them to give it up. I fought like crazy to not have our DOCs controlled through our Documentation Control department to avoid many of the problems you are having. They have to be control somehow but I keep track of them within our Compliance Department. How I was able to avoid ECN control of the DOC is on the DOC itself I reworded the statement to say; “The product herewith displaying the CE marking complies with the requirements of the……” So I argued that the CE compliance is not based on the DOC but on the CE Marking which is ECN controlled. The DOC just shows what the CE marking means at the time it was generated. As far as the DOC generation, we keep the information on all products in a database which includes the last audit date and other information that would appear on the DOC. When we pull up a DOC for any product, the DOC is dynamically generated with all the appropriate dates and information. We just print/save it to a .pdf file and store it in an archive area on our Intranet/network Page where the Sales/Marketing and Manuals departments have READ access. I’m the only one in the company with WRITE access to these folder so only I can change the DOCs. We also archive all the old DOCs incase someone wants to pull a copy of an old version. I hope this was helpful. The Other Brian From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Monday, October 11, 2010 11:38 AM To: emc-p...@ieee.org Subject: Updating EU DoC Hello group, I am looking to see how you folks generate and update your EU DOC. We use the typical MS Word template and every time there is a need for an update, we update this document and have to go through ECO (Engineering Change Order) since it is a controlled document and I found this process to be very time consuming and not really efficient in particular when you have over 100 DOC's to maintain. Is there any easier way? Is there an automated process out there? Do we really need to have it under control revision? Thank you Peter - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com _ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee
RE: Updating EU DoC
Bear in mind that under the latest EMC Directive, the DoC must contain dated references (i.e., the standards tested to and their dates)(see note). If the dates of the standards change then the DoC must be updated. Note: Reference Directive 2004/108/EC, Annex IV, paragraph 2, fourth item. Bob Heller 3M EMC Laboratory, 76-1-01 St. Paul, MN 55107-1208 Tel: 651- 778-6336 Fax: 651-778-6252 = emc-p...@ieee.org wrote on 10/11/2010 12:49:27 PM: From: Kunde, Brian brian_ku...@lecotc.com To: emc-p...@ieee.org Date: 10/11/2010 12:51 PM Subject: RE: Updating EU DoC Sent by: emc-p...@ieee.org Power is control and control is power and once someone has the power it is difficult for them to give it up. I fought like crazy to not have our DOCs controlled through our Documentation Control department to avoid many of the problems you are having. They have to be control somehow but I keep track of them within our Compliance Department. How I was able to avoid ECN control of the DOC is on the DOC itself I reworded the statement to say; “The product herewith displaying the CE marking complies with the requirements of the……” So I argued that the CE compliance is not based on the DOC but on the CE Marking which is ECN controlled. The DOC just shows what the CE marking means at the time it was generated. As far as the DOC generation, we keep the information on all products in a database which includes the last audit date and other information that would appear on the DOC. When we pull up a DOC for any product, the DOC is dynamically generated with all the appropriate dates and information. We just print/save it to a .pdf file and store it in an archive area on our Intranet/network Page where the Sales/Marketing and Manuals departments have READ access. I’m the only one in the company with WRITE access to these folder so only I can change the DOCs. We also archive all the old DOCs incase someone wants to pull a copy of an old version. I hope this was helpful. The Other Brian From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Monday, October 11, 2010 11:38 AM To: emc-p...@ieee.org Subject: Updating EU DoC Hello group, I am looking to see how you folks generate and update your EU DOC. We use the typical MS Word template and every time there is a need for an update, we update this document and have to go through ECO (Engineering Change Order) since it is a controlled document and I found this process to be very time consuming and not really efficient in particular when you have over 100 DOC's to maintain. Is there any easier way? Is there an automated process out there? Do we really need to have it under control revision? Thank you Peter - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com _ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web
AW: Updating EU DoC
Hello Peter, for this issue we have developed the „DoC-Manager“ with an interface to our standards management software GLOBALNORM. If you are interested we can present this tool via a telephoe conference. I also attend the IEEE PSES symposium in Boston and we have a booth at the exhibition if you are going to Boston. Kind regards Dipl.-Ing. Michael Loerzer Managing Director Regulatory Affairs Specialist Das neue Buch zum Thema Product Compliance: http://www.beuth.de/sc/produktkonformitaet http://www.beuth.de/sc/produktkonformitaet (Produktkonformität, Prozesse, Risikomanagement, CE-Kennzeichnung, Fallbeispiele für Geschäftsführung, Konstruktion, Normenabteilung, Vertrieb, Einkauf, Produktion, QM) _ Globalnorm GmbH Alt-Moabit 94 10559 Berlin Fon +49 30 3229027-51 Mobile +49 170 3229027 Fax +49 30 3229027-59 Mailmichael.loer...@globalnorm.de mailto:michael.loer...@globalnorm.de www.globalnorm.de http://www.globalnorm.de/ www.globalnorm.ca http://www.globalnorm.ca/ www.product-compliance.com http://www.product-compliance.com/ _ Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin Geschäftsführer: Dipl.-Ing. Michael Loerzer Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448 Von: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Im Auftrag von peterh...@aol.com Gesendet: Dienstag, 12. Oktober 2010 05:50 An: brian_ku...@lecotc.com; emc-p...@ieee.org Betreff: Re: Updating EU DoC Thank you all for your positive feedback. The changes that we make is not component related, but it is mainly related to change in standards. For example, EN60950-1 1st edition to 2nd edition. So product itself has hardly changed but rather the Directive or standard has changed and therefore we need to reflect these in the new DoC. How would you handle such cases? Thanks Peter -Original Message- From: Kunde, Brian brian_ku...@lecotc.com To: emc-pstc emc-p...@ieee.org Sent: Mon, Oct 11, 2010 10:51 am Subject: RE: Updating EU DoC Power is control and control is power and once someone has the power it is difficult for them to give it up. I fought like crazy to not have our DOCs controlled through our Documentation Control department to avoid many of the problems you are having. They have to be control somehow but I keep track of them within our Compliance Department. How I was able to avoid ECN control of the DOC is on the DOC itself I reworded the statement to say; “The product herewith displaying the CE marking complies with the requirements of the……” So I argued that the CE compliance is not based on the DOC but on the CE Marking which is ECN controlled. The DOC just shows what the CE marking means at the time it was generated. As far as the DOC generation, we keep the information on all products in a database which includes the last audit date and other information that would appear on the DOC. When we pull up a DOC for any product, the DOC is dynamically generated with all the appropriate dates and information. We just print/save it to a .pdf file and store it in an archive area on our Intranet/network Page where the Sales/Marketing and Manuals departments have READ access. I’m the only one in the company with WRITE access to these folder so only I can change the DOCs. We also archive all the old DOCs incase someone wants to pull a copy of an old version. I hope this was helpful. The Other Brian From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Monday, October 11, 2010 11:38 AM To: emc-p...@ieee.org Subject: Updating EU DoC Hello group, I am looking to see how you folks generate and update your EU DOC. We use the typical MS Word template and every time there is a need for an update, we update this document and have to go through ECO (Engineering Change Order) since it is a controlled document and I found this process to be very time consuming and not really efficient in particular when you have over 100 DOC's to maintain. Is there any easier way? Is there an automated process out there? Do we really need to have it under control revision? Thank you Peter - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. 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
Re: Updating EU DoC
Thank you all for your positive feedback. The changes that we make is not component related, but it is mainly related to change in standards. For example, EN60950-1 1st edition to 2nd edition. So product itself has hardly changed but rather the Directive or standard has changed and therefore we need to reflect these in the new DoC. How would you handle such cases? Thanks Peter -Original Message- From: Kunde, Brian brian_ku...@lecotc.com To: emc-pstc emc-p...@ieee.org Sent: Mon, Oct 11, 2010 10:51 am Subject: RE: Updating EU DoC Power is control and control is power and once someone has the power it is difficult for them to give it up. I fought like crazy to not have our DOCs controlled through our Documentation Control department to avoid many of the problems you are having. They have to be control somehow but I keep track of them within our Compliance Department. How I was able to avoid ECN control of the DOC is on the DOC itself I reworded the statement to say; “The product herewith displaying the CE marking complies with the requirements of the……” So I argued that the CE compliance is not based on the DOC but on the CE Marking which is ECN controlled. The DOC just shows what the CE marking means at the time it was generated. As far as the DOC generation, we keep the information on all products in a database which includes the last audit date and other information that would appear on the DOC. When we pull up a DOC for any product, the DOC is dynamically generated with all the appropriate dates and information. We just print/save it to a .pdf file and store it in an archive area on our Intranet/network Page where the Sales/Marketing and Manuals departments have READ access. I’m the only one in the company with WRITE access to these folder so only I can change the DOCs. We also archive all the old DOCs incase someone wants to pull a copy of an old version. I hope this was helpful. The Other Brian From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Monday, October 11, 2010 11:38 AM To: emc-p...@ieee.org Subject: Updating EU DoC Hello group, I am looking to see how you folks generate and update your EU DOC. We use the typical MS Word template and every time there is a need for an update, we update this document and have to go through ECO (Engineering Change Order) since it is a controlled document and I found this process to be very time consuming and not really efficient in particular when you have over 100 DOC's to maintain. Is there any easier way? Is there an automated process out there? Do we really need to have it under control revision? Thank you Peter - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com _ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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 LT;emc-p...@ieee.orgGT; All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. 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 LT;emcp...@radiusnorth.netGT; Mike Cantwell LT;mcantw...@ieee.orgGT; For policy questions, send mail to: Jim Bacher LT;j.bac...@ieee.orgGT; David Heald LT;dhe...@gmail.comGT; - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL
RE: Updating EU DoC
Power is control and control is power and once someone has the power it is difficult for them to give it up. I fought like crazy to not have our DOCs controlled through our Documentation Control department to avoid many of the problems you are having. They have to be control somehow but I keep track of them within our Compliance Department. How I was able to avoid ECN control of the DOC is on the DOC itself I reworded the statement to say; “The product herewith displaying the CE marking complies with the requirements of the……” So I argued that the CE compliance is not based on the DOC but on the CE Marking which is ECN controlled. The DOC just shows what the CE marking means at the time it was generated. As far as the DOC generation, we keep the information on all products in a database which includes the last audit date and other information that would appear on the DOC. When we pull up a DOC for any product, the DOC is dynamically generated with all the appropriate dates and information. We just print/save it to a .pdf file and store it in an archive area on our Intranet/network Page where the Sales/Marketing and Manuals departments have READ access. I’m the only one in the company with WRITE access to these folder so only I can change the DOCs. We also archive all the old DOCs incase someone wants to pull a copy of an old version. I hope this was helpful. The Other Brian From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of peterh...@aol.com Sent: Monday, October 11, 2010 11:38 AM To: emc-p...@ieee.org Subject: Updating EU DoC Hello group, I am looking to see how you folks generate and update your EU DOC. We use the typical MS Word template and every time there is a need for an update, we update this document and have to go through ECO (Engineering Change Order) since it is a controlled document and I found this process to be very time consuming and not really efficient in particular when you have over 100 DOC's to maintain. Is there any easier way? Is there an automated process out there? Do we really need to have it under control revision? Thank you Peter - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com _ LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
RE: [PSES] Updating EU DoC
Hello Peter, You do not need to update your DoC for every ECO. Your DoC is your declaration to the outside world that you declare your particular product (or several model variations of products) compliant with the EC Directive. If you make a component change (or any other reason for your ECO), yet your model number remains the same as stated on your current DoC, then a new DoC is certainly not required. You would, of course, need to record the effect of the ECO in your technical file, which backs up the DoC and this is where your control should concentrate (i.e. your “internal production control” under the 2004/108/EC). My one-day EMC Goggles training course addresses such issues relating to the EMC Directive, amongst many other aspects of EMC, including a clear understanding of the effects of interference, design for compliance and EMC testing. It’s a complete all-round course with many tips included from my 20 years spent working in EMC. I am giving this course at San Jose, California, on Monday 18th October – that’s just next week! If anyone is interested in attending, or knows of someone within their organisation who needs to be brought up to speed on EMC, please email me separately. There are a few places available. Best Regards, John From: peterh...@aol.com [mailto:peterh...@aol.com] Sent: 11 October 2010 16:38 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Updating EU DoC Hello group, I am looking to see how you folks generate and update your EU DOC. We use the typical MS Word template and every time there is a need for an update, we update this document and have to go through ECO (Engineering Change Order) since it is a controlled document and I found this process to be very time consuming and not really efficient in particular when you have over 100 DOC's to maintain. Is there any easier way? Is there an automated process out there? Do we really need to have it under control revision? Thank you Peter - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com -- This message has been scanned for viruses and dangerous content by MailScanner http://www.mailscanner.info/ , and is believed to be clean. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
Updating EU DoC
Hello group, I am looking to see how you folks generate and update your EU DOC. We use the typical MS Word template and every time there is a need for an update, we update this document and have to go through ECO (Engineering Change Order) since it is a controlled document and I found this process to be very time consuming and not really efficient in particular when you have over 100 DOC's to maintain. Is there any easier way? Is there an automated process out there? Do we really need to have it under control revision? Thank you Peter - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to emc-p...@ieee.org All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
Antwort: EU DoC on 2.4GHz TX Modules
Grace, you need to use the RTTE Directive where LVD and EMCD are included. For RTTE see radio standards. Kind regards Mario Lehmann Geschäftsbereich European Compliance Laboratory (ECL) __ HERBERG. Service Plus GmbH Tel:+49 911 59835-923 Nordostpark 51 Fax:+49 911 59835-90 90411 Nürnberg mailto: mlehm...@herberg-sp.de mailto:mlehm...@herberg-sp.de http://www.herberg-sp.de http://www.herberg-sp.de/ Amtsgericht NürnbergGeschäftsführer HRB 19587 Peter Birkmann Grace Lin graceli...@gmail.com Gesendet von: emc-p...@ieee.org 20.05.2008 17:44 An emc-p...@ieee.org Kopie Thema EU DoC on 2.4GHz TX Modules Dear Members, Is there any EU rule specified reqirements for a transmitter module? My questions are: 1). Does CE mark apply to a transmitter module? 2). If yes from 1), does a DoC need to include Low Voltage Directive and EMC Directive? Thank you and look forward to hear from you. Best regards, Grace - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: EU DoC on 2.4GHz TX Modules
Grace 1) Yes 2) RTTE Directive and standards applied Peter Grace Lin graceli...@gmail.com wrote: Dear Members, Is there any EU rule specified reqirements for a transmitter module? My questions are: 1). Does CE mark apply to a transmitter module? 2). If yes from 1), does a DoC need to include Low Voltage Directive and EMC Directive? Thank you and look forward to hear from you. Best regards, Grace - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
EU DoC on 2.4GHz TX Modules
Dear Members, Is there any EU rule specified reqirements for a transmitter module? My questions are: 1). Does CE mark apply to a transmitter module? 2). If yes from 1), does a DoC need to include Low Voltage Directive and EMC Directive? Thank you and look forward to hear from you. Best regards, Grace - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: EU DoC for Antennas
Greetings! For antenna itself (shipping separately and can work with different model of products), is there any need for an EU DoC? Please reference Interpretation of The http://ec.europa.eu/enterprise/rtte/interp.htm Directive 1999/5/EC at Europa while paying particular attention to the following: http://ec.europa.eu/enterprise/rtte/tcam8.htm#antennas 23. Are antennas covered by the Directive? specifically: 3. Passive antennas are not considered as relevant components in their own right under Article 2(c) of the RTTE Directive, and thus fall outside the scope of the RTTE Directive if placed on the market as a single commercial unit for distribution or final use. Passive antennas, if they are marketed in conjunction with a radio product, will be subject to all the requirements of the Directive as part of the overall radio product. If the hyperlinks do not work for you the URL’s follow: http://ec.europa.eu/enterprise/rtte/interp.htm http://ec.europa.eu/enterprise/rtte/tcam8.htm#antennas Alvin Disclaimer: The contents reflect the opinion of the author and are meant for entertainment purposes only. _ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Grace Lin Sent: Tuesday, December 11, 2007 7:31 AM To: emc-p...@ieee.org Subject: EU DoC for Antennas Dear Members, Does a manufacturer need to have an EU Declaration of Conformity for antennas which work with hand-held remote controllers? The antenna contains no electronic circuit. A RF device typically is certified with certain models of antennas. For antenna itself (shipping separately and can work with different model of products), is there any need for an EU DoC? Is BNC connector (popular connector) a problem? Thank you and look forward to hear from you. Best regards, Grace - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages attached to it, may contain information that is confidential and/or legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, please DO NOT disclose the contents to another person, store or copy the information in any medium, or use any of the information contained in or attached to this transmission for any purpose. If you have received this transmission in error, please immediately notify the sender by reply email or at mailto:priv...@plantronics.com, and destroy the original transmission and its attachments without reading or saving in any manner. For further information about Plantronics - the Company, its products, brands, partners, please visit our website www.plantronics.com. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: EU DoC for Antennas
Per the guide on the recent LVD update, I think the answer is it depends. Here is an excerpt: However, other electrical components which are intended to be incorporated into other equipment and for which a risk assessment can be undertaken[7], such as - transformers and electrical motors, are covered as such by the Directive and must be CE marked. If one were to make an inductive loop antenna that needed to be assessed for hazardous voltage, it could be viewed in the same light as the transformer in the excerpt. As the RTTED includes the LVD and EMCD, it looks like at least some antennas require a CE mark. Don Umbdenstock Manager Compliance Engineering Tyco Safety Products / Sensormatic 6600 Congress Avenue Boca Raton, FL 33487 USA Phone: 561.912.6440 djumbdenst...@tycoint.com From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Tuesday, December 11, 2007 11:52 AM To: emc-p...@ieee.org Subject: Re: EU DoC for Antennas In message 2a93eb060712110730w1f0425c7u5d068e4249cf6...@mail.gmail.com, dated Tue, 11 Dec 2007, Grace Lin graceli...@gmail.com writes: Does a manufacturer need to have an EU Declaration of Conformity for antennas which work with hand-held remote controllers? The antenna contains no electronic circuit. A RF device typically is certified with certain models of antennas. For antenna itself (shipping separately and can work with different model of products), is there any need for an EU DoC? I'm not entirely sure what the RTTE Directive requires, but I can't see that either the LVD or the EMCD requires a DoC for an antenna. I would include with the antenna a list of the products it is intended to work with and a warning not to use it with any other product. (Just to show that all the 'angles' have been considered.) Is BNC connector (popular connector) a problem? In what way? I don't see any problem. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk For very important information, please turn over. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: EU DoC for Antennas
In message 8b3bf7a02b910640ab146a919ab3659404c5c...@exsvl03.hq.netapp.com, dated Tue, 11 Dec 2007, Kim, Ben ben@netapp.com writes: For some intentional radiators, FCC doesn't allow to use popular connector/jack for antenna. Please check whether your products are regulated under FCC Part 15.203 or not. The enquiry is in connection with the European market, so the FCC is irrelevant. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk For very important information, please turn over. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: EU DoC for Antennas
For some intentional radiators, FCC doesn't allow to use popular connector/jack for antenna. Please check whether your products are regulated under FCC Part 15.203 or not. Ben Kim From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Tuesday, December 11, 2007 8:52 AM To: emc-p...@ieee.org Subject: Re: EU DoC for Antennas In message 2a93eb060712110730w1f0425c7u5d068e4249cf6...@mail.gmail.com, dated Tue, 11 Dec 2007, Grace Lin graceli...@gmail.com writes: Does a manufacturer need to have an EU Declaration of Conformity for antennas which work with hand-held remote controllers? The antenna contains no electronic circuit. A RF device typically is certified with certain models of antennas. For antenna itself (shipping separately and can work with different model of products), is there any need for an EU DoC? I'm not entirely sure what the RTTE Directive requires, but I can't see that either the LVD or the EMCD requires a DoC for an antenna. I would include with the antenna a list of the products it is intended to work with and a warning not to use it with any other product. (Just to show that all the 'angles' have been considered.) Is BNC connector (popular connector) a problem? In what way? I don't see any problem. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk For very important information, please turn over. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: EU DoC for Antennas
For some intentional radiators, FCC doesn't allow to use popular antenna. Please check whether your products are regulated under FCC Part 15.203 or not. Ben Kim From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Tuesday, December 11, 2007 8:52 AM To: emc-p...@ieee.org Subject: Re: EU DoC for Antennas In message 2a93eb060712110730w1f0425c7u5d068e4249cf6...@mail.gmail.com, dated Tue, 11 Dec 2007, Grace Lin graceli...@gmail.com writes: Does a manufacturer need to have an EU Declaration of Conformity for antennas which work with hand-held remote controllers? The antenna contains no electronic circuit. A RF device typically is certified with certain models of antennas. For antenna itself (shipping separately and can work with different model of products), is there any need for an EU DoC? I'm not entirely sure what the RTTE Directive requires, but I can't see that either the LVD or the EMCD requires a DoC for an antenna. I would include with the antenna a list of the products it is intended to work with and a warning not to use it with any other product. (Just to show that all the 'angles' have been considered.) Is BNC connector (popular connector) a problem? In what way? I don't see any problem. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk For very important information, please turn over. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: EU DoC for Antennas
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Tuesday, December 11, 2007 8:52 AM To: emc-p...@ieee.org Subject: Re: EU DoC for Antennas In message 2a93eb060712110730w1f0425c7u5d068e4249cf6...@mail.gmail.com, dated Tue, 11 Dec 2007, Grace Lin graceli...@gmail.com writes: Is BNC connector (popular connector) a problem? A well-assembled BNC can be used in a lab environment from DC to about 1 GHz. The BNC is very easy to mate / unmate, and it is not horribly expensive. However, a test antenna is moved around during use, and puts stresses on the attached cable. Since you want the antenna / cable assembly to be very reliable, I wouldn't recommend using a BNC beyond about 30 MHz. Better results will be had if you use a TNC or an N connector. If the antenna is being carried on a mast carriage, then you should consider proper cable support to keep the cable weight from hanging from the antenna connector. Ed Price ed.pr...@cubic.com WB6WSN NARTE Certified EMC Engineer Technician Electromagnetic Compatibility Lab Cubic Defense Applications San Diego, CA USA 858-505-2780 (Voice) 858-505-1583 (FAX) Military Avionics EMC Is Our Specialty - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: EU DoC for Antennas
In message 2a93eb060712110730w1f0425c7u5d068e4249cf6...@mail.gmail.com, dated Tue, 11 Dec 2007, Grace Lin graceli...@gmail.com writes: Does a manufacturer need to have an EU Declaration of Conformity for antennas which work with hand-held remote controllers? The antenna contains no electronic circuit. A RF device typically is certified with certain models of antennas. For antenna itself (shipping separately and can work with different model of products), is there any need for an EU DoC? I'm not entirely sure what the RTTE Directive requires, but I can't see that either the LVD or the EMCD requires a DoC for an antenna. I would include with the antenna a list of the products it is intended to work with and a warning not to use it with any other product. (Just to show that all the 'angles' have been considered.) Is BNC connector (popular connector) a problem? In what way? I don't see any problem. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk For very important information, please turn over. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
EU DoC for Antennas
Dear Members, Does a manufacturer need to have an EU Declaration of Conformity for antennas which work with hand-held remote controllers? The antenna contains no electronic circuit. A RF device typically is certified with certain models of antennas. For antenna itself (shipping separately and can work with different model of products), is there any need for an EU DoC? Is BNC connector (popular connector) a problem? Thank you and look forward to hear from you. Best regards, Grace - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
EU DoC
In response to John's comment/question, the answer could well be that the Commission and it's national enforcing authorities do not want to be faced with the possibility of having chase 2(or even 3 or more under a multiple branding situation) companies over a non-compliance/safety situation. Thus - as far as Directives compliance is concerned - they want only 1 company to take the responsibility for each product. But there's no way for them to ensure that. From what I can tell, there's nothing to stop several different different importers from importing the same product and independently issuing their own declarations for it. If the product is found to be defective, all the importers of the product will theoretically be responsible - although I have no idea how the authorities might trace them. Greg Galluccio www.productapprovals.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: EU DoC - ATEX Examples
In a message dated 11/8/02 7:56:16 AM Eastern Standard Time, chris_al...@eur.3com.com writes: Company B should issue the DoC. But to show due diligence they should obtain a DoC (and copies of test reports) from Company A. That makes two DoC's for one product. If company A issues a legally compliant DoC, why would company B issue one? Greg Galluccio www.productapprovals.com
RE: EU DoC - ATEX Examples
Dear All, We should learn from the Australians. When there are multiple distributors in Europe and in order not to have the file duplicated, you the manufacturer, can use an Agent that can hold the file and the Declarations. The agent number should then appear by the CE Mark. I think this would solve many sleepless nights and will create jobs for the unemployed as Agents. All the Best, This e-mail message may contain privileged or confidential information. If you are not the intended recipient, you may not disclose, use, disseminate, distribute, copy or rely upon this message or attachment in any way. If you received this e-mail message in error, please return by forwarding the message and its attachments to the sender. PETER S. MERGUERIAN Technical Director I.T.L. (Product Testing) Ltd. 26 Hacharoshet St., POB 211 Or Yehuda 60251, Israel Tel: + 972-(0)3-5339022 Fax: + 972-(0)3-5339019 Mobile: + 972-(0)54-838175 http://www.itl.co.il http://www.i-spec.com -Original Message- From: Chris Allen [mailto:chris_al...@eur.3com.com] Sent: Friday, November 08, 2002 2:54 PM To: John Woodgate Cc: emc-p...@majordomo.ieee.org Subject: Re: EU DoC - ATEX Examples I thought it was the person who placed the product on the market that was responsible for issuing the DoC? In this case there are 2 markets that the product is being placed on to. The commercial market and the end user market. Company B should issue the DoC. But to show due diligence they should obtain a DoC (and copies of test reports) from Company A. That way if it ever goes to court, Company B can show that they showed due diligence in maintaining appropriate documentation and that Company A is responsible for the failure to comply. Chris. John Woodgate j...@jmwa.demon.co.uk on 08/11/2002 09:39:21 Please respond to John Woodgate j...@jmwa.demon.co.uk Sent by: John Woodgate j...@jmwa.demon.co.uk To: emc-p...@majordomo.ieee.org cc:(Chris Allen/GB/3Com) Subject: Re: EU DoC - ATEX Examples I read in !emc-pstc that John Allen john.al...@era.co.uk wrote (in BFE68AB0084CD311B4FB00508B014C8703CF9CD3@MERCURY) about 'EU DoC - ATEX Examples' on Fri, 8 Nov 2002: In response to John's comment/question, the answer could well be that the Commission and it's national enforcing authorities do not want to be faced with the possibility of having chase 2(or even 3 or more under a multiple branding situation) companies over a non-compliance/safety situation. Thus - as far as Directives compliance is concerned - they want only 1 company to take the responsibility for each product. Maybe, but legally it won't wash. If Company B (marketer) were pursued for a violation, its lawyers would immediately involve Company A (manufacturer), and if they had previously earned their keep, that would be based on the contract between A and B requiring A to provide a DOC in every way and in every effect the same as if it were a DOC as required by the relevant Directives. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail
RE: EU DoC
Chris Allen wrote: Company B should raise a DoC to sell the item under it's own brand name. However, company B should obtain a DoC issued by company A for it's own good. My mistake. I overlooked the statement of the original message, which says both companies are located in EU. Chris is right. However, my message is true when at least company B is located elsewhere in the world. Alexandru Guidea. -Original Message- From: Chris Allen [mailto:chris_al...@eur.3com.com] Sent: Thursday, November 07, 2002 2:34 AM To: richwo...@tycoint.com Cc: emc-p...@majordomo.ieee.org Subject: Re: EU DoC Company B should raise a DoC to sell the item under it's own brand name. However, company B should obtain a DoC issued by company A for it's own good. Chris. richwo...@tycoint.com on 06/11/2002 18:22:08 Please respond to richwo...@tycoint.com Sent by: richwo...@tycoint.com To: emc-p...@majordomo.ieee.org cc:(Chris Allen/GB/3Com) Subject: EU DoC Company A builds a device for company B which sells the device in the EU under their own brand name. The device is subject to a Declaration of Conformity, and both companies are located within the EU. Must both companies issue a Declaration? Richard Woods Sensormatic Electronics Tyco International --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived
Re: EU DoC - ATEX Examples
I read in !emc-pstc that John Allen john.al...@era.co.uk wrote (in BFE68AB0084CD311B4FB00508B014C8703CF9CD3@MERCURY) about 'EU DoC - ATEX Examples' on Fri, 8 Nov 2002: In response to John's comment/question, the answer could well be that the Commission and it's national enforcing authorities do not want to be faced with the possibility of having chase 2(or even 3 or more under a multiple branding situation) companies over a non-compliance/safety situation. Thus - as far as Directives compliance is concerned - they want only 1 company to take the responsibility for each product. Maybe, but legally it won't wash. If Company B (marketer) were pursued for a violation, its lawyers would immediately involve Company A (manufacturer), and if they had previously earned their keep, that would be based on the contract between A and B requiring A to provide a DOC in every way and in every effect the same as if it were a DOC as required by the relevant Directives. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: EU DoC
Nick I can see your viewpoint, but I don't think I agree with you - I believe that b(i) and b(ii) are alternatives - not additive. In Clause 3 Intepretations of the UK EMC Regs Regulations (SI 99 No 2372) it defines the responsible person as follows: responsible person in relation to relevant apparatus means- (a) the manufacturer thereof; (b) the manufacturer's authorised representative; or (c) where the manufacturer is not established in the Community and he has not appointed an authorised representative, the person who supplies the relevant apparatus;.. From the or at the end of (b)I take these to mean that (a), (b) and (c) are alternatives - not an additive list. See also my separate response today to John Woodgate's point about the Commission's probably attitude to multiple signatories. Regards John Allen Technical Consultant Electromagnetics, Safety and Reliability Group ERA Technology Ltd Cleeve Rd Leatherhead Surrey KT22 7SA Tel:+44 (0) 1372-367025 (Direct) +44 (0) 1372-367000 (Switchboard) Fax:+44 (0) 1372-367102 (Fax) -Original Message- From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: 07 November 2002 21:54 To: John Allen Cc: emc-p...@majordomo.ieee.org Subject: RE: EU DoC ...but for an alternative view, Regulation 40 (2) of the UK's The Electromagnetic Compatibility Regulations 1992 (SI 1992:2372) says: An EC declaration of conformity to which this regulation applies shall- (a) be in English; (b) give the name and address- (i) of the responsible person; (ii) where that person is not the manufacturer, of the manufacturer; which I took to mean that both the manufacturer and their authorised representative should sign where the manufacturer is not resident in the EU. Rgds Nick. At 16:55 + 7/11/02, John Allen wrote: Hi Folks Whilst investigating something else today, I came upon the Commission Guidance Notes for the implementation of the ATEX Directive : http://europa.eu.int/comm/enterprise/atex/guide/guide_en.pdf On Page 112 in reply to Question 13 (about something else), Case 1, 2nd paragraph, states the following: The EC declaration of conformity and the application of the CE marking may be effected either by the manufacturer or his authorised representative, but not by both. . Whilst this is ATEX-specific, I think it would appear reasonable to assume that the Commission takes a similar line with the other CE Marking directives. The document does also contain more background and explanatory information on this point and the Directive in general. Regards John Allen _ This e-mail has been scanned for viruses by the WorldCom Internet Managed Scanning Service - powered by MessageLabs. For further information visit http://www.worldcom.com * Copyright ERA Technology Ltd. 2002. (www.era.co.uk). All rights reserved. The information supplied in this Commercial Communication should be treated in confidence. No liability whatsoever is accepted for any loss or damage suffered as a result of accessing this message or any attachments. _ This e-mail has been scanned for viruses by the WorldCom Internet Managed Scanning Service - powered by MessageLabs. For further information visit http://www.worldcom.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: EU DoC - ATEX Examples
Hi Folks In response to John's comment/question, the answer could well be that the Commission and it's national enforcing authorities do not want to be faced with the possibility of having chase 2(or even 3 or more under a multiple branding situation) companies over a non-compliance/safety situation. Thus - as far as Directives compliance is concerned - they want only 1 company to take the responsibility for each product. Regards John Allen Technical Consultant Electromagnetics, Safety and Reliability Group ERA Technology Ltd Cleeve Rd Leatherhead Surrey KT22 7SA Tel:+44 (0) 1372-367025 (Direct) +44 (0) 1372-367000 (Switchboard) Fax:+44 (0) 1372-367102 (Fax) -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 07 November 2002 20:37 To: emc-p...@majordomo.ieee.org Subject: EU DoC - ATEX Examples I read in !emc-pstc that John Allen john.al...@era.co.uk wrote (in BFE68AB0084CD311B4FB00508B014C8703CF9CD2@MERCURY) about 'EU DoC - ATEX Examples' on Thu, 7 Nov 2002: The EC declaration of conformity and the application of the CE marking may be effected either by the manufacturer or his authorised representative, but not by both. . Whilst this is ATEX-specific, I think it would appear reasonable to assume that the Commission takes a similar line with the other CE Marking directives. Can you think of any justification at all for *banning* 'effecting' by both? It seems not sensible to me. I doubt that they would both WANT to do it, but that is beside the point. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list _ This e-mail has been scanned for viruses by the WorldCom Internet Managed Scanning Service - powered by MessageLabs. For further information visit http://www.worldcom.com * Copyright ERA Technology Ltd. 2002. (www.era.co.uk). All rights reserved. The information supplied in this Commercial Communication should be treated in confidence. No liability whatsoever is accepted for any loss or damage suffered as a result of accessing this message or any attachments. _ This e-mail has been scanned for viruses by the WorldCom Internet Managed Scanning Service - powered by MessageLabs. For further information visit http://www.worldcom.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: EU DoC
I read in !emc-pstc that Nick Williams nick.willi...@conformance.co.uk wrote (in v04220803b9f0904184ca@[192.168.1.50]) about 'EU DoC' on Thu, 7 Nov 2002: ...but for an alternative view, Regulation 40 (2) of the UK's The Electromagnetic Compatibility Regulations 1992 (SI 1992:2372) says: An EC declaration of conformity to which this regulation applies shall- (a) be in English; (b) give the name and address- (i) of the responsible person; (ii) where that person is not the manufacturer, of the manufacturer; which I took to mean that both the manufacturer and their authorised representative should sign where the manufacturer is not resident in the EU. That text doesn't say that *anyone* must sign! People based in UK have to comply with the above, but other people need only comply with the somewhat different approach indicated in the Guidelines and Directives. The UK Regulations were written before the Commission was asked about OEM supply and other less simple cases, and have not been revised. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: EU DoC
...but for an alternative view, Regulation 40 (2) of the UK's The Electromagnetic Compatibility Regulations 1992 (SI 1992:2372) says: An EC declaration of conformity to which this regulation applies shall- (a) be in English; (b) give the name and address- (i) of the responsible person; (ii) where that person is not the manufacturer, of the manufacturer; which I took to mean that both the manufacturer and their authorised representative should sign where the manufacturer is not resident in the EU. Rgds Nick. At 16:55 + 7/11/02, John Allen wrote: Hi Folks Whilst investigating something else today, I came upon the Commission Guidance Notes for the implementation of the ATEX Directive : http://europa.eu.int/comm/enterprise/atex/guide/guide_en.pdf On Page 112 in reply to Question 13 (about something else), Case 1, 2nd paragraph, states the following: The EC declaration of conformity and the application of the CE marking may be effected either by the manufacturer or his authorised representative, but not by both. . Whilst this is ATEX-specific, I think it would appear reasonable to assume that the Commission takes a similar line with the other CE Marking directives. The document does also contain more background and explanatory information on this point and the Directive in general. Regards John Allen --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
EU DoC - ATEX Examples
I read in !emc-pstc that John Allen john.al...@era.co.uk wrote (in BFE68AB0084CD311B4FB00508B014C8703CF9CD2@MERCURY) about 'EU DoC - ATEX Examples' on Thu, 7 Nov 2002: The EC declaration of conformity and the application of the CE marking may be effected either by the manufacturer or his authorised representative, but not by both. . Whilst this is ATEX-specific, I think it would appear reasonable to assume that the Commission takes a similar line with the other CE Marking directives. Can you think of any justification at all for *banning* 'effecting' by both? It seems not sensible to me. I doubt that they would both WANT to do it, but that is beside the point. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: EU DoC - ATEX Examples
Hi Folks Whilst investigating something else today, I came upon the Commission Guidance Notes for the implementation of the ATEX Directive : http://europa.eu.int/comm/enterprise/atex/guide/guide_en.pdf On Page 112 in reply to Question 13 (about something else), Case 1, 2nd paragraph, states the following: The EC declaration of conformity and the application of the CE marking may be effected either by the manufacturer or his authorised representative, but not by both. . Whilst this is ATEX-specific, I think it would appear reasonable to assume that the Commission takes a similar line with the other CE Marking directives. The document does also contain more background and explanatory information on this point and the Directive in general. Regards John Allen Technical Consultant Electromagnetics, Safety and Reliability Group ERA Technology Ltd Cleeve Rd Leatherhead Surrey KT22 7SA Tel:+44 (0) 1372-367025 (Direct) +44 (0) 1372-367000 (Switchboard) Fax:+44 (0) 1372-367102 (Fax) -Original Message- From: Chris Allen [mailto:chris_al...@eur.3com.com] Sent: 07 November 2002 07:34 To: richwo...@tycoint.com Cc: emc-p...@majordomo.ieee.org Subject: Re: EU DoC Company B should raise a DoC to sell the item under it's own brand name. However, company B should obtain a DoC issued by company A for it's own good. Chris. richwo...@tycoint.com on 06/11/2002 18:22:08 Please respond to richwo...@tycoint.com Sent by: richwo...@tycoint.com To: emc-p...@majordomo.ieee.org cc:(Chris Allen/GB/3Com) Subject: EU DoC Company A builds a device for company B which sells the device in the EU under their own brand name. The device is subject to a Declaration of Conformity, and both companies are located within the EU. Must both companies issue a Declaration? Richard Woods Sensormatic Electronics Tyco International --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: EU DoC
Greg I think your statement needs some clarification. Even if it is produced by Company A, the DoC must clearly state the name and model number of the Company B which sells the product in question in the EU, so that the document is clearly and specifically associated with that product as sold in the EU.. I agree. The authorities have to be able to tie the product to the DoC. I was going to go into that, but it seems like it would stand to reason. Therefore I believe that many of the former would prefer to produce their own DoCs which made no mention of Company A - which should be OK as the Company B's are legally required to hold the supporting technical files/documentation prepared by Company A. Agreed again. From the standpoint of the authorities, it's probably better that company B issues the DoC. However, from the standpoint of company B, who may not have as much control over production QC as they'd like, a declaration issued by Company A might be preferable. I've seen joint declarat ions, also, although I don't know what the Commission thinks about that. Greg Galluccio www.productapprovals.com
Re: EU DoC
In a message dated 11/6/02 4:42:04 PM Eastern Standard Time, gui...@cae.com writes: For the European law, company B is considered as manufacturer and shall issue the DoC. No point company A issues its own DoC. I don't think that's entirely correct. I think it depends on the relationship between A and B. Greg Galluccio www.productapprovals.com
Re: EU DoC
Greg I think your statement needs some clarification. Even if it is produced by Company A, the DoC must clearly state the name and model number of the Company B which sells the product in question in the EU, so that the document is clearly and specifically associated with that product as sold in the EU.. By comparison, if it were only to reference only the brand name and model number of Company A, the document would have no obvious relationship to the markings on the product itself. This would not go down well with inspecting authorities such as UK Trading Standards Officers, who could reasonably argue that the DoC - and thus the CE Marking - was of dubious provenance. Furthermore, I think that some Company B's might be somewhat unhappy from a marketing perspective to offer DoCs which clearly show that the product was manufactured by someone else (Company A) - and if multiple Company B's sell exactly the same product from Company A (especially if they charge different prices for it!). Therefore I believe that many of the former would prefer to produce their own DoCs which made no mention of Company A - which should be OK as the Company B's are legally required to hold the supporting technical files/documentation prepared by Company A. Regards John Allen Technical Consultant Electromagnetics, Safety and Reliability Group ERA Technology Ltd Cleeve Rd Leatherhead Surrey KT22 7SA Tel: +44 (0) 1372-367025 (Direct) +44 (0) 1372-367000 (Switchboard) Fax: +44 (0) 1372-367102 (Fax) (sent from my home email address) - Original Message - From: soundsu...@aol.com To: emc-p...@majordomo.ieee.org Sent: Wednesday, November 06, 2002 7:10 PM Subject: Re: EU DoC Company A builds a device for company B which sells the device in the EU under their own brand name. The device is subject to a Declaration of Conformity, and both companies are located within the EU. Must both companies issue a Declaration? No. A declaration from either company will suffice. Greg Galluccio www.productapprovals.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: EU DoC
For the European law, company B is considered as manufacturer and shall issue the DoC. No point company A issues its own DoC. The text of the EMC Directive reads the manufacturer may subcontract certain operations, e.g., apparatus design or production, provided that he retains overall control and responsibility for the apparatus as a whole. By the same token, he may use ready-made items or components, CE marked or not, to produce the apparatus without losing his status as a manufacturer. There are two ways company B ensures compliance with EU Directives: 1. Company B shall request from company A all necessary proof of compliance with the relevant standards. 2. Company B qualifies the product and prepares supporting documentation. Company B will do QA, audits and inspections at company A to ensure consistency of all products with the test sample(s). Alexandru Guidea CAE Inc. Montreal, CANADA -Original Message- From: richwo...@tycoint.com [mailto:richwo...@tycoint.com] Sent: Wednesday, November 06, 2002 1:22 PM To: emc-p...@majordomo.ieee.org Subject: EU DoC Company A builds a device for company B which sells the device in the EU under their own brand name. The device is subject to a Declaration of Conformity, and both companies are located within the EU. Must both companies issue a Declaration? Richard Woods Sensormatic Electronics Tyco International --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: EU DoC
I read in !emc-pstc that richwo...@tycoint.com wrote (in 846BF526A205F8 4BA2B6045BBF7E9A6A0467594A@flbocexu05) about 'EU DoC' on Wed, 6 Nov 2002: Company A builds a device for company B which sells the device in the EU under their own brand name. The device is subject to a Declaration of Conformity, and both companies are located within the EU. Must both companies issue a Declaration? Only if both put it on the market. But if A does not market it, B would be well advised to insist contractually on what is effectively a DOC being supplied by A. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: EU DoC
Rich, Since company B puts the device into service under their own brand name, they are the only ones that need to hold the DoC.] Best Regards, Peter Merguerian -Original Message- From: richwo...@tycoint.com To: emc-p...@majordomo.ieee.org Sent: 11/6/02 8:22 PM Subject: EU DoC Company A builds a device for company B which sells the device in the EU under their own brand name. The device is subject to a Declaration of Conformity, and both companies are located within the EU. Must both companies issue a Declaration? Richard Woods Sensormatic Electronics Tyco International --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
Re: EU DoC
Company A builds a device for company B which sells the device in the EU under their own brand name. The device is subject to a Declaration of Conformity, and both companies are located within the EU. Must both companies issue a Declaration? No. A declaration from either company will suffice. Greg Galluccio www.productapprovals.com --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
EU DoC
Company A builds a device for company B which sells the device in the EU under their own brand name. The device is subject to a Declaration of Conformity, and both companies are located within the EU. Must both companies issue a Declaration? Richard Woods Sensormatic Electronics Tyco International --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on browse and then emc-pstc mailing list
RE: EU DoC
I would say that you have to list the amendments. For instance some of our products currently comply with EN55013:1990 + A12 + A13 and this is stated on the DoC. I am currently re-testing these products to include A14:1999. I will re-issue the DoCs stating this. If I just stated EN55013:1990 on the DoC, there would be no way of knowing which version of the standard the products complied with unless the test documentation was referred to. Hardly precise, compete and clearly defined? Just my humble opinion. Chris -Original Message- From: wo...@sensormatic.com [SMTP:wo...@sensormatic.com] Sent: 19 October 2000 15:01 To: emc-p...@majordomo.ieee.org Subject: EU DoC EN 45014:1998 specifies the General criteria for supplier's declaration of conformity. Concerning the identification of standards, the document says the DoC shall contain the referenced normative documents in a precise, complete and clearly defined way . . . The example of a DoC in Annex A lists the document number, title and edition/date of issue. Thus, it appears that EN60950 is not precise, complete and clearly defined since there is a 1992 and a 2000 version. Does EN60950:1992 meet the criteria or is necessary to list the applied amendments? e.g., EN60950:1992 + A1 + A2 + A3 + A4 I require the latter in DoCs from my OEM suppliers so I will know that they are up to date, but I am not clear on just what is sufficient from a legal point of view. Richard Woods --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org ** Please visit us at www.tagmclarenaudio.com ** The contents of this E-mail are confidential and for the exclusive use of the intended recipient. If you receive this E-mail in error, please delete it from your system immediately and notify us either by E-mail, telephone or fax. You should not copy, forward or otherwise disclose the content of the E-mail. TAG McLaren Audio Ltd The Summit, 11 Latham Road Huntingdon, Cambs, PE29 6ZU Telephone : 01480 415600 (+44 1480 415600) Facsimile : 01480 52159 (+44 1480 52159) ** Please visit us at www.tagmclarenaudio.com ** --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
EU DoC
EN 45014:1998 specifies the General criteria for supplier's declaration of conformity. Concerning the identification of standards, the document says the DoC shall contain the referenced normative documents in a precise, complete and clearly defined way . . . The example of a DoC in Annex A lists the document number, title and edition/date of issue. Thus, it appears that EN60950 is not precise, complete and clearly defined since there is a 1992 and a 2000 version. Does EN60950:1992 meet the criteria or is necessary to list the applied amendments? e.g., EN60950:1992 + A1 + A2 + A3 + A4 I require the latter in DoCs from my OEM suppliers so I will know that they are up to date, but I am not clear on just what is sufficient from a legal point of view. Richard Woods --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Re: EU DoC
Phil Ford wrote: Jim Nadolny wrote I was told that the responsible person must be a resident of the EU. A company in the States could not self certify and place the CE mark on equipment with only the head of quality signature, assuming the head of quality lives in Anytown USA. I also heard that less than reputable companies in the States find some European guy who will sign anything and can vanish if the need arises. Article 10 of the EMC Directive states: 1. ...shall be certified by an EC declaration of conformity issued by the manufacturer or his authorised representative established within the Community. ... Where neither the manufacturer nor his authorised representative is established within the Community, the above obligation to keep the EC declaration of conformity available shall be the responsibility of the person who places the apparatus on the Community market. The same requirements are then applied to the Technical Construction File. Unless there is something else I have missed, the manufacturer, his authorised representative and the person who keeps the DoC could all be resident outside the EU. -- Regards, Phil Ford phil_f...@uk.xyratex.com tel +44 (0)1705 443255fax +44 (0)1705 499315 Xyratex, Langstone Road, Havant, PO9 1SA, United Kingdom Sorry Phil, but I have learned in a seminar for Product Safety at the Leuven University in Belgium by some expert Professors for European Rights that the responsible company or person must be a resident of one of the EU member states. This is stated by the term established within the Community. If there is no company involved for the import of the good into the EU, it is the person who brings the good to the EU - be it on his/her own benefit. The company/person/authorized representative, or whoever imports the good into the EU must be residing within the EU. -- Kind regards/mit freundlichen Gruessen, Horst Dierich, Germany EMAIL: dier...@ibm.net
EU DoC
Horst Dierich wrote: Sorry Phil, but I have learned in a seminar for Product Safety at the Leuven University in Belgium by some expert Professors for European Rights that the responsible company or person must be a resident of one of the EU member states. This is stated by the term established within the Community. Horst, I think, in practical terms, you are quite right. There will usually be a person or commercial body established within the EU who puts the product on the market. This person or body will be responsible for the DoC or the TCF. However, the text of the Directive does allow that neither the manufacturer nor his authorised representative is established within the Community. What then would be the status of an individual importing a product for personal use and not placing the apparatus on the Community market? The Directive does not appear to say much about this situation (probably rightly so). -- Regards, Phil Ford phil_f...@uk.xyratex.com tel +44 (0)1705 443255fax +44 (0)1705 499315 Xyratex, Langstone Road, Havant, PO9 1SA, United Kingdom
EU DoC
Jim Nadolny wrote I was told that the responsible person must be a resident of the EU. A company in the States could not self certify and place the CE mark on equipment with only the head of quality signature, assuming the head of quality lives in Anytown USA. I also heard that less than reputable companies in the States find some European guy who will sign anything and can vanish if the need arises. Article 10 of the EMC Directive states: 1. ...shall be certified by an EC declaration of conformity issued by the manufacturer or his authorised representative established within the Community. ... Where neither the manufacturer nor his authorised representative is established within the Community, the above obligation to keep the EC declaration of conformity available shall be the responsibility of the person who places the apparatus on the Community market. The same requirements are then applied to the Technical Construction File. Unless there is something else I have missed, the manufacturer, his authorised representative and the person who keeps the DoC could all be resident outside the EU. -- Regards, Phil Ford phil_f...@uk.xyratex.com tel +44 (0)1705 443255fax +44 (0)1705 499315 Xyratex, Langstone Road, Havant, PO9 1SA, United Kingdom
