RE: New Approach Directives and DOA and DOW
I'm not going to disagree with Neil's approach (indeed I endorse it), but I would observe that the Construction Products Directive (CPD) is different to the other New Approach Directives in this (and many other!) respects, in that CE marking is not possible for products within the scope of the Directive until a Harmonised standard has been published. It is not possible to CE mark against the Essential Requirements of the CPD since these apply to the buildings into which the product is integrated, not the product itself. The European Commission has decided, for all CPD harmonised standards, that there will be a period of 9 months from the Date of Availability of the standard, before CE marking can commence. This is in order to allow governments, trading standards, notified bodies, test labs and manufacturers etc,, to prepare for the big event. Thus even if the Harmonised Standard is available and you can test to it now, you are not permitted to apply the CE marking until after the date published by the Commission in the Official Journal. The CPD is a mess, and certainly has done nothing to promote a free market in construction products for more than ten years now. The Commission has allowed the whole of this market sector to be hijacked by people whose primary business interest is in conformity assessment and as a result manufacturers of CPs will gain nothing like the market freedom offered by (i.a.) the LVD or Machinery Directives. Nick. At 10:13 +0100 11/6/03, Barker, Neil wrote: I would agree with you. Providing that the CPD has been enacted in the law of the Member State in which you wish to market your product, and that appropriate routes to compliance are available, then it should be your decision to take that route to market in preference to the former national system. You could take issue with the responsible government agency concerning the actions of their Notified Body, but remembering that you are at liberty to use any NB in the EU, I would simply go elsewhere. You don't have to use a NB in the destination country. Best regards, Neil R. Barker Compliance Engineering Manager e2v technologies ltd Waterhouse Lane Chelmsford Essex CM1 2QU U.K. Tel: +44 (01245) 453616 Fax: +44 (01245) 453410 E-mail: neil.bar...@e2vtechnologies.com -Original Message- From: Kevin Harris [mailto:kevinharr...@dsc.com] Sent: 10 June 2003 16:00 To: EMC-PSTC (E-mail) Subject: New Approach Directives and DOA and DOW Hello Group, I've just been told a story by a notified body under the Construction Products Directive in Europe that as far as they were concerned, despite the fact that a standard was published in the OJ and it's DOA has already passed that they were under no obligation to accept that standard or indeed follow the CPD at all until the DOW (removing their national standard) had passed. In this case, the notified body under the CPD is the same agency that currently is their notified body under their national system. I have always presumed that the choice of systems to follow in the transition time between DOA and DOW was the manufacturer's and not the notified body's. Comments? Best Regards, Kevin Harris Manager, Approvals and CAD Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: kevinharr...@dsc.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: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
RE: New Approach Directives and DOA and DOW
I would agree with you. Providing that the CPD has been enacted in the law of the Member State in which you wish to market your product, and that appropriate routes to compliance are available, then it should be your decision to take that route to market in preference to the former national system. You could take issue with the responsible government agency concerning the actions of their Notified Body, but remembering that you are at liberty to use any NB in the EU, I would simply go elsewhere. You don't have to use a NB in the destination country. Best regards, Neil R. Barker Compliance Engineering Manager e2v technologies ltd Waterhouse Lane Chelmsford Essex CM1 2QU U.K. Tel: +44 (01245) 453616 Fax: +44 (01245) 453410 E-mail: neil.bar...@e2vtechnologies.com -Original Message- From: Kevin Harris [mailto:kevinharr...@dsc.com] Sent: 10 June 2003 16:00 To: EMC-PSTC (E-mail) Subject: New Approach Directives and DOA and DOW Hello Group, I've just been told a story by a notified body under the Construction Products Directive in Europe that as far as they were concerned, despite the fact that a standard was published in the OJ and it's DOA has already passed that they were under no obligation to accept that standard or indeed follow the CPD at all until the DOW (removing their national standard) had passed. In this case, the notified body under the CPD is the same agency that currently is their notified body under their national system. I have always presumed that the choice of systems to follow in the transition time between DOA and DOW was the manufacturer's and not the notified body's. Comments? Best Regards, Kevin Harris Manager, Approvals and CAD Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: kevinharr...@dsc.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: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
New Approach Directives and DOA and DOW
Hello Group, I've just been told a story by a notified body under the Construction Products Directive in Europe that as far as they were concerned, despite the fact that a standard was published in the OJ and it's DOA has already passed that they were under no obligation to accept that standard or indeed follow the CPD at all until the DOW (removing their national standard) had passed. In this case, the notified body under the CPD is the same agency that currently is their notified body under their national system. I have always presumed that the choice of systems to follow in the transition time between DOA and DOW was the manufacturer's and not the notified body's. Comments? Best Regards, Kevin Harris Manager, Approvals and CAD Services Digital Security Controls 3301 Langstaff Road Concord, Ontario CANADA L4K 4L2 Tel: +1 905 760 3000 Ext. 2378 Fax +1 905 760 3020 Email: kevinharr...@dsc.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: emc_p...@symbol.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org Archive is being moved, we will announce when it is back on-line. All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
