Dear Experts, I am looking for help in understanding how to correctly address 
LVD concerns within the RTTED.

The RTTED has three main concerns (essential requirements),

1.       Radio spectrum issues [art. 3.2]

2.       Low voltage safety [art. 3.1.a] - LVD

3.       Electromagnetic compatibility [art. 3.1.b] - EMCD

EU guidance says each of these concerns may be addressed separately. [Csion 
guide Apr 2009 6.1 first para]

The low voltage directive (LVD)  as a stand alone requirement, doesn't apply 
until DC input voltages reach 75V, but the RTTED requires the LVD to apply 
regardless of voltage [art. 3.1.a -end]. RTTED also says that the conformity 
assessment procedures of the LVD may be used where the item is within scope of 
the LVD (e.g., electrical equipment operating from 80VDC) [art. 10.2].  If a 
product is not within scope of the LVD on its own (e.g., operating from 12 
VDC), one must use the conformity assessment procedures defined in the RTTED (I 
think).

In the RTTED the only assessment procedure that does not require a notified 
body is 'production control' (Annex II).   The Production Control method (Annex 
II) is *not* allowed for equipment with radio transmitters [art. 10.3,4,5].

So if I have a very low voltage device (e.g. 12 volts) with a data transmission 
function I must, at first glance, use RTTED conformity assessment methods (and 
thereby a Notified Body), to assess the LVD concerns.

I have already had my widget assessed for radio spectrum issues and EMC issues 
by Notified Bodies.  It looks like I need a notified body for the LVD stuff 
too. If the voltages were higher, I could self declare LVD compliance. This 
does not make sense. What am I misunderstanding?

Regards,
Lauren Crane
KLA-Tencor


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