Dear Group,
Some correction is needed here. Notified body involvement is mandatory when harmonized standards can not be used or are not available for the equipment at hand. Or if the manufacturer wants to use its own testing routine. In all these cases the NB needs to assess the equipment against the essential requirements (annex IV). Self declaration is only allowed if all applicable harmonized standards are being (fully) followed. Kind regards, Willem Jan Jong Manager Product Certification Telefication From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of ce-test, qualified testing bv - Gert Gremmen Sent: zaterdag, 22 juni, 2013 4:20 PM To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Is a Notified Body really needed to assess electrical safety for a 12VDC RTTE device? Hi Lauren, As far as my understanding goes, without any further study regarding your arguments, I remember that for NO RTTED equipment a NoBo is mandatory. Said differently, the intention of the RTTED has always been (and I was always learned ) that the manufacturers declaration is sufficient for all. NoBo's are mandatory for some machines, medical equipment class 2 and higher and a number of other directives that cover high risk equipment. The same is true for the EMCD and the LVD. In general the tendency in Europe is to reduce the role of the NoBo's. The fault you make in my view, is that you state that the product is not in the scope of the LVD (12V), so you need to apply annex III, IV or V (instead of II, IV or V), but as the voltage requirement is removed, all equipment falls in the (modified) LVD scope. In my experience most equipment is assessed as office equipment (EN 60950) Hope this helps... Regards, Ing. Gert Gremmen, BSc g.grem...@cetest.nl www.cetest.nl Kiotoweg 363 3047 BG Rotterdam T 31(0)104152426 F 31(0)104154953 Before printing, think about the environment. Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Crane, Lauren Verzonden: Friday, June 21, 2013 11:59 PM Aan: EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: Is a Notified Body really needed to assess electrical safety for a 12VDC RTTE device? 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 - ---------------------------------------------------------------- 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...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
