Re: [PSES] One DoC per manufactured Unit?!

2013-01-15 Thread Pete Perkins
Lauren et al, Thanx to Lauren and the others who are advocating for reasonableness in these requirements. From the foreigh manufacturer's point of view I believe that it is important to keep from getting tied up in knots too soon. 'No unreasonable requirement should be

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread ce-test, qualified testing bv - Gert Gremmen
The new DoC concept for the LVD says in COM2011-0773 (referring to 768/2008) ANNEX IV [Annex III of Decision No 768/2008/EC] EU DECLARATION OF CONFORMITY 1. No xx (unique identification of the electric equipment): 2. Name and address of the manufacturer or

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread Peter_Kelleher
COM(2011)773 final is the proposal from the Commission to the Council and Parliament. It does not represent a final draft of the directive. This and proposals for other directives are currently under discussion between all three institutions of the EU and are subject to further modifications

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread Kunde, Brian
I agree with John. We went through this when the new Machinery Directive came out a few years back. The directive itself only said, description and identification of the machinery, including generic denomination, function, model, type, serial number and commercial name;, but the guide said, As

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread John Woodgate
In message 64D32EE8B9CBDD44963ACB076A5F6ABB0262C6D0@Mailbox-Tech.lecotech.local, dated Mon, 14 Jan 2013, Kunde, Brian brian_ku...@lecotc.com writes: As far as the color picture, well, that?s just stupid. Why not ask for a hologram of the product? A fully working full-size model would be

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread ce-test, qualified testing bv - Gert Gremmen
You can make fun of it, but all these things have been introduced with the goal of creating a better level playing field, thus making possible to find, an pursue those manufacturers that spoil the market by selling untested, possible unsafe cheap rubbish. Customs are better able to simply stop

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread John Cotman
The Toy Safety Directive already has the picture requirement on the D of C. John C -Original Message- From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] Sent: 14 January 2013 14:37 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] One DoC per manufactured

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread John Woodgate
In message FCA549BE3ECF9D4CB8CB8576837EA489140C40@ZEUS.cetest.local, dated Mon, 14 Jan 2013, ce-test, qualified testing bv - Gert Gremmen g.grem...@cetest.nl writes: You can make fun of it, but all these things have been introduced with the goal of creating a better level playing field, thus

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread Crane, Lauren
Thanks John and all for your comments. There is a persistent problem knitted into this issue regarding the meaning of 'product'. Most inquiries to the Commission tend to end up clarifying that 'product' means a particular unit and not a model line or type. This is particularly true when

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread Michael Derby
. Michael Derby Regulatory Engineer ACB Europe -Original Message- From: John Cotman [mailto:john.cot...@conformance.co.uk] Sent: 14 January 2013 16:37 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] One DoC per manufactured Unit?! The Toy Safety Directive already has the picture requirement

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread John Woodgate
In message 021c01cdf279$f5b33720$e119a560$@acbcert.com, dated Mon, 14 Jan 2013, Michael Derby micha...@acbcert.com writes: I believe one of the situations that arises from the NLF is that the requirements of each Directive are being harmonised. This often means looking at all the Directives,

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread John Woodgate
In message sij2yahm4d9qf...@jmwa.demon.co.uk, dated Mon, 14 Jan 2013, John Woodgate j...@jmwa.demon.co.uk writes: n message 021c01cdf279$f5b33720$e119a560$@acbcert.com, dated Mon, 14 Jan 2013, Michael Derby micha...@acbcert.com writes: I believe one of the situations that arises from the NLF

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread Tyra, John
Thanks Lauren, I appreciate your insight as it is always tricky business interpreting what the regulator's intended when they wrote the Directives. Hopefully this is not what the powers that be intended because, as John pointed out, it is easier and less expensive to create paperwork then it

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread Crane, Lauren
John, I share your hope. I have the fortunate experience of doing some policy advocacy on RoHS2 and WEEE2 face to face with members of Parliament and Council and I very quickly learned that law makers do not have any obligation to understand in depth the industry/ies they may be impacting.

Re: [PSES] One DoC per manufactured Unit?!

2013-01-14 Thread John Woodgate
In message 617eb8c8634c9149aa66c853d7b8ac53d...@by2prd0310mb389.namprd03.prod.outlo ok.com, dated Mon, 14 Jan 2013, Crane, Lauren lauren.cr...@kla-tencor.com writes: I very quickly learned that law makers do not have any obligation to understand in depth the industry/ies they may be

Re: [PSES] One DoC per manufactured Unit?!

2013-01-13 Thread Tyra, John
I don't know Lauren, I read COM(2011) 773 final and NLF Council Decision 768/2008 and I interpret it to mean you need a unique model number which can be cross referenced with the TCF reports for that model. I am not seeing where it requires each unit to have a unique ID# listed on the DoC which

Re: [PSES] One DoC per manufactured Unit?!

2013-01-10 Thread John Woodgate
In message 617eb8c8634c9149aa66c853d7b8ac53b...@by2prd0310mb389.namprd03.prod.outlo ok.com, dated Wed, 9 Jan 2013, Crane, Lauren lauren.cr...@kla-tencor.com writes: Does anyone reading have any additional perspective on this battle? Will a ?model line? DoC be possible in the future?

[PSES] One DoC per manufactured Unit?!

2013-01-09 Thread Crane, Lauren
As many know, the LVD is in the process of being recast for alignment with the New Legislative Framework (NLF). The Commission proposed text, (COM(2011) 773 final), calls for what looks like a unique equipment identification number do be provided in the Declaration of Conformity (DoC). The