Re: [PSES] RED and "putting on the market"

[Scott Xe]

Interesting point/view on point 4.  Will it happen in stores that all radio 
products comply with RED on 13 June 2017 or did similar case of LVD and EMC 
happen last year?  No sale of radio products complied with R will be 
continued 13 June 2017.

 

Scott

 

 

 

From: Monrad Monsen 
Reply-To: Monrad Monsen 
Date: Saturday, 4 February 2017 at 2:10 AM
To: 
Subject: Re: [PSES] RED and "putting on the market"

 

Hi Mike,

I urge you to read section 2 of the Blue Guide which can be downloaded at the 
below web address:

http://ec.europa.eu/DocsRoom/documents/18027 

 

Regarding your specific question …

> For the purpose of products manufactured outside of 

> the EU, is "put on the market" equivalent to being 

> physically brought into the EU?

Blue Guide section 2.3 states “A product is placed on the market when it is 
made available for the first time on the Union market.”

Therefore, the “made available” definition is important as well, so I will cite 
in my answer some sections from that definition as well. Besides, the RED 
directive requires that “radio equipment” comply with the directive both when 
made available (RED article 6) and put into service (RED article 7).

 

1.  Mere entry of a product into the EU territory does not automatically 
trigger “make available” or “put into service” definitions.  

Blue Guide section 2.2 states “Supplying a product is only considered as making 
available on the Union market, when the product is intended for end use on the 
Union market.”  For example, a server product can enter for a 
value-added-reseller (VAR) or value-added-distributor (VAD) to install it into 
a rack along with disk arrays and Ethernet switches to create an integrated 
solution that might be intended for sale to end-user customers outside of 
Europe.  The mere entry of the server into Europe does not trigger a CE mark 
requirement.  Of course, it would be important that the shipping documentation 
make the intended use clear to answer questions and avoid delays through 
customs.

 

2.  A product is “made available” when supplied for distribution, consumption 
or use within the European Union market. This is true even if donated free of 
charge.  In fact, it is true even if the product is merely loaned but product 
ownership is not transferred to the end user.

Blue Guide section 2.2 states: “A product is made available on the market when 
supplied for distribution, consumption or use on the Union market in the course 
of a commercial activity, whether in return for payment or free of charge.”

Also, section 2.2 states: “Thus, a transfer of a product is considered to have 
taken place, for instance, in the circumstances of sale, loan, hire, leasing 
and gift. Transfer of ownership implies that the product is intended to be 
placed at the disposal of another legal or natural person.”

 

3.  The trigger of “made available” and “placed on the market” can occur even 
before the product physically reaches the market territory – triggered by the 
advertizing campaigns, etc.

Blue Guide section 2.2 states: “Such supply includes any offer for 
distribution, consumption or use on the Union market which could result in 
actual supply (e.g. an invitation to purchase, advertising campaigns).”

Also, section 2.3 states: “Products offered for sale online by sellers based 
outside the EU are considered to be placed on the Union market if sales are 
specifically targeted at EU consumers or other end-users.”

 

4.  One may not create a huge stock-pile of products within a warehouse in 
Europe before a standard’s implementation deadline (like RED on 12 June 2017) 
and then trickle sales to end user European customers after the deadline.

Blue Guide section 2.5 states: “Putting into service takes place at the moment 
of first use within the Union by the end user for the purposes for which it was 
intended.”  This occurs when the product (per serial number) is placed in 
possession of the end user customer and the customer actually puts the product 
into service.  On the date that the product is put into service and use, the 
product must meet the European Union rules in effect on that date.

 

Hope this helps.

Monrad

DISCLAIMER:  Everything written in my email are my own opinions and are not 
necessarily those of any company for which I work.

From: Mike Sherman - Original Message - [mailto:msherma...@comcast.net] 
Sent: Thursday, February 02, 2017 9:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED and "putting on the market"

 

It is my understanding that products that are not RED compliant but are RTTE 
compliant can be "put on the market" through June 12, 2017.

 

For the purpose of products manufactured outside of the EU, is "put on the 
market" equivalent to being physically brought into the EU?

 

I'm asking this because it is evident that a number of the harmonized standards 
necessary for 

Re: [PSES] safety standard - mobile inverters ooops 61204-7

[Pete Perkins]

Ralph,  

Oooops...  my fumble fingers typo error...

Try IEC 61204-7, Low-voltage switch mode power supplies - Part 7: 
Safety requirements.  Ed 2 is just coming out; the FDIS was voted in last fall. 
  

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

p.perk...@ieee.org

-Original Message-
From: Ralph McDiarmid [mailto:ralph.mcdiar...@schneider-electric.com] 
Sent: Friday, February 3, 2017 8:54 AM
To: Pete Perkins 
Subject: RE: [PSES] safety standard - mobile inverters

Hi Pete,  the IEC webstore say this:

IEC 61207-7:2013 

Expression of performance of gas analyzers - Part 7: Tuneable semiconductor 
laser gas analyzers

?

Ralph McDiarmid
Product Compliance
Engineering
Solar Business
Schneider Electric


-Original Message-
From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] 
Sent: Thursday, February 02, 2017 8:08 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] safety standard - mobile inverters

Ralph, et al,

Thanx to Bostjan for this reference.  

IEC 62477-1 Safety requirements for power electronic converter systems 
and equipment - Part 1: General.  

Or

IEC 61207-7 Ed 2 (based upon 62477-1) Low-voltage switch mode power 
supplies - Part 7: Safety requirements (which had been based upon 60950 but has 
been redirected a 62477-1 basis).  This should better fit your product rather 
than the General requirements.   
 
If you are still considering 60950 you should focus on 62368 which is 
replacing the obsolescent requirements of 60950.  

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, 
ORe  97281-3427

503/452-1201

p.perk...@ieee.org

-Original Message-
From: Boštjan Glavič [mailto:bostjan.gla...@siq.si]
Sent: Thursday, February 2, 2017 1:45 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] safety standard - mobile inverters

What about IEC 62477-1: Safety requirements for power electronic converter 
systems and equipment - Part 1: General


With kind regards,
 
Boštjan Glavič
Head of Laboratory
Safety and Electromagnetics 
 
phone +386 1 4778 265
SIQ Ljubljana - Trzaska cesta 2 - 1000 Ljubljana - Slovenia - www.siq.si






From: Adam Dixon [mailto:lanterna.viri...@gmail.com]
Sent: Thursday, February 2, 2017 10:03 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] safety standard - mobile inverters

What about IEC 62109-2 with emphasis on standalone (i.e. not grid-connected)?
Regards,
Adam in Atlanta
adam.di...@ieee.org

IEC 62109-2:2011
Safety of power converters for use in photovoltaic power systems - Part 2: 
Particular requirements for inverters 

On Thu, Feb 2, 2017 at 2:31 AM, John Woodgate  wrote:
I don't think there is one. A search on the IEC web site shows IEC 
61204-7:2016, which is not about inverters but might be sufficiently applicable.

With best wishes DESIGN IT IN! OOO – Own Opinions Only www.jmwa.demon.co.uk J M 
Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

-Original Message-
From: Ralph McDiarmid [mailto:ralph.mcdiar...@schneider-electric.com]
Sent: Wednesday, February 1, 2017 7:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] safety standard - mobile inverters

Dear group,

I am looking for suggestions on best-fit product safety standard for LVD for a 
230V inverter intended for vehicular use only. (buses & small trucks)

Test lab suggests EN60950, which I dismissed.  EN50178 and EN60335-1 don’t 
appear to be suitable.  I’m really looking for an IEC equivalent to UL458


Thanks,

Ralph McDiarmid
Product Compliance
Engineering
Solar Business
Schneider Electric


-

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All emc-pstc postings are 

Re: [PSES] RED and "putting on the market"

[Monrad Monsen]

Hi Mike,

I urge you to read section 2 of the Blue Guide which can be downloaded at the 
below web address:

http://ec.europa.eu/DocsRoom/documents/18027 

 

Regarding your specific question …

> For the purpose of products manufactured outside of 

> the EU, is "put on the market" equivalent to being 

> physically brought into the EU?

Blue Guide section 2.3 states “A product is placed on the market when it is 
made available for the first time on the Union market.”

Therefore, the “made available” definition is important as well, so I will cite 
in my answer some sections from that definition as well. Besides, the RED 
directive requires that “radio equipment” comply with the directive both when 
made available (RED article 6) and put into service (RED article 7).

 

1.  Mere entry of a product into the EU territory does not automatically 
trigger “make available” or “put into service” definitions.  

Blue Guide section 2.2 states “Supplying a product is only considered as making 
available on the Union market, when the product is intended for end use on the 
Union market.”  For example, a server product can enter for a 
value-added-reseller (VAR) or value-added-distributor (VAD) to install it into 
a rack along with disk arrays and Ethernet switches to create an integrated 
solution that might be intended for sale to end-user customers outside of 
Europe.  The mere entry of the server into Europe does not trigger a CE mark 
requirement.  Of course, it would be important that the shipping documentation 
make the intended use clear to answer questions and avoid delays through 
customs.

 

2.  A product is “made available” when supplied for distribution, consumption 
or use within the European Union market. This is true even if donated free of 
charge.  In fact, it is true even if the product is merely loaned but product 
ownership is not transferred to the end user.

Blue Guide section 2.2 states: “A product is made available on the market when 
supplied for distribution, consumption or use on the Union market in the course 
of a commercial activity, whether in return for payment or free of charge.”

Also, section 2.2 states: “Thus, a transfer of a product is considered to have 
taken place, for instance, in the circumstances of sale, loan, hire, leasing 
and gift. Transfer of ownership implies that the product is intended to be 
placed at the disposal of another legal or natural person.”

 

3.  The trigger of “made available” and “placed on the market” can occur even 
before the product physically reaches the market territory – triggered by the 
advertizing campaigns, etc.

Blue Guide section 2.2 states: “Such supply includes any offer for 
distribution, consumption or use on the Union market which could result in 
actual supply (e.g. an invitation to purchase, advertising campaigns).”

Also, section 2.3 states: “Products offered for sale online by sellers based 
outside the EU are considered to be placed on the Union market if sales are 
specifically targeted at EU consumers or other end-users.”

 

4.  One may not create a huge stock-pile of products within a warehouse in 
Europe before a standard’s implementation deadline (like RED on 12 June 2017) 
and then trickle sales to end user European customers after the deadline.

Blue Guide section 2.5 states: “Putting into service takes place at the moment 
of first use within the Union by the end user for the purposes for which it was 
intended.”  This occurs when the product (per serial number) is placed in 
possession of the end user customer and the customer actually puts the product 
into service.  On the date that the product is put into service and use, the 
product must meet the European Union rules in effect on that date.

 

Hope this helps.

Monrad

DISCLAIMER:  Everything written in my email are my own opinions and are not 
necessarily those of any company for which I work.

From: Mike Sherman - Original Message - [mailto:msherma...@comcast.net] 
Sent: Thursday, February 02, 2017 9:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED and "putting on the market"

 

It is my understanding that products that are not RED compliant but are RTTE 
compliant can be "put on the market" through June 12, 2017.

 

For the purpose of products manufactured outside of the EU, is "put on the 
market" equivalent to being physically brought into the EU?

 

I'm asking this because it is evident that a number of the harmonized standards 
necessary for conformity assessment to the RED will not be published by June 
13, 2017, and Notified Bodies might not be able to handle the surge of that 
alternate path, so one obvious tactic for existing products would be to stock 
up RTTE compliant products within the EU until the RED requirements as detailed 
in the harmonized standards become more clear.

 

Mike Sherman

Graco Inc.

-


This message is from the IEEE Product Safety Engineering 

Re: [PSES] RED and "putting on the market"

[Scott Xe]

Hi Ted,

 

Mike’s suggestion is not uncommon.  Before any new directive/regulation become 
in force, the retailers/importers will stock some quantities before deadline to 
allow the manufacturers’ update to the new requirements and using up all old 
components.  Since the models are on sales before the implementation date and 
their warehouses have the stock, how can the current law restrict these 
activities?

 

Hi Mike,

 

The testing laboratories also encounter different challenge to update their 
accreditation meeting the new/draft version of harmonised standards.

 

Scott

 

 

 

From: Ted Eckert <07cf6ebeab9d-dmarc-requ...@ieee.org>
Reply-To: Ted Eckert 
Date: Friday, 3 February 2017 at 9:32 PM
To: 
Subject: Re: [PSES] RED and "putting on the market"

 

Hello Mike,

 

Sections 2.2 and 2.3 of the Blue Guide cover this subject. If a manufacturer 
brings products into the EU but still retains ownership and control, it does 
not necessarily constitute placing the products on the market. If an importer 
or distributor buys the product from the manufacturer either at the time the 
product is shipped into the EU or after that time, it likely would be 
considered as being placed on the market. Section 2.3 makes it clear that the 
product has not yet been placed on the market if a manufacturer brings a 
product into the EU and  places it into their own warehouse.

 

Sections 2.4 and 2.5 will give additional information useful in making the 
determination for your product. I recommend consulting an attorney with 
expertise in this area if your situation is unclear.

 

I believe the European Commission’s intention was to restrict a manufacturer’s 
ability to import large quantities of products prior to the implementation date 
of a regulation with the intention of selling them to the end user well after 
that date. However, this is my interpretation of the EC’s intent.

 

Ted Eckert

The opinions expressed are my own and do not necessarily reflect those of my 
employer or the European Commission.

 

From: Mike Sherman - Original Message - [mailto:msherma...@comcast.net] 
Sent: Thursday, February 2, 2017 8:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED and "putting on the market"

 

It is my understanding that products that are not RED compliant but are RTTE 
compliant can be "put on the market" through June 12, 2017.

 

For the purpose of products manufactured outside of the EU, is "put on the 
market" equivalent to being physically brought into the EU?

 

I'm asking this because it is evident that a number of the harmonized standards 
necessary for conformity assessment to the RED will not be published by June 
13, 2017, and Notified Bodies might not be able to handle the surge of that 
alternate path, so one obvious tactic for existing products would be to stock 
up RTTE compliant products within the EU until the RED requirements as detailed 
in the harmonized standards become more clear.

 

Mike Sherman

Graco Inc.

-


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  

-


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  


-

This message is from the IEEE Product Safety 

Re: [PSES] RED and "putting on the market"

[Ted Eckert]

Hello Mike,

Sections 2.2 and 2.3 of the Blue 
Guide cover this subject. If a 
manufacturer brings products into the EU but still retains ownership and 
control, it does not necessarily constitute placing the products on the market. 
If an importer or distributor buys the product from the manufacturer either at 
the time the product is shipped into the EU or after that time, it likely would 
be considered as being placed on the market. Section 2.3 makes it clear that 
the product has not yet been placed on the market if a manufacturer brings a 
product into the EU and  places it into their own warehouse.

Sections 2.4 and 2.5 will give additional information useful in making the 
determination for your product. I recommend consulting an attorney with 
expertise in this area if your situation is unclear.

I believe the European Commission’s intention was to restrict a manufacturer’s 
ability to import large quantities of products prior to the implementation date 
of a regulation with the intention of selling them to the end user well after 
that date. However, this is my interpretation of the EC’s intent.

Ted Eckert
The opinions expressed are my own and do not necessarily reflect those of my 
employer or the European Commission.

From: Mike Sherman - Original Message - [mailto:msherma...@comcast.net]
Sent: Thursday, February 2, 2017 8:17 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] RED and "putting on the market"

It is my understanding that products that are not RED compliant but are RTTE 
compliant can be "put on the market" through June 12, 2017.

For the purpose of products manufactured outside of the EU, is "put on the 
market" equivalent to being physically brought into the EU?

I'm asking this because it is evident that a number of the harmonized standards 
necessary for conformity assessment to the RED will not be published by June 
13, 2017, and Notified Bodies might not be able to handle the surge of that 
alternate path, so one obvious tactic for existing products would be to stock 
up RTTE compliant products within the EU until the RED requirements as detailed 
in the harmonized standards become more clear.

Mike Sherman
Graco Inc.
-


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 >

-

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] DoC when exempted from RED 2014/53/EU

[ce-test, qualified testing bv - Gert Gremmen]

It depends. If it costs money probably they will refrain or at least be 
reluctant and prefer
a warning in chinglish on page 97 note 21. 

Regards,

Ing. Gert Gremmen
Approvals manager



+ ce marking of electrical/electronic equipment
+ Independent Consultancy Services
+ Compliance Testing and Design for CE marking according to EC-directives:
  - Electro Magnetic Compatibility 2014/30/EC
- Electrical Safety 2014/35/EC
- Radio & Telecommunication Terminal Equipment 99/5/EC

Web:    www.cetest.nl  (English) www.ce-test.nl (Dutch) www.cetest.fr (under 
construction)
Phone :  +31 10 415 24 26
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This e-mail and any attachments thereto may contain information 
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Any use of the information contained herein (including, but not 
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Thank you for your co-operation.

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Thursday 2 February 2017 23:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] DoC when exempted from RED 2014/53/EU

Yes, manufacturers would be well advised to take precautions not to kill 
potential customers. Can we rely on them to do that?

With best wishes DESIGN IT IN! OOO - Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Pete Perkins [mailto:peperkin...@cs.com] 
Sent: Thursday, February 2, 2017 10:36 PM
To: 'John Woodgate' ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU

John, et al,  

   My point, which I believe that I made below, is that even for 
board kits which leave everything out in the open there are techniques to 
minimize the exposure problems since not all of the users are experienced or 
fully qualified to know the risks and keep themselves out of harm's way.  
   The manufacturer has the responsibility to provide a device that 
is easy to use in a 'safe' manner (the definition of which I have expanded to 
include EMC issues altho not technically safety per se).  
   It's not good enuf to hide behind 'we met all of the 
requirements' - which were mostly none.  

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

p.perk...@ieee.org

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Thursday, February 2, 2017 9:44 AM
To: 'Pete Perkins' ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU

I'm not quite sure of your point. The thread is about evaluation kits, which 
are very often just populated PC boards with I/O and power connectors. 
Everything is accessible, so if the board uses voltages that hurt (which is 
uncommon but not unknown), you don't touch. Equally, there are no fire 
enclosures.

With best wishes DESIGN IT IN! OOO - Own Opinions Only
www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England

Sylvae in aeternum manent.

From: Pete Perkins [mailto:peperkin...@cs.com] 
Sent: Thursday, February 2, 2017 5:21 PM
To: 'John Woodgate' ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] DoC when exempted from RED 2014/53/EU

John, et al,  

   It's nice to look for exemption loopholes but ... I would be 
careful in encouraging too much loosening based upon the skill of the users.  
   In today's environment many engineers and technicians are primarily 
software folks who are working with hardware to implement systems and these 
folks do not have the same training or appreciation of electrical hazards in 
equipment.  
   This comment applies equally to problems arising from EMC interference 
in applications; we know that there are a myriad of issues arising from the 
advent of multiple cell towers in operation.  Dropped call issues are usually 
dealt with by modifying software not repositioning antennas or other hardware 
fixes which are above the technicians pay grade.  
   I include radios generally in this comment because of the 
widespread use of digital radio equipment and the IoT explosion underway.     

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

p.perk...@ieee.org

From: John Woodgate [mailto:jmw1...@btinternet.com] 
Sent: Thursday, February 2, 2017 4:55 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG