Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents or via affixed QR

[Scott Xe]

Dear Bernd & Charlie,

Thanks for your advice!!  For the time being, we have to put the safety
instructions with the unit.

Best regards,

Scott


On Tue, 15 Aug 2023 at 15:54, Dürrer Bernd  wrote:

> Dear Scott,
>
>
>
> I agree with Charlie Blackham’s conclusions on instructions in electronic
> format embedded in the device. I am not aware of any plans to amend LVD and
> RED to align their requirements on instructions with the new Machinery
> regulation. However, as the monetary and environmental costs due to
> extensive paper-based documentation has been identified as one of the
> problems of the old Machinery Directive (cf.
> eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021SC0082=3,
> p. 21 and 41ff.), I hope that there will be an initiative to introduce an
> option for digital documentation also in other directives and regulations.
>
>
>
> Currently, you have to follow Charlie’s advice to provide a short printed
> guide with the mandatory instructions and safety information. If you are
> lucky and all mandatory information for your product can be presented
> graphically, you may avoid to translate the document to the 24 official EU
> languages and the additional 3 languages of states in the European Economic
> Area (EEA) and the EU-Turkey Customs Union (DocsRoom - European
> Commission (europa.eu) <https://ec.europa.eu/docsroom/documents/38022>,
> p. 246).
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
>
>
>
>
> *Von:* Scott Xe 
> *Gesendet:* Dienstag, 15. August 2023 08:24
> *An:* Dürrer Bernd 
> *Cc:* EMC-PSTC@listserv.ieee.org
> *Betreff:* Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying
> documents or via affixed QR
>
>
>
> [EXTERNAL E-MAIL] This email originated from outside of the organization.
> Do not click links or open attachments unless you recognize the sender.
>
> Dear Bernd,
>
>
>
> Although LVD and RED are modern directives, they are considered old
> compared with MR issued in 2023.  Could the view on instructions in
> electronic format be aligned all together one day?
>
>
>
> Thanks and regards,
>
>
>
> Scott
>
>
>
>
>
> On Tue, 15 Aug 2023 at 13:27, Scott Xe  wrote:
>
> Dear Bernd,
>
>
>
> Thanks for your good references!  The LVD and RED do not decline the
> instructions in electronic format.  What about those instructions embedded
> in the ROM as the memory is not expensive as before?  For example, mobile
> phones, TVs, etc.
>
>
>
> Regards,
>
>
>
> Scott
>
>
>
>
>
>
>
> On Mon, 14 Aug 2023 at 15:14, Dürrer Bernd  wrote:
>
> Hi Amund,
>
>
>
> In the European Union, it depends on the Directive that is applicable for
> your product. Both the Low Voltage Directive 2014/35/EU 
> (L_2014096EN.01035701.xml
> (europa.eu)
> <https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32014L0035#d1e32-371-1>,
> Article 6, Point 7, Article 8, Point 4, and Article 9, Point 2) and the
> Radio Directive 2014/53/EU (Consolidated TEXT: 32014L0053 — EN —
> 27.12.2022 (europa.eu)
> <https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02014L0053-20221227#tocId84>,
> Article 10, Point 8, Article 12, Point 4, and Article 13, Point 2) require
> that manufacturers, importers, and distributors ensure that the product is
> accompanied by instructions and safety information. Only new regulation
> (EU) 2023/1230 that will replace Machinery Directive in January 2027 allows
> to provide instructions in digital format (L_2023165EN.01000101.xml
> (europa.eu)
> <https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1230=1688119698228#d1e1695-1-1>,
> Article 10, Point 7).
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* John Woodgate 
> *Gesendet:* Sonntag, 13. August 2023 19:14
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] SV: [PSES] User manual by accompanying documents or
> via affixed QR
>
>
>
> [EXTERNAL E-MAIL] This email originated from outside of the organization.
> Do not click links or open attachments unless you recognize the sender.
>
> No. I don't see so many EU documents as others here do, and it is very
> difficult, as you know, to find a document when you don't know a document
> title to look for. I am remembering information posted here quite a long
> time ago.
>
> On 2023-08-13 17:56, Amund Westin wrote:
>
> Yes, I was thinking that a short paper guide would help. URL link is
> important as you say, and QR are actually for advanced mobile users.
>
>
>
> Have you seen this issue been discussed in “Blue Guide” or other EU
> documents?
>
>
>

Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents or via affixed QR

[Scott Xe]

Dear Bernd,

Although LVD and RED are modern directives, they are considered old
compared with MR issued in 2023.  Could the view on instructions in
electronic format be aligned all together one day?

Thanks and regards,

Scott


On Tue, 15 Aug 2023 at 13:27, Scott Xe  wrote:

> Dear Bernd,
>
> Thanks for your good references!  The LVD and RED do not decline the
> instructions in electronic format.  What about those instructions embedded
> in the ROM as the memory is not expensive as before?  For example, mobile
> phones, TVs, etc.
>
> Regards,
>
> Scott
>
>
>
> On Mon, 14 Aug 2023 at 15:14, Dürrer Bernd  wrote:
>
>> Hi Amund,
>>
>>
>>
>> In the European Union, it depends on the Directive that is applicable for
>> your product. Both the Low Voltage Directive 2014/35/EU 
>> (L_2014096EN.01035701.xml
>> (europa.eu)
>> ,
>> Article 6, Point 7, Article 8, Point 4, and Article 9, Point 2) and the
>> Radio Directive 2014/53/EU (Consolidated TEXT: 32014L0053 — EN —
>> 27.12.2022 (europa.eu)
>> ,
>> Article 10, Point 8, Article 12, Point 4, and Article 13, Point 2) require
>> that manufacturers, importers, and distributors ensure that the product is
>> accompanied by instructions and safety information. Only new regulation
>> (EU) 2023/1230 that will replace Machinery Directive in January 2027 allows
>> to provide instructions in digital format (L_2023165EN.01000101.xml
>> (europa.eu)
>> ,
>> Article 10, Point 7).
>>
>>
>>
>> Kind regards,
>>
>>
>>
>> Bernd
>>
>>
>>
>> *Von:* John Woodgate 
>> *Gesendet:* Sonntag, 13. August 2023 19:14
>> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
>> *Betreff:* Re: [PSES] SV: [PSES] User manual by accompanying documents
>> or via affixed QR
>>
>>
>>
>> [EXTERNAL E-MAIL] This email originated from outside of the organization.
>> Do not click links or open attachments unless you recognize the sender.
>>
>> No. I don't see so many EU documents as others here do, and it is very
>> difficult, as you know, to find a document when you don't know a document
>> title to look for. I am remembering information posted here quite a long
>> time ago.
>>
>> On 2023-08-13 17:56, Amund Westin wrote:
>>
>> Yes, I was thinking that a short paper guide would help. URL link is
>> important as you say, and QR are actually for advanced mobile users.
>>
>>
>>
>> Have you seen this issue been discussed in “Blue Guide” or other EU
>> documents?
>>
>>
>>
>>
>>
>>
>>
>>
>>
>> *Fra:* John Woodgate
>> *Sendt:* 13. august 2023 18:43
>> *Til:* EMC-PSTC@LISTSERV.IEEE.ORG
>> *Emne:* Re: [PSES] User manual by accompanying documents or via affixed
>> QR
>>
>>
>>
>> I believe that in Europe, it is not allowed. Current practice seems to be
>> to include with the product a short  'User Guide' or similar, which
>> includes the safety information required by the relevant safety standard,
>> and the DOC(s), together with a text link of the URL of the full User
>> Manual. You could include a QR code in addition, but not instead of the
>> text link, because about 15 % of people don't have a smart phone or don't
>> know much about using it for anything but calls, text messages and the
>> camera.
>>
>> On 2023-08-13 16:57, Amund Westin wrote:
>>
>> To avoid a lot of paper use, it is possible to leave a short instruction
>> with the product to enter a web site or use affixed QR code (on product) to
>> get access to the User manual and other relevant documentation?
>>
>> Should such a symbol Link https://www.iso.org/obp/ui#iso:grs:7000:3500
>>  also be attached when using QR code?
>>
>>
>>
>> Best regards
>>
>> Amund
>>
>>
>> --
>>
>> 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:
>> https://www.mail-archive.com/emc-pstc@listserv.ieee.org/
>> 
>>
>> Website: https://ewh.ieee.org/soc/pses/
>> Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to
>> unsubscribe) 
>> List rules: https://ewh.ieee.org/soc/pses/listrules.html
>>
>> For help, send mail to the list administrators:
>> Mike Sherman at: msherma...@comcast.net
>> Rick Linford at: linf...@ieee.org
>>
>> For policy questions, send mail to:
>> Jim Bacher at: j.bac...@ieee.org
>> --
>>
>> To unsubscribe from the EMC-PSTC list, click the following link:
>> https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
>>
>> --
>>
>> This message is from the IEEE Product Safety Engineering Society emc-pstc
>> discussion list. To post a message to the list, 

Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents or via affixed QR

[Charlie Blackham]

Scott

Requirements on instructions to be in printed format are often included/implied 
in safety standards – for example EN 62368-1:2014:

F.4 Instructions
When information with regard to safety is required according to this standard, 
this information
shall be given in an instruction for installation or instruction for initial 
use. This information
shall be available prior to installation and initial use of the equipment.

The final sentence precludes safety instructions being embedded on the device

Article 10(8) of the RED states:

Manufacturers shall ensure that the radio equipment is accompanied by 
instructions and safety information in a language which can be easily 
understood by consumers and other end-users, as determined by the Member State 
concerned.

Section 2.6(j) of the RED Guide states:

The Blue Guide, in Chapter 3.1.4, provides more details on how the instructions 
and safety information need to be provided. According to the Blue Guide, whilst 
the safety information needs to be provided on paper, it is not required that 
all the set of instructions is also provided on paper but they can also be on 
electronic or other data storage format, however a paper version should always 
be available free of charge for the consumers who request it. It is noted that 
the information in Article 10.8 (second sub-paragraph) and Article 10.10, as is 
specifically required by the RED and not directly related with the general 
instructions of use, shall be provided in paper.

The practical application of this is a short printed guide shipped with the 
product.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Scott Xe 
Sent: Tuesday, August 15, 2023 6:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents 
or via affixed QR

Dear Bernd,

Thanks for your good references!  The LVD and RED do not decline the 
instructions in electronic format.  What about those instructions embedded in 
the ROM as the memory is not expensive as before?  For example, mobile phones, 
TVs, etc.

Regards,

Scott



On Mon, 14 Aug 2023 at 15:14, Dürrer Bernd 
mailto:bernd.duer...@wilo.com>> wrote:
Hi Amund,

In the European Union, it depends on the Directive that is applicable for your 
product. Both the Low Voltage Directive 2014/35/EU (L_2014096EN.01035701.xml 
(europa.eu)<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32014L0035#d1e32-371-1>,
 Article 6, Point 7, Article 8, Point 4, and Article 9, Point 2) and the Radio 
Directive 2014/53/EU (Consolidated TEXT: 32014L0053 — EN — 27.12.2022 
(europa.eu)<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02014L0053-20221227#tocId84>,
 Article 10, Point 8, Article 12, Point 4, and Article 13, Point 2) require 
that manufacturers, importers, and distributors ensure that the product is 
accompanied by instructions and safety information. Only new regulation (EU) 
2023/1230 that will replace Machinery Directive in January 2027 allows to 
provide instructions in digital format (L_2023165EN.01000101.xml 
(europa.eu)<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1230=1688119698228#d1e1695-1-1>,
 Article 10, Point 7).

Kind regards,

Bernd

Von: John Woodgate mailto:j...@woodjohn.uk>>
Gesendet: Sonntag, 13. August 2023 19:14
An: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Betreff: Re: [PSES] SV: [PSES] User manual by accompanying documents or via 
affixed QR

[EXTERNAL E-MAIL] This email originated from outside of the organization. Do 
not click links or open attachments unless you recognize the sender.

No. I don't see so many EU documents as others here do, and it is very 
difficult, as you know, to find a document when you don't know a document title 
to look for. I am remembering information posted here quite a long time ago.
On 2023-08-13 17:56, Amund Westin wrote:
Yes, I was thinking that a short paper guide would help. URL link is important 
as you say, and QR are actually for advanced mobile users.

Have you seen this issue been discussed in “Blue Guide” or other EU documents?




Fra: John Woodgate
Sendt: 13. august 2023 18:43
Til: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Emne: Re: [PSES] User manual by accompanying documents or via affixed QR


I believe that in Europe, it is not allowed. Current practice seems to be to 
include with the product a short  'User Guide' or similar, which includes the 
safety information required by the relevant safety standard, and the DOC(s), 
together with a text link of the URL of the full User Manual. You could include 
a QR code in addition, but not instead of the text link, because about 15 % of 
people don't have a smart phone or don't know much about using it for anything 
but calls, text messages and the camer

Re: [PSES] AW: [PSES] SV: [PSES] User manual by accompanying documents or via affixed QR

[Scott Xe]

Dear Bernd,

Thanks for your good references!  The LVD and RED do not decline the
instructions in electronic format.  What about those instructions embedded
in the ROM as the memory is not expensive as before?  For example, mobile
phones, TVs, etc.

Regards,

Scott



On Mon, 14 Aug 2023 at 15:14, Dürrer Bernd  wrote:

> Hi Amund,
>
>
>
> In the European Union, it depends on the Directive that is applicable for
> your product. Both the Low Voltage Directive 2014/35/EU 
> (L_2014096EN.01035701.xml
> (europa.eu)
> ,
> Article 6, Point 7, Article 8, Point 4, and Article 9, Point 2) and the
> Radio Directive 2014/53/EU (Consolidated TEXT: 32014L0053 — EN —
> 27.12.2022 (europa.eu)
> ,
> Article 10, Point 8, Article 12, Point 4, and Article 13, Point 2) require
> that manufacturers, importers, and distributors ensure that the product is
> accompanied by instructions and safety information. Only new regulation
> (EU) 2023/1230 that will replace Machinery Directive in January 2027 allows
> to provide instructions in digital format (L_2023165EN.01000101.xml
> (europa.eu)
> ,
> Article 10, Point 7).
>
>
>
> Kind regards,
>
>
>
> Bernd
>
>
>
> *Von:* John Woodgate 
> *Gesendet:* Sonntag, 13. August 2023 19:14
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Betreff:* Re: [PSES] SV: [PSES] User manual by accompanying documents or
> via affixed QR
>
>
>
> [EXTERNAL E-MAIL] This email originated from outside of the organization.
> Do not click links or open attachments unless you recognize the sender.
>
> No. I don't see so many EU documents as others here do, and it is very
> difficult, as you know, to find a document when you don't know a document
> title to look for. I am remembering information posted here quite a long
> time ago.
>
> On 2023-08-13 17:56, Amund Westin wrote:
>
> Yes, I was thinking that a short paper guide would help. URL link is
> important as you say, and QR are actually for advanced mobile users.
>
>
>
> Have you seen this issue been discussed in “Blue Guide” or other EU
> documents?
>
>
>
>
>
>
>
>
>
> *Fra:* John Woodgate
> *Sendt:* 13. august 2023 18:43
> *Til:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Emne:* Re: [PSES] User manual by accompanying documents or via affixed QR
>
>
>
> I believe that in Europe, it is not allowed. Current practice seems to be
> to include with the product a short  'User Guide' or similar, which
> includes the safety information required by the relevant safety standard,
> and the DOC(s), together with a text link of the URL of the full User
> Manual. You could include a QR code in addition, but not instead of the
> text link, because about 15 % of people don't have a smart phone or don't
> know much about using it for anything but calls, text messages and the
> camera.
>
> On 2023-08-13 16:57, Amund Westin wrote:
>
> To avoid a lot of paper use, it is possible to leave a short instruction
> with the product to enter a web site or use affixed QR code (on product) to
> get access to the User manual and other relevant documentation?
>
> Should such a symbol Link https://www.iso.org/obp/ui#iso:grs:7000:3500
>  also be attached when using QR code?
>
>
>
> Best regards
>
> Amund
>
>
> --
>
> 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:
> https://www.mail-archive.com/emc-pstc@listserv.ieee.org/
> 
>
> Website: https://ewh.ieee.org/soc/pses/
> Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to
> unsubscribe) 
> List rules: https://ewh.ieee.org/soc/pses/listrules.html
>
> For help, send mail to the list administrators:
> Mike Sherman at: msherma...@comcast.net
> Rick Linford at: linf...@ieee.org
>
> For policy questions, send mail to:
> Jim Bacher at: j.bac...@ieee.org
> --
>
> To unsubscribe from the EMC-PSTC list, click the following link:
> https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
>
> --
>
> 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:
> https://www.mail-archive.com/emc-pstc@listserv.ieee.org/
> 
>
> Website: https://ewh.ieee.org/soc/pses/
> Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to
> unsubscribe) 
> List rules: