From: =?iso-8859-1?Q?Juan_Pedro_Pe=F1a?= <[email protected]>
Subject: RE: CE marking vs. Annex ZB in EN60950
I apologise for answering this old subject after so long time.=20
I consider that "national deviation" should be removed in most of the
cases. Most of them are simply a hidden protection of national
industries, but not always. For example, I understand different
environmental tests if a product is intended to be used in a tropical
country. I'm afraid that is not the case of Annex ZB.=20
But CE marking is a different question. Most of the times, we forget
that EN standards are not mandatory for CE marking. They are just an
useful guide. If your product does not comply with Norway (or Sweden)
national deviations, it does not mean that your product does not comply
with the LVD. Even more, in my opinion, it will be very difficult for
the Norwich Authorities to convince any European Judge they are right
and the rest of the world is wrong about the compliance of the product
with the LVD. In a situation like that one, according to the EU
legislation, the Norwich Authorities have to demonstrate your product
does not comply with the LVD, not with the recommended and voluntary
standard.
Juan Pedro Pe=F1a
____________________________________________________________
CENTRO DE TECNOLOGIA DE LAS COMUNICACIONES, S.A.
PTA - C/ Severo Ochoa, 2 - 29590 Campanillas
(Malaga) - SPAIN
Tel.: +34 95 261 91 55 - Fax: +34 95 261 91 13
e-mail: [email protected]
Web: http://www.cetecom.es/
____________________________________________________________
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De: [email protected][SMTP:[email protected]]
Enviado el: mi=E9rcoles 19 de agosto de 1998 18:17
Para: [email protected]
Cc: [email protected]
Asunto: CE marking vs. Annex ZB in EN60950
I am trying to sort out an an apparent contradiction between the
main body of
the "harmonized" EN 60950 and the national deviations that
appear in Annex ZB.
I would appreciate some assistance from the safety professionals
and
regulatory experts in the emc-pstc and treg forums.
My particular problem has to do with the specified insulation
between between
TNV-3 circuits and SELV circuits, although the question about
Annex ZB applies
to other national deviations as well. I will use the TNV/SELV
issue as an
example.
Clause 6.2.1.2 of EN 60950 specifies basic insulation between
TNV-3 and SELV
circuits. However, in Annex ZB, it states that Norway and
Sweden require
supplementary insulation. Annex ZB states that "for the
countries in which
the special national conditions apply, these provisions are
normative. For
other countries they are informative."
I am trying to understand how this distinction is applied for CE
marking. I
thought that the intent of CE marking was that products could be
evaluated
against "harmonized" standards and then have the CE marking
applied. I
thought that products with the CE marking were allowed to move
freely among
the member countries in the EU. Annex ZB seems to complicate
this simple
interpretation.=20
My tentative conclusions about the above situation are:
1) A manufacturer who intends to market his product in a list of
EU countries
that excludes Norway and Sweden can apply the CE marking to a
product that has
only basic insulation between TNV-3 and SELV circuits.
2) A manufacturer who intends to market his product in a list of
EU countries
that includes Norway or Sweden can only apply the CE mark if the
product
provides supplementary insulation between TNV-3 and SELV
circuits.
The above two cases result in products that each bear identical
CE marking,
but one of them (case 1) is technically illegal for use in
Norway and Sweden.
From looking at the product marking, there is no way to
determine that the
product in case 1 should not be used in Norway or Sweden.
I suppose that this distinction could be made in the user
manual. I also
presume that the manufacturer in case 1 would be obligated to
ensure that the
product is not offered for sale in Norway or Sweden. Maybe this
is enough to
comply with the letter of the law, but I suspect that it would
be easy for the
product in case 1 to find its way into Norway and Sweden.
Prior to the adoption of CTR 21 for analog modems, the above
issue was largely
academic, since individual national approvals and the
corresponding national
labels were still required for connection to the PSTN.
However, now that CTR 21 has been adopted, I expect there will
be a rush
toward "full" CE marking (including the crossed hockey sticks)
of analog
modems. National approval labels will no longer be required. I
think this
will bring additional attention to the situation I have
described above.
Can anyone offer some some insight into how this situation
should be handled?
Is my interpretation correct? Any comments would be welcome.
Joe Randolph
Telecom Design Consultant
Randolph Telecom, Inc.
325 Highland Avenue
Winchester, MA, USA 01890
781-721-2848 (voice)
781-721-0582 (fax)
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