The UK measure that relates to power cords is the Plugs and Sockets (safety)
Regulations 1994, Statutory Instrument 1994 No. 1768. I have not read this
measure but I understand that it requires that mains powered electrical
equipment
being supplied in the UK and likely to be sold in the UK to domestic consumers
must be
supplied by the 'first supplier' i.e. manufacturer or importer, with a mains
lead
with a properly fitted plug. This plug must be either a UK style fused 250V 13A
plug
to BS 1363A with a correctly rated fuse or a plug to a type approved for use in
a
EEA member state in which case an approved conversion adaptor to BS1363A
again fited with a correctly rated fuse must be supplied.
This requirement came into force on 1 Feb 1994. It was not brought in under the
Low Voltage Directive (implimented in the UK by Statutory Instrument 1994 No.
3260)
but as secondary legislation under the Consummer Protection Act. Such national
measures that may be thought to be in conflict with European directives must be
submitted to the Commission under Directive 83/139/EEC, as amended, who may
order a delay before implimentation to allow for any objection to be raised and
dealt with. There were objections from the Commission and others to this measure
but they were finally resolved and the measure approved by the Commission.
I spoke to Nick Winter who is responsible for the unit at the UK Department of
Trade
and Industry (DTI) that deals with electrical safety legislation. He told me
that in
trying to steer the Plugs and Sockets Regulations through the 83/139/EEC
mechanism his unit had done a survey of other EEA members states to look for
requirements for national style plugs. They found nearly all had some such
requirement.
Most had, in implimenting the LVD, taken the requirement in Annex 1 1(c) of the
directive that 'the electrical equipment, together with its component parts
should be made in
such a way as to ensure that it can be safely and properly assembled and
connected'
and implimented it for their state to require that mains connections be made
with national style mains plugs and sockets.
My conclusion is that it is fine for the distributor in the UK (who as importer
becomes
first supplier) to substitute UK power cords for US ones for units for sale in
the UK.
There is a good chance that it would be fine to substitute other other power
chords for
other destinations but you would have to examine the national laws in each state
to
be sure.
All this demonstrates that Europe is very far from a single market. Vic Boersma
says
that 'the issue here is not UK Statutes, but EU Directives, which are legally
binding laws
of the European Union that become mandatory by their transposition into national
laws of the Member States.' This misses the point that the directives are not
in themselves legally binding on individuals or companies. Member states are
treaty bound to 'approximate'
national laws to the directives but these approximations, which are legally
binding on indivduals in that state, are in many cases just that, approximate.
Member states can,
via the 83/139/EEC mechanism introduce national measures in derogation of the
principal of
the free movement of goods and several hundred such measures have been notified
under
this mechanism. The Commission can bring member states to court for incorrect
implimentation of the directives and in one case an individual successfully
challenged
a member state's implimentation of a directive in the European Court but such
litigation is
not for the faint hearted.
Vic was however much nearer the truth than me in one other matter. In a recent
post he
used the definition of rated voltage in IEC950 to deduce that the LVD did not
apply to
equipment that was powered by a voltage below the limit but generated voltages
within
the limits. I'm still not sure of using IEC950 but the conclusion he came to
agreed with the
interpretation of phrase 'designed for use with a voltage rating of ...' given
by Nick Winter
at the DTI. They regard the directive as applying only to equipment powered by
voltages
within the stated limits
Nick Rouse
