Greetings,

>From the example below, I would not be as concerned with "who" tested 
it, but which standard it was tested to. I think that we must remember 
that standards organizations have made progress toward harmonization, 
but the heart of the problem is that US standards and EU standards are 
not interchangeable. And under the LVD, EU Harmonized standards must 
be used where available.

Ray Russell

ray_russ...@gastmfg.com

----------
From:  POWELL, DOUG[SMTP:do...@ftc2.aei.com]
Sent:  Wednesday, September 09, 1998 3:37 PM
To:  emc-p...@ieee.org
Subject:  RE: Agency approvals on components in CE

A little clarification by way of example,

Traditionally if we build a power conversion product for North 
America, we
provide a UL/CSA approved circuit breaker as a part of the design. 
 However
if we subsequently apply for certificates from an agency in Europe 
they will
insist upon a European approved circuit breaker.  Historically we have 
had
no success in finding circuit breakers with multiple approvals 
suitable for
both continents.  If the component has approval form an accredited 
test lab
we feel that it is not unsafe to use.  What is the risk of 
self-declaring
compliance to the LVD using only the UL/CSA approved part?  This would 
be a
major cost savings.

A second example would be the use of an EMI filter which is already 
approved
by one agency (not European).

I heard that this question was posed to the European Commission this 
year
(1998) and their response was to the effect that the choice of 
components is
up to the manufacturer.  I am unable to recall which email or 
periodical
made this statement.  Or was it something I read in the Official 
Journal.  I
tried browsing the European Commission's website and was unable to 
find any
document to this effect.  It is a difficult site to navigate.

Doug Powell
Advanced Energy Industries, Inc.
Fort Collins, Colorado USA
 ----------
From: je...@ftc2.aei.com
To: emc-p...@ieee.org
Subject: Agency approvals on components in CE mar
List-Post: emc-pstc@listserv.ieee.org
Date: Tuesday, September 08, 1998 10:31AM


It is my understanding that the European Commission has stated that a
manufacturer has the freedom to determine the acceptability of 
components
used in CE marked products.  (Or words to that effect.)  I would 
conclude
that this would remove the need for using European agency approved
components in safety critical locations.  Any reputable agency 
approval, or
appropriate evaluation by the manufacturer, would be acceptable.

Does anyone know of where I can obtain this statement in writing?  I'd 
like
to have something to back this up.  Also, I welcome comments on the
conclusions I have drawn based on this "alleged" EC statement.

Regards,

Jeff Jenkins
Senior Regulatory Compliance Engineer
Advanced Energy Industries, Inc.
Fort Collins, CO  USA




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