It is my understanding that if a component is not approved to the apprpriate
EU standard, the component must be evaluated to the standard.  The
evaluation of the component does not have to be conducted by an EU agency
except for specific types of equipment which require notified body approval.

I would appreciate any comments on this position.

Pryor McGinnis
Compliance Test Laboratories
c...@prodigy.net

-----Original Message-----
From: Russell, Ray <ray_russ...@gastmfg.com>
To: 'emc-p...@ieee.org' <emc-p...@ieee.org>; 'POWELL, DOUG'
<do...@ftc2.aei.com>
List-Post: emc-pstc@listserv.ieee.org
Date: Thursday, September 10, 1998 12:08 PM
Subject: RE: Agency approvals on components in CE


>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
>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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