Hi Joe:

An excellent question !

Let me ask one or two of my own here.

1. Are we sure that both Sweden and Norway are currently EU members ?  Not
just IEC members ?

Regardless of that answer the question really remains valid for the other
items in annex ZB

2. Would it be reasonable that these National Requirements are only
applicable when getting a National Approval, and that they are not
applicable to CE marking and compliance with the EN standard ?


I hope to see a lot of opinions, this should be interesting.



Richard Payne
MBD Product Safety Engineering
Tektronix, Inc.
v (503) 627-1820
f (503) 627-3838
e richard.pa...@tek.com



> -----Original Message-----
> From: j...@aol.com [SMTP:j...@aol.com]
> Sent: Wednesday, August 19, 1998 9:17 AM
> To:   emc-p...@ieee.org
> Cc:   t...@world.std.com
> Subject:      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. 
> 
> 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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