Hello Richard, It's the ce-marking directive (93/68/EEC) that changed the legal status of both EMC and LVD directives.Before the amendments on these 2 (and more) took place, the application of both directives was "voluntary" (no sanctions).
Look on the site of DGXIII http://www2.echo.lu/nasd/ for an overview of the directives that were amended in 93. "Sometimes we have to forget quicly not to get stuck in older requirements" (free after Richard Woods) Feel free to continue discussion to the benefit of those who dare not ask..... Regards, Gert Gremmen, Ing. == Ce-test, Qualified testing == Consultants in EMC, Electrical safety and Telecommunication Compliance tests for European standards and ce-marking Member of NEC/IEC voting committee for EMC. Our Web presence: http://www.cetest.nl List of current harmonized standards http://www.cetest.nl/emc-harm.htm 15 great tips for the EMC-designer http://www.cetest.nl/features01.htm -----Oorspronkelijk bericht----- Van: WOODS, RICHARD <wo...@sensormatic.com> Aan: 'Mike Hopkins' <mhopk...@keytek.com> CC: '@IEEE' <emc-p...@ieee.org> Datum: vrijdag 24 april 1998 20:43 Onderwerp: RE: GS Requirements >How quickly we forget. Recall that the Low Voltage Directive was issue in >1973 and was in effect over 10 years before the EMC Directive became >effective. So what was the status of local EMC laws during this 10 year >period? Since there was no EMC Directive, each state had their own law. >Remember the legal need to have emissions testing to the VDE limits? The >existance of the Low Voltage Directive had no bearing on the local EMC laws >or any other state laws not in conflict with the Low Voltage Directive. It >is nonsense to say that this situation has now changed just because the EMC >Directrive is active. The CE mark denotes compliance with all relevant >Directives - that is all it denotes. Each state can still have laws that >affect the sale and use of equipment as long as the laws are not in conflict >with any Directives. > >Richard Woods >Sensormatic Electronics >wo...@sensormatic.com >Views expressed by the author do not necessarily represent those of >Sensormatic. > >> ---------- >> From: Mike Hopkins[SMTP:mhopk...@keytek.com] >> Reply To: Mike Hopkins >> Sent: Friday, April 24, 1998 9:16 AM >> To: WOODS, RICHARD >> Cc: '@IEEE' >> Subject: RE: GS Requirements >> >> I don't believe Germany or any other EU country can impose additional >> legal >> restraints on the importation or use of equipment beyond the CE >> requirements. If this were allowed, each nation could, and probably would, >> impose additional restrictive requirements for the importation and use of >> products in their country -- exactly what the EU is trying to avoid. This >> said, any CUSTOMER can then decide what criteria a product must meet >> before >> purchasing it, but that's a negotiation between the customer and the >> supplier -- not a legal restraint or condition of trade. >> >> > -----Original Message----- >> > From: WOODS, RICHARD [SMTP:wo...@sensormatic.com] >> > Sent: Thursday, April 23, 1998 4:32 PM >> > To: 'emc-pstc' >> > Subject: RE: GS Requirements >> > >> > Did I miss something along the way? Did Germany delete the "Equipment >> > Safety >> > Law" of 24 June 1968 and ammended 13th August 1980? Article 3 of the law >> > says, "The manufacturer or importer of technical equipment may only >> > display >> > or put into circulation if it is of such a nature, in accordance with >> the >> > generally recognized rules of technology and the work safety and >> accident >> > prevention regulations . . ." The article then goes on to say " The >> > manufacturer or importer of an item of technical equipment may affix >> there >> > to the symbol "GS = geprfte Sicherheit (safety tested) . . . if the >> > equipment has undergone a type test by a Test Centre." The law goes on >> to >> > describe how the technical rules are developed. >> > >> > Remember that an EU state may have any law affecting equipment as long >> as >> > it >> > does not conflict with a Directive. Germany has at least two such >> > requirements: ergonomics for workstations (PCs) and human exposure to >> EMF. >> > One cannot receive a GS mark for a PC unless it complies with the >> > ergonomic >> > requirements of ZH1. That is the law and it is not in conflict with any >> > directive since there is no directive on ergonomics nor are there any >> > harmonized standards. Likewise there is no directive on EMF exposure. >> The >> > ENV 50166 series will eventually become the harmonized standards. >> > >> > Again, all of this is moot if Germany has repealed the Equipment Safety >> > Law >> > which I don't beleive they have. >> > >> > Richard Woods >> > Sensormatic Electronics >> > wo...@sensormatic.com >> > Views expressed by the author do not necessarily represent those of >> > Sensormatic. >> > >> > >> > > ---------- >> > > From: Ing. Gert Gremmen[SMTP:cet...@cetest.nl] >> > > Sent: Thursday, April 23, 1998 3:14 PM >> > > To: WOODS, RICHARD; 'emc-pstc' >> > > Subject: Re: GS Requirements >> > > >> > > Hello Richard, >> > > >> > > No other requirements are necessary for your products then >> > "manufacturers >> > > declaration", based on EMC and/or LVD requirements/tests, who are >> backed >> > > up >> > > by appropriate standards to attach the ce-mark and export to europe. >> > Make >> > > sure safety instructions are in the right European language. Although >> > the >> > > lVD directive does not insist on this, local authorities are keen on >> > > maintaining safety. If any problems occcur, directly contact the >> > > European >> > > Commission by means of the appropriate office for compliants. Make >> sure >> > > you >> > > have a representative in Europe, who can be contacted for inspection >> of >> > > technical files. >> > > >> > > Regards, >> > > >> > > Gert Gremmen Ing. >> > > >> > > == Ce-test, Qualified testing == >> > > Consultants in EMC, Electrical safety and Telecommunication >> > > Compliance tests for European standards and ce-marking >> > > Member of NEC/IEC voting committee for EMC. >> > > Our Web presence: http://www.cetest.nl >> > > List of current harmonized standards http://www.cetest.nl/emc-harm.htm >> > > 15 great tips for the EMC-designer http://www.cetest.nl/features01.htm >> > > >> > > >> > > >> > > >> > > >> > > >> > > -----Oorspronkelijk bericht----- >> > > Van: WOODS, RICHARD <wo...@sensormatic.com> >> > > Aan: 'emc-pstc' <emc-p...@majordomo.ieee.org> >> > > Datum: woensdag 22 april 1998 21:02 >> > > Onderwerp: GS Requirements >> > > >> > > >> > > >Equipment sold in Germany must comply with the GS requirements. >> > Somewhere >> > > in >> > > >the bowels of the German Government, there must be a list of >> standards >> > > that >> > > >must be met in order to comply with the GS requirements. Does anyone >> > know >> > > >where one can find this list? What agency is responsible for >> > > >maintaining/changing the list? Is there a legal methodology that must >> > be >> > > >followed in order to change the list, especially a public notice >> prior >> > to >> > > >the change? Given that a change is going to take place, are there >> > > standard >> > > >transition rules? >> > > > >> > > >The particular case at hand is that TUV has informed me that the EMF >> > > human >> > > >exposure standards have changed. VDE 0848 parts 2 and 4 have been >> > > replaced >> > > >by ENV 50166-1 and ENV 50166-2. Any further information that anyone >> has >> > > in >> > > >this regard would be helpful, especially information on any >> transition >> > > >rules. >> > > > >> > > > >> > > >Richard Woods >> > > >Sensormatic Electronics >> > > >wo...@sensormatic.com >> > > >Views expressed by the author do not necessarily represent those of >> > > >Sensormatic. >> > > > >> > > >> >
