Hoping this reaches the eyes. Our comments on the document: 1. In many places, the English is not idiomatic and lays stress inappropriately, often by incorrect use of the negative or of "does". For instance "this phenomenon needs not to be considered" means it is compulsory not to consider it! Sometimes this doesn't matter; sometimes it would have legal significance. If the English text is to carry legal weight, it should be edited by a native English speaker to ensure that it does not convey the wrong meaning; the same applies of course to all the other languages. 2. In annex II section C.1 concerning documentation accompanying a product, there is the requirement that documents (presumably all of them, including instruction manuals, declarations of conformity etc. etc.) "have to be available in one of the official languages of the member state where the apparatus is to be taken into service ..." I understand the desirability of this for consumer goods, where it is generally followed today, but for professional equipment I think it is unnecessarily onerous. A manufacturer such as Dolby might sell only one or two samples per year of an apparatus into say Finland or Portugal, and to have to translate and print multipage documents into those languages would be uneconomic. 3. Article 5 contains a section that states: "Member States shall not impede for reasons relating to electromagnetic compatibility the placing on the market and/or the taking into service for its intended use of equipment conforming to this directive." As you are well aware, states and smaller administrative areas such as cities are currently impeding installation of equipment that conforms to the present Emc and low voltage directives, despite CE marking and accompanying declarations of conformity . I suggest that this clause should be strengthened to make clear that it applies not only to national governments but to others as well. Chris James Dolby Labs Inc -----Original Message----- From: John Juhasz [mailto:[email protected]] Sent: Thursday, March 30, 2000 3:19 PM To: '[email protected]'; [email protected] Subject: RE: EMC Directive revisions
Here we go . . . 'indirect' trade barrier . . . forget Class A. To whom can we directly raise our concerns (besides product trade associations)? John Juhasz Fiebr Options Bohemia, NY -----Original Message----- From: [email protected] [ mailto:[email protected] <mailto:[email protected]> ] Sent: Thursday, March 30, 2000 7:39 AM To: [email protected] Subject: RE: EMC Directive revisions Thanks Brian. I have some very serious concerns about this draft. Art 3A, 1a: "General" type products appear to have to be able to function in any EMC environment including industrial. Class A type products just went out the window since the product must also be able to function in a residential environment. Annex II, A1,1: Testing immunity to DC current or voltage on AC networks???????? Annex II, B.1: Oh great! Now we have to design so emissions are "reduced as far as possible." I can just see now that we ship every system is a sealed, welded steel container. Annex II B.1.1: and B.2.1: If a standard lists several levels of emissions and immunity, the product must comply with the most severe limits. They have to be kidding! If this is the outcome of SLIM, I would hate to see the outcome of FAT! Richard Woods ---------- From: Brian Jones [SMTP:[email protected]] Sent: Thursday, March 30, 2000 4:06 AM To: EMC-PSTC Subject: Re: EMC Directive revisions Ed, Richard, and everyone Following discussions in the SLIM working group, the Commission has now produced a draft of the revised EMC Directive. This is a complete rewrite, not an amendment. The major change is removal of the requirement for fixed installations to be assessed and CE marked prior to taking into service, but the possibility for investigation by enforcement authorities, should interference be caused, remains. The distinction between "systems" which continue to require CE marking, and "fixed installations" is unclear at present. It is expected that the draft will undergo further development and changes at SLIM working group meetings during this year before a draft is published for comment. I will be presenting a paper in one of the poster sessions at the EMC Symposium in Washington DC, on the latest position. Best wishes Brian Jones EMC Consultant and Competent Body Signatory ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected] ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected] ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected]
