Gary, as one of the GS mark certification organisations I like to give some explanations. The GS mark is the only safety mark backed up by laws in Europe. The regulations for the GS-mark are defined in the German law for safety. It is possible to apply for the status as a GS mark certification body and test lab by all test and certification organisations located in Europe. The audits are done by the German government. The GS mark is a mark for the user. It should show the conformity to safety, EMC, it includes to check the user manual, it contains somehow the functionality of the product to be checked. The safety check should be based on standards, but the law defines an overall safety for the user, so sometimes GS means to check more like for example misuse. GS is not a quality mark, so we do not check, if a product lasts for one year of for longer time. The GS mark test houses and certification bodies are required to have an insurance. In case of issues on the market there is a defined escalation path. By law, it is not allowed to issue a GS mark only based on safety testing without taking care of EMC. If there is no EMC report available, then you might get a trade mark label like INNOVA mark, VDE, TÜV or others, but this is just showing, that one test house has done testing for safety. With best regards Horst INNOVA Product Service GmbH Ampferweg 6 87677 Stöttwang Tel: 08345-952727 Fax : 08345-952729
Von: [email protected] [ ailto:[email protected]]Im Auftrag von Gary McInturff Gesendet: Mittwoch, 26. Mai 2004 01:13 An: EMC-PSTC (E-mail) Betreff: Legal requirements linking GS and EMC Gents, The claim has once more been put forth by a major European based NRTL doing business in the us that they cannot grant a GS mark for ITE equipment unless they have the emissions data during the safety review. I believe that they may want it but it is not required under statutes, and in fact can hamper the certification process by turning a somewhat parallel process into an absolutely serial process. About the only connection that comes to mind is the X and Y capacitors - at least in most cases. They have safety requirements as well as EMC requirements. So if one goes through safety with parts that are identified as safety critical items and then have to make changes because of EMC one has to return to the safety agency and have a review of those components. If not the factory inspections would show a non-approved (sorry not a good choice of words) to maintain the agency mark. But the EMC data does not need to be presented. In my opinion, and you all may well be about to change that, is that the safety NRTL has no rights under the LVD, EMC, or the CE marking process to tie the two processes into their approval. If there isn't such a legal requirement I will be dropping the vendor and move on to one of the many others who can now provide the same services. If there is such a law I'm stuck and grudgingly concede. Thoughts? Thanks Gary McInturff
