First do no harm - review John's notes about the user and the various
sensitivities of headphones etc and do some good engineering evaluation of why
the output levels are set where they are, the cost to redesign, and the effect
on your production schedule will help you decide to "fight or flight" and for
how long and how hard. 
It is sometimes the case the NB does overstep their authority. They, just as
we, are bound by the standard and just as we don't get to waive stuff we don't
like, they don't get to add stuff they do like (that used to be referred to as
a desk standard)  - they evaluate to the standards in place and don't get to
amend them at will. If they are insisting then they must have some written
clause in the standard that says that so make them justify it, if they can't
keep pushing the issue uphill until they run out of excuses. I'd check the
referenced standards to see if EN60065 is called out in the main standard as
well. 

I once had to TUV engineers, one in Japan and one in the US- both native
German speaker, disagree over the same translation of a warning to replace a
fuse with the same size and type of fuse. The wording in the standard at the
time said ."Warning replace with.......", or equivalent wording. Heavy sigh!

It is an uphill battle but not a forgone conclusion. 

-----Original Message-----
From: Huang, Tim [mailto:tim.hu...@harman.com] 
Sent: Wednesday, July 13, 2011 12:23 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN50332-2

Dear John,

Thanks for your comment. 
I like your advice. 

TUV-SUD China is verifying our product(which is only powered by AC mains)
according to IEC60065 and EN60065, they don't have the certification move on
since they found that the headphone output exceed limits in EN50332-2. They
insist that it is must to meet comply with EN50332-2 for the headphone port. 
How could I persuade them to move on? 

Regards
Tim


-----Original Message-----
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Wednesday, July 13, 2011 3:04 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EN50332-2

In message 
<5cd28539512e3142abbfd0ecbebbf50108b4d57...@hicgwsex01.ad.harman.com>, 
dated Tue, 12 Jul 2011, "Huang, Tim" <tim.hu...@harman.com> writes:

>Does anybody know if EN50332-2 is mandatory to a DVD which only powered 
>by AC mains?

It is not.
>
>There is a headphone port in this DVD, I?m wondering if EN50332-2 only 
>applicable to portable audio products?

It is.
>
>My DVD is defined as portable product?

Not if it's only mains powered.

Even so, a responsible company would not produce a product that could 
damage a customer's hearing. The EN 50332-2 requirements for output 
voltage are probably too stringent, but can be used as a guide.

Even so 2, you have no control over which headphones the user may 
connect to the product, and the sensitivity of products on the market 
varies over a wide range.

So the available solution seems to be to include advice in the user 
instructions:

Don't listen at a level such that you can't hear your own voice;

Don't listen for long periods (e.g. over 4  hours) to loud music;

Reduce your listening volume and/or duration if you experience ringing 
in your ears, difficulty in understanding speech immediately after a 
listening session or noises (crackling, rustling, tones) in your ears.

Go to www.dontlosethemusic.co.uk for more advice.

[This URL now re-directs to a page with the same good advice but, in my 
opinion, inappropriately presented. I have made my views known.]
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
When I point to a star, please look at the star, not my finger. The star will
be more interesting.

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