Something seems to have got lost along the way here: The original question was not "who can grant the <HAR> mark?", but (paraphrased) "must the cable factory be in the EU?"
The answer to the factory question is "No", as millions of consumer products made outside the EU with <HAR> marked cable shows. (and yes there is falsely marked cable too) John C. -----Original Message----- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: 26 April 2013 09:06 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] <HAR> factories for marked cable In message <3f0347ac6ed9504191f91f07629fbb0c0155b...@thhsle14mbx2.hslive.net>, dated Fri, 26 Apr 2013, Charlie Blackham <char...@sulisconsultants.com> writes: > >Looking at the LVD guidance, (and of course it's "guidance" not "law") >http://ec.europa.eu/enterprise/sectors/electrical/files/lvdgen_en.pdf , >page 28 > > > >Products Scope of LVD Examples of products Comments > >Cables Yes [picture of >cable] Marked with HAR to increase tractability 'tractability' - the quality of being easily managed I suspect weasel wording here. The Commission has no business apparently elevating a private marking scheme to a requirement under a Directive. So using a confusing word may be a way to 'fog' the issue. Some people will assume it's a typo for 'traceability'. Participation in the HAR scheme is *effectively* restricted to certification bodies (it's not a manufacturers' organization) in Europe because ENs and HDs must be in force in the country - from the HAR site: QUOTE Within the country of the applicant, the European ENs and HDs must have formally entered into force; any conflicting national standards must have been withdrawn. Assessment of capability and qualification of the candidate by a HAR assessment team, according to harmonised requirements; positive results to be formally endorsed by the HAR Group. ENDQUOTE This restriction must, in fact, bear some responsibility for the widespread presence of dangerous fake 'HAR' marked cables. I have a sample alleged to have 0.75 mm^2 conductors, which are barely 0.3 mm^2 in fact, fitted with a fake British 13 A plug marked '10 A' but without a fuse. The point is that if you use a test house and the cable isn't HAR marked, the test house may well want to test the cable to whichever of HD 21, HD 22, EN 50525, EN 50143, EN 50214, EN 60702 or EN 61138 applies, and that is extremely costly. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk They took me to a specialist burns unit - and made me learn 'To a haggis'. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
