A color photograph has been a requirement of the Toy Directive for a long time. However, toys are different than most other products. If customs receives a shipment of toy cars of model X from company Y, it can be difficult to determine if what is in the box is what is declared on the DoC. The product may have labeling or packaging clearly identifying it, but it may not. The photograph is an important tool for market surveillance. This requirement was added to the draft NLF Directives for a similar purpose. However, the issue is different with other types of products, particularly with highly specialize equipment where a DoC may cover a series of products that differ significantly in appearance depending on the configuration of components. The result was that the photograph was made an option. I would recommend it for products where it can be difficult to clearly identify the model and manufacturer. However, this won't apply to most technology products.
The routine testing depends on the product type, but it would be the EN 50514 testing for products falling under EN 60950-1. The standard only requires routine testing for some components types and for some conditions to allow reduced spacings and such. However, it doesn't specify routine testing at the system level. I believe that the current list of standards harmonized under the Low Voltage Directive includes some routine testing standards, such as EN 50106 for household and similar electrical appliances. However, it does not include EN 50514, so routine testing would not be required if you were to declare the presumption of conformity through the standards route. If your product is certified, the certification agency may require routine testing, but certification isn't mandatory. For ITE, I believe you could self-declare compliance without routine testing. The new LVD is intended to change that. Disclaimer: I do not have extensive knowledge of the development of the new LVD and what I stated may be incorrect. Take it as guidance only and not necessarily as hard fact. I would encourage anybody with better insight to correct my statements where they are wrong. Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. -----Original Message----- From: Kunde, Brian [mailto:brian_ku...@lecotc.com] Sent: Monday, November 30, 2015 7:27 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] New LV Directive 2014/35/EU Scott, The New LVD as with the latest Machinery Directive requires a Risk Assessment of the Essential Health and Safety Requirements called out in the Directive. Most likely the new ISO EN 12100 Risk Assessment standard will be harmonized to the LVD and you can use this on your DoCs to show compliance for safety in additional to any other applicable safety standards. The world of product safety is changing from a list of do's and don't found in product safety standards to a proper Risk Assessment of your products. There are several good articles out there on this topic. The color image is optional. I'm curious to see how many manufacturers include color images and how they implement them on DoCs. I think this was added because in some cases there may be items that cannot be properly identified by other means in which case the color image may be required. I think the only requirement of the image is that it must show the product in a way where it can be properly identified from other products if you are relying on the image for that purpose. Regarding sample testing, I'm not sure. This could refer the 100% type testing performed in Production, which you should already be doing. Or it could refer to actual product audits, which I am highly in favor of but many companies do not bother with; except for the factory inspections performed by 3rd party certification houses. If and how you do sample testing of production to insure you are shipping compliant products will vary from company to company depending on many factors and can only really be determined by the manufacturer. I hope this was helpful. The Other Brian -----Original Message----- From: Scott Xe [mailto:scott...@gmail.com] Sent: Monday, November 30, 2015 8:47 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] New LV Directive 2014/35/EU There are 3 additional requirements as compared with existing one. The technical documentation shall include an adequate analysis and assessment of the risk(s). What is objective and scope for these? Do these analysis and assessment refer to 3rd party verification of compliance with applicable standard(s) or are they on top of compliance with applicable safety standard(s)? In DoC, a suitable identification of the product should be included - a colour image of the product could be employed. Is there any guideline for this product image? One exterior front view photo like one on front cover of catalogue or a series of different views of the product? Article 6, point 4 regarding manufacturers’ obligations, to protect the health and safety of consumers, carry out sample testing of electrical equipment made available on the market. Does it mean the sample testing, i.e.. dielectric strength test, earth continuity test, etc. is taken in production at factory or in warehouse of destined market? Your guidance is highly appreciated! 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