Hi Chuck,
Appreciate your detail explanation! You are very experience in this area!
Absolutely important, we must clear it up before the contract is signed off.
As you mentioned the general perception of CE marking, the product can be sold
in EU all 28 countries. Is it really an expectation from the buyers and the
users? Can an UK product be sold to Germany? I doubt the commercial people
will do so! A product can be sold to all 28 member countries is a long term
vision, probably not now! Do the people believe they can do so in EU? If they
do, we do not need to tell them all the details about ND and always test the
products to all NDs regardless of which country of EU to go.
Regards,
Scott
On 22/7/2017, 9:48 PM, "Chuck Seyboldt" <seybo...@gmail.com> wrote:
Dear Scott:
What I meant by that was to describe a legal relationship
between a standard and a country, and that relationship in the
context you described of a competitive test house not wanting to
unnecessarily jack up prices.
I am picturing a hypothetical standard. That standard
has a general part, and several "National Differences" parts. I
took it that you wanted to know how to deal with this situation,
faced with a customer, and maybe the customer and maybe you and
maybe neither knowing which countries the product would be sold
in.
I say that either you educate the customer, because
whether he says it or not, he is naive about the legal
relationship between the standard and the countries and he
expects you to tell him how his unstated expectations might not
be met. In other words, you tell him he can affix the CE
marking, and he assumes this is the same as you telling him he
can now legally sell in all of he Community countries.
When his goods are impounded at the Swedish border, and
he is told they are illegal because they have a mercury-wetted
slip ring, he is going to ask you to pay for his unexpected
costs.
Back to my cryptic statement, this is the sort of thing
you should tell him before he contracts with you for testing:
Standard No. EN 12345-6-78 Applies
Testing to EN 12345-6-78, good for all countries EXCEPT
Sweden, Denmark, and Poland
Cost = $ 9,876.55
Additional Testing required for Sweden and Denmark
Cost = $1,111.11
Additional Testing required for Poland
Cost = $ 432.42
Now he knows the territorial limits of your test report
(driven by National Differences in the standard), and if he wants
to sell in Sweden, it's on him to ask you what is special about
Sweden.
Regards,
Chuck Seyboldt
(207) 893-0352
(207) 838-4026 Cellular
(800) 893-8142 Facsimile
At 09:24 (-0000) on 17.07.22, Scott Xe wrote:
> Dear Chuck,
>
> What is exact meaning of the general report that covers XYZ
> countries, and National Differences in Country A adds $$,
> Country B adds $$, etc.? Are they different countries for
> general part and national differences? To the buyers, they are
> only interested in the products that legally sell to their
> markets.
>
> Thanks and regards,
>
> Scott
>
>
> On 22/7/2017, 8:52 PM, "Chuck Seyboldt" <seybo...@gmail.com> wrote:
>
>
> Dear Scott:
>
> On that issue, National Differences, if you have told your
> customer you are an expert on European Compliance, they will
> expect expert advice. If National Differences affects their
> ability to sell, they will expect you will have advised them
> of the limits associated with your report.
>
> It is obviously best to tell them in advance that the
> general report covers XYZ countries, and National Differences in
> Country A adds $$, Country B adds $$, etc.
>
> Basically, pass the buck to your customers and potential
> customers, by informing and educating them.
>
> If you, the expert, don't cover this ground, and their
> products are barred from some country, they will be unhappy. The
> ramifications of this are highly variable. Lawsuits over this
> type of subject are common.
>
> Regards,
> Chuck Seyboldt
>
> (207) 893-0352
> (207) 838-4026 Cellular
> (800) 893-8142 Facsimile
>
> At 07:49 (-0000) on 17.07.22, Scott Xe wrote:
>
> > Dear Steli,
> >
> > Thanks for your advice! Do National Differences mean National
> > conditions and National deviations normally in Annex of the
> > standard?
> >
> > How can a testing house ignore the National Differences? I
> > dare to guest the applicants may not decide where the goods to
> > be sold when applies for the testing. Thus the testing house
> > either does not test the national differences or test all
> > national differences. As a commercial testing house, testing
> > them all will increase the testing charges reducing their
> > competitive edge on the market. If the applicant indicates the
> > destined market, the testing house cannot avoid the testing to
> > national differences and deviations. The buyer must be careful
> > to accept the supplier’s evidence when they receive those
> > testing report and see if it fits for purpose.
> >
> > Regards,
> >
> > Scott
> >
> >
> >
> > On 22/7/2017, 6:01 PM, "Steli Loznen" <rshap...@post.tau.ac.il>
wrote:
> >
> > Dear Scott,
> > In addition to the Mr. Woodgate comment, please be informed that
in the frame of the CB Scheme need to pay attention to "National Differences"
on IEC standards. This is an important issue which not all time is addressed by
the testing houses which issue the CB Test Reports.
> > Best Regards,
> > Steli
> >
> >
> >
> > Steli Loznen, M.Sc., SM-IEEE
> > Member of BoG IEEE-PSES
> > Convener IEC 62A/MT 62354
> > 17-3 Shaul HaMelech Blvd.
> > Tel Aviv 6436719
> > Israel
> > Tel:+972-3-6912668
> > Fax:+972-3-6913988
> > Mobile:+972-54-7245794
> > e-mail: sloz...@ieee.org
> >
> > -----Original Message-----
> > From: Scott Xe [mailto:scott...@gmail.com]
> > Sent: Saturday, July 22, 2017 11:54 AM
> > To: EMC-PSTC@LISTSERV.IEEE.ORG
> > Subject: Re: [PSES] AW: Harmonised standard withdrawn
> >
> > Dear John,
> >
> > It is a good point to note!
> >
> > Thanks and regards,
> >
> > Scott
> >
> >
> > On 22/7/2017, 4:37 PM, "John Woodgate" <jmw1...@btinternet.com>
wrote:
> >
> > The EN and the IEC are *never* identical, especially now that
the ENs have to include a succession of 'Z' annexes. Large parts of the
technical content may well be identical, but the ENs include a lot of European
'baggage', which can't safely be ignored.
> >
> > With best wishes DESIGN IT IN! OOO – Own Opinions Only
> > www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh
England
> >
> > Sylvae in aeternum manent.
> >
> > -----Original Message-----
> > From: Scott Xe [mailto:scott...@gmail.com]
> > Sent: 22 July 2017 09:13
> > To: John Woodgate <jmw1...@btinternet.com>
> > Subject: Re: [PSES] AW: Harmonised standard withdrawn
> >
> > Hi John,
> >
> > I notice the CB reports that they will conduct the test
according to IEC standard and the standards for destined market, i.e. EN for
EU. As usual, EN standards are derived from IEC standard. If the IEC standard
is listed below the EN standard without indication of modified, the IEC
compliance report can be used as self-declaration of conformity to the
directive due to the fact that both EN and IEC standards are identical.
> >
> > Regards,
> >
> > Scott
> >
> >
> > On 22/7/2017, 2:24 PM, "John Woodgate"
<jmw1...@btinternet.com> wrote:
> >
> > That isn't a 'listing' of the IEC standards, it's an
indication of what the EN was derived from. You can see that, because some of
the IEC standards are described as '(modified)'.
> >
> > With best wishes DESIGN IT IN! OOO – Own Opinions Only
> > www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh
England
> >
> > Sylvae in aeternum manent.
> >
> > -----Original Message-----
> > From: Scott Xe [mailto:scott...@gmail.com]
> > Sent: 22 July 2017 03:53
> > To: John Woodgate <jmw1...@btinternet.com>;
EMC-PSTC@LISTSERV.IEEE.ORG
> > Subject: Re: [PSES] AW: Harmonised standard withdrawn
> >
> > Dear John,
> >
> > The attached HS list does have IEC standards. Do they
have other meaning that I might incorrectly interpret it?
> >
> > Thanks and regards,
> >
> > Scott
> >
> >
> > On 22/7/2017, 1:08 AM, "John Woodgate"
<jmw1...@btinternet.com> wrote:
> >
> > IEC standards are rarely, if ever, notified in the
OJ, because they are not harmonized so all EU/CENELEC countries do not have to
accept them.
> >
> > With best wishes DESIGN IT IN! OOO – Own Opinions Only
> > www.jmwa.demon.co.uk J M Woodgate and Associates
Rayleigh England
> >
> > Sylvae in aeternum manent.
> >
> > -----Original Message-----
> > From: Scott Xe [mailto:scott...@gmail.com]
> > Sent: 21 July 2017 17:50
> > To: EMC-PSTC@LISTSERV.IEEE.ORG
> > Subject: Re: [PSES] AW: Harmonised standard withdrawn
> >
> > Hi Durrer,
> >
> > Both IEC and EN 60335-2-24 were in the harmonised
standard list of OJEU before they were removed. Regarding the national
standard BS EN 60335-2-24 should be technically identical with EN 60335-2-24.
Although it is still valid in BSI website, the HS removal is due to UK
objection. It does not make sense using BS EN 60335-2-24 to declare the
compliance with LVD.
> >
> > It is good suggestion to take care this known issue
in risk assessment required in LVD. As this issue is being discussed in IEC to
EN standard conversion. For the time being, the latest IEC A2 amendment seems
a reasonable reference to address the fire risk.
> >
> > Regards,
> >
> > Scott
> >
> >
> > On 21/7/2017, 4:16 PM, "Dürrer Bernd"
<bernd.duer...@wilo.com> wrote:
> >
> > Dear Scott,
> >
> > The removal of the reference to EN 60335-2-24
from the OJEU means that compliance with this standard does not provide the
presumption of conformity as defined in Article 12 of LVD. Actually, the
nationally adopted versions of this standard are still valid (e.g. BS EN
60335-2-24, https://shop.bsigroup.com/ProductDetail/?pid=000000000030236214).
As IEC 60335-2-24 is not listed as an international standard in the OJEU, I do
not see any advantage in declaring CE compliance with the IEC version,
especially as the objection raised by the UK against the use of highly
flammable materials would also apply to fridges compliant with IEC 60335-2-24.
> >
> > As risk analysis (preferably according to CENELEC
Guide 32) is a mandatory part of the technical documentation (LVD, Annex III,
Module A, 2.), the manufacturer is bound to consider the findings in UK's
objection and to avoid the use of such materials even if they are compliant
with the IEC/EN standard. Please be aware that the obligations of the
manufacturer (LVD, Art. 6) also include the monitoring of products already in
the market and to take corrective measures if it is found that a product
presents a risk.
> >
> > Regarding a new product, you may still refer to
EN 60335-2-24, but it will not give you presumption of conformity. With the CE
DoC you declare that your electrical equipment provides "a high level of
protection of health and safety of persons, and of domestic animals and
property" (LVD, Art. 1), using the standard as a technical means to demonstrate
compliance, but considering also risks that are not adequately addressed in the
standard.
> >
> > Kind regards,
> >
> > Bernd
> >
> > Von: Wiseman, Josh UTC CCS
[mailto:joshua.e.wise...@carrier.utc.com]
> > Gesendet: Donnerstag, 20. Juli 2017 21:31
> > An: EMC-PSTC@LISTSERV.IEEE.ORG
> > Betreff: Re: [PSES] Harmonised standard withdrawn
> >
> > Scott,
> >
> > You can continue to use EN 60335-1 and reference
IEC 60335-2-24 to show compliance. Just because the EN is withdrawn doesn’t
mean the IEC is no longer valid. Knowing now about the plastic issue, maybe
you do some other evaluation method for it to ensure it’s safe to be used in
that application.
> >
> > Josh Wiseman
> > Senior Compliance Engineer
> >
> > Taylor Company
> > Joshua Wiseman
> > Senior Compliance Engineer
> > 750 N. Blackhawk Blvd. | Rockton, IL 61072
> > Office: 815.624.5628 | Cell: 815.262.5517 | Fax:
815.624.5181
> > http://www.taylor-company.com/ |
https://twitter.com/TheTaylorCo | http://www.youtube.com/TheTaylorCompany
> > -----------------------------------------------
> > This message is intended only for the
recipient(s) named above. It may contain confidential or legally privileged
information. If you are not the intended recipient, do not read, copy, use or
circulate this message. Instead, please notify the sender immediately by
replying to this message and then delete it from your system. Internet
communications are not secure. While every reasonable effort has been made to
ensure that this communication has not been tampered with, Taylor Company
cannot be responsible for alterations made to the contents of this message
without its express consent, and Taylor Company accepts no responsibility for
changes to or interception of this message after it was sent or for any damage
to the recipient's systems or data caused by this message or its attachments.
Opinions, conclusions and other information contained in this message that do
not relate to the official business of Taylor Company shall be understood as
neither given nor e ndorsed by Taylor Co mpany. Please also note that messages
to or from Taylor Company may be monitored to ensure compliance with Taylor
Company policies and standards and to protect our business.
> > -----------------------------------------------
> >
> > From: Scott Xe [mailto:scott...@gmail.com]
> > Sent: Thursday, July 20, 2017 9:38 AM
> > To: mailto:EMC-PSTC@LISTSERV.IEEE.ORG
> > Subject: [External] [PSES] Harmonised standard
withdrawn
> >
> > The harmonised standard EN 60335-2-24 is removed
from the harmonised standard list on OJEU. The common compliance route of
self-declaration of conformity to LVD using harmonised standard becomes lost.
What are other options to demonstrating the compliance with LVD?
> >
> > Thanks and regards,
> >
> > Scott
> > -
> >
----------------------------------------------------------------
> > 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 <mailto:emc-p...@ieee.org>
> > All emc-pstc postings are archived and searchable
on the web at:
https://urldefense.proofpoint.com/v2/url?u=http-3A__www.ieee-2Dpses.org_emc-2Dpstc.html&d=DwMFaQ&c=ilBQI1lupc9Y65XwNblLtw&r=RyQ6Fr0g7aHfEQCV0zeIZ5rmc48Lfs-2bcf6A3GtyRc&m=EzMmtVsAChI0PUoxZd-jG3QWM48V9wWIGTfBBod8eyM&s=VIRQq3ILdGSf6dvMzNp5OWiCAeSuh8Ssf9WYmfhEpz0&e=
> > Attachments are not permitted but the IEEE PSES
Online Communities site at
https://urldefense.proofpoint.com/v2/url?u=http-3A__product-2Dcompliance.oc.ieee.org_&d=DwMFaQ&c=ilBQI1lupc9Y65XwNblLtw&r=RyQ6Fr0g7aHfEQCV0zeIZ5rmc48Lfs-2bcf6A3GtyRc&m=EzMmtVsAChI0PUoxZd-jG3QWM48V9wWIGTfBBod8eyM&s=3zDWGtj2JcDcnfAvvRC9oYVUDo7raetrj4p-ATYjkJ0&e=
can be used for graphics (in well-used formats), large files, etc.
> > Website:
https://urldefense.proofpoint.com/v2/url?u=http-3A__www.ieee-2Dpses.org_&d=DwMFaQ&c=ilBQI1lupc9Y65XwNblLtw&r=RyQ6Fr0g7aHfEQCV0zeIZ5rmc48Lfs-2bcf6A3GtyRc&m=EzMmtVsAChI0PUoxZd-jG3QWM48V9wWIGTfBBod8eyM&s=9w0yYDC69Ng_SmSEIaEmWhzThHwIfwGAhDPAow8jUyY&e=
> > Instructions:
https://urldefense.proofpoint.com/v2/url?u=http-3A__www.ieee-2Dpses.org_list.html&d=DwMFaQ&c=ilBQI1lupc9Y65XwNblLtw&r=RyQ6Fr0g7aHfEQCV0zeIZ5rmc48Lfs-2bcf6A3GtyRc&m=EzMmtVsAChI0PUoxZd-jG3QWM48V9wWIGTfBBod8eyM&s=_tfBUhxNcZTrOJohdxg3nlXk7j3uL6EehFkkkYcxflA&e=
> > List rules:
https://urldefense.proofpoint.com/v2/url?u=http-3A__www.ieee-2Dpses.org_listrules.html&d=DwMFaQ&c=ilBQI1lupc9Y65XwNblLtw&r=RyQ6Fr0g7aHfEQCV0zeIZ5rmc48Lfs-2bcf6A3GtyRc&m=EzMmtVsAChI0PUoxZd-jG3QWM48V9wWIGTfBBod8eyM&s=-uUeSArkKHSGt0s1-cu4EGS5VC9rX49ocK0RqXkb6Sw&e=
> > For help, send mail to the list administrators:
> > Scott Douglas <mailto:sdoug...@ieee.org>
> > Mike Cantwell <mailto:mcantw...@ieee.org>
> > For policy questions, send mail to:
> > Jim Bacher <mailto:j.bac...@ieee.org>
> > David Heald <mailto: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 <mailto: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://www.ieee-pses.org/list.html
> > List rules:
http://www.ieee-pses.org/listrules.html
> > For help, send mail to the list administrators:
> > Scott Douglas <mailto:sdoug...@ieee.org>
> > Mike Cantwell <mailto:mcantw...@ieee.org>
> > For policy questions, send mail to:
> > Jim Bacher <mailto:j.bac...@ieee.org>
> > David Heald <mailto:dhe...@gmail.com>
> >
> > ________________________________
> >
> >
> > WILO SE
> > Nortkirchenstrasse 100, 44263 Dortmund
> > Amtsgericht Dortmund, HRB 21356
> > www.wilo.com
> >
> > Vorstand/Executive Board:
> > Oliver Hermes (Vorsitzender/Chairman), Dr. Markus
Beukenberg, Carsten Krumm, Eric Lachambre, Mathias Weyers
> > Aufsichtsratsvorsitzender/Chairman of the
Supervisory Board:
> > Prof. Dr. Norbert Wieselhuber
> >
> > Dieses Dokument ist vertraulich zu behandeln. Die
Weitergabe sowie Vervielfaeltigung, Verwertung und Mitteilung seines Inhalts
ist nur mit unserer ausdruecklichen Genehmigung gestattet. Alle Rechte
vorbehalten, insbesondere fuer den Fall der Schutzrechtsanmeldung.
> >
> > This document has to be treated confidentially.
Its contents are not to be passed on, duplicated, exploited or disclosed
without our expressed permission. All rights reserved, especially the right to
apply for protective rights.
> >
> > -
> >
----------------------------------------------------------------
> > 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://www.ieee-pses.org/list.html
(including how to unsubscribe)
> > List rules:
http://www.ieee-pses.org/listrules.html
> >
> > For help, send mail to the list administrators:
> > Scott Douglas <sdoug...@ieee.org>
> > 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://www.ieee-pses.org/list.html
(including how to unsubscribe) List rules:
http://www.ieee-pses.org/listrules.html
> >
> > For help, send mail to the list administrators:
> > Scott Douglas <sdoug...@ieee.org>
> > 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://www.ieee-pses.org/list.html (including how
to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html
> >
> > For help, send mail to the list administrators:
> > Scott Douglas <sdoug...@ieee.org>
> > 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://www.ieee-pses.org/list.html (including how to
unsubscribe)
> > List rules: http://www.ieee-pses.org/listrules.html
> >
> > For help, send mail to the list administrators:
> > Scott Douglas <sdoug...@ieee.org>
> > 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://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html
For help, send mail to the list administrators:
Scott Douglas <sdoug...@ieee.org>
Mike Cantwell <mcantw...@ieee.org>
For policy questions, send mail to:
Jim Bacher: <j.bac...@ieee.org>
David Heald: <dhe...@gmail.com>
