Peter,
Yes, I am very fortunate to be part of this forum where there are many very
experience experts to discuss lots of interesting subjects. Chuck is one of
the best to share his esteemed knowledge and views. When I began my work,
there was no internet but only self-taught with magazines, reference books,
standards, regulations, etc. Now we can communicate and establish the
networking worldwide and must appreciate the contribution of IEEE Org.
Regards,
Scott
On 24/7/2017, 1:22 PM, "Pete Perkins" <peperkin...@cs.com> wrote:
Scott,
I hope that you realize how fortunate you are that you have a
professional colleague like Chuck who will take the time to walk you thru all
of the intricate details of this issue.
Most folks learn the hard way - trial and error.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201
p.perk...@ieee.org
-----Original Message-----
From: Scott Xe [mailto:scott...@gmail.com]
Sent: Saturday, July 22, 2017 9:25 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] AW: Harmonized standard withdrawn
Dear Chuck,
Thanks for sharing! Nice to have met you!
Best regards,
Scott
On 22/7/2017, 10:53 PM, "Chuck Seyboldt" <seybo...@gmail.com> wrote:
Dear Scott:
My experience about client (manufacturer, usually)
companies' expectations about territorial validity of my advice
is varied. Some of them have one-off projects going to a known
destination country. Others have products with indefinite
destination. The product will be made available via a
distributor in the community, and purchases come from "wherever,"
with that being possibly any of the EU and EFTA countries.
Most of my clients who hear about "CE" for the first
time, come to a belief that "CE" catches everything, everywhere
in the EU and EFTA. Not that they know about EFTA, just that
they think "CE" is some sort of EU passport, one size fits all.
For general talking purposes, their belief is both okay.
The problem is that real life doesn't allows follow the
general rule or the gross simplification. As an expert, your
client expects YOU to know the difference. That is why they hire
you. Some will assume that your positive test report is all they
need to justify "CE," and that's it. Done. Legal in all the EU.
See the Directive, see the test report, my expert "Certified my
product legal in the EU."
Many also think your test report makes them
lawsuit-proof, and that your company is now responsible for their
design. That isn't true either, but it is a very common belief.
Also as an expert, you have to adjust your message for
the client and product in front of you. It doesn't work to give
everybody the whole book of requirements and exceptions. You
might as well point them to the EUROPA website, and say, "the
requirements are in there."
I make a point to educate my clients about territorial
quirks that apply, if there are any, but only what applies to
their product. The mercury-wetted slip ring is a REAL example.
Forbidden in some countries, has nothing to do with a CE Marking
law. It is rare for me to confront a product that has elemental
mercury, so I rarely advise clients of this exception.
That the standards have National Differences is very
helpful to the expert. Otherwise the expert would have to study
the national laws in all the countries.
With respect to the extent of a market territory, the
original point of CE Marking was for exactly the commercial
purpose you suggested. Selling a UK product in Germany and
France and Spain and Italy and so on. Before CE, manufacturers
had to investigate the laws of 28 countries, and maybe apply 5
different standards (and maybe make 5 different products) to
cover the same 28 countries.
I live and work out of the US, and give the example to my
clients as basic tutorial about "CE," what if a toaster for
Indiana was not legal in New York? That was the situation in the
EU, before CE Marking.
Regards,
Chuck Seyboldt
(207) 893-0352
(207) 838-4026 Cellular
(800) 893-8142 Facsimile
At 10:15 (-0000) on 17.07.22, Scott Xe wrote:
> 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
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> > >
-----------------------------------------------
> > >
> > > 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
> > > -
> > >
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> > > 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>
> > >
> > >
> > >
> > > -
> > >
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> > > 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>
> > >
> >
> >
>
>
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----------------------------------------------------------------
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>
