In my opinion, the Guide is making too fine a distinction. I know that when I examine a DoC for electrically powered machinery, I expect to see both the MSD and LVD. This gives me some assurance that the manufacturer has considered both aspects.
Also in my experience, Turkish customs sometimes prefers their own logic over that expressed in the Guide or similar documents. I would just list both MSD and LVD on the DoC. Just be sure your technical file is clear. Mike Sherman Retired Product Safety Engineer > On 01/17/2022 10:40 AM Oliver Betz <list...@gmx.net> wrote: > > > Hi all, > > the "Guide to application of the Machinery Directive 2006/42/EC", > Edition 2.2: https://ec.europa.eu/docsroom/documents/38022 states: > > "...Thus, whilst machinery with an electrical supply, which is not in > any of the categories listed in Article 1(2) (k) of MD, shall fulfil the > safety objectives of the LVD, the manufacturer’s EC Declaration of > conformity shall not refer to the LVD but to the MD". > > Yet, EN60204-1:2018 is listed in the LVD summary of harmonised standards. > > Would it harm to state also the LVD conformity in a DoC for machinery? > > The above mentioned guide writes that the DoC "shall *not* refer to the > LVD but to the MD" but I'm not sure about the intention behind. > > And we have problems with Turkish customs insisting that the DoC shall > list also LVD compliance. > > I wonder whether / how I can phrase an elegant note on the LVD compliance. > > Any ideas? > > Oliver > > - > ---------------------------------------------------------------- > 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>
