Dear Group,
Some correction is needed here.
Notified body involvement is mandatory when harmonized standards can not
be used or are not available for the equipment at hand. Or if the
manufacturer wants to use its own testing routine. In all these cases
the NB needs to assess the equipment against the essential requirements
(annex IV).
Self declaration is only allowed if all applicable harmonized standards
are being (fully) followed.
Kind regards,
Willem Jan Jong
Manager Product Certification
Telefication
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of ce-test,
qualified testing bv - Gert Gremmen
Sent: zaterdag, 22 juni, 2013 4:20 PM
To: Crane, Lauren; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: Is a Notified Body really needed to assess electrical
safety for a 12VDC RTTE device?
Hi Lauren,
As far as my understanding goes, without any
further study regarding your arguments, I remember that for NO
RTTED equipment a NoBo is mandatory.
Said differently, the intention of the RTTED has always been
(and I was always learned ) that the manufacturers declaration
is sufficient for all. NoBo's are mandatory for some machines,
medical equipment class 2 and higher and a number of other
directives that cover high risk equipment.
The same is true for the EMCD and the LVD.
In general the tendency in Europe is to reduce the role of the NoBo's.
The fault you make in my view, is that you state that the product is not
in the scope
of the LVD (12V), so you need to apply annex III, IV or V (instead of
II, IV or V),
but as the voltage requirement is removed, all equipment falls in the
(modified) LVD scope.
In my experience most equipment is assessed as office equipment (EN
60950)
Hope this helps...
Regards,
Ing. Gert Gremmen, BSc
g.grem...@cetest.nl
www.cetest.nl
Kiotoweg 363
3047 BG Rotterdam
T 31(0)104152426
F 31(0)104154953
Before printing, think about the environment.
Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Crane, Lauren
Verzonden: Friday, June 21, 2013 11:59 PM
Aan: EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Is a Notified Body really needed to assess electrical safety
for a 12VDC RTTE device?
Dear Experts, I am looking for help in understanding how to correctly
address LVD concerns within the RTTED.
The RTTED has three main concerns (essential requirements),
1. Radio spectrum issues [art. 3.2]
2. Low voltage safety [art. 3.1.a] - LVD
3. Electromagnetic compatibility [art. 3.1.b] - EMCD
EU guidance says each of these concerns may be addressed separately.
[Csion guide Apr 2009 6.1 first para]
The low voltage directive (LVD) as a stand alone requirement, doesn't
apply until DC input voltages reach 75V, but the RTTED requires the LVD
to apply regardless of voltage [art. 3.1.a -end]. RTTED also says that
the conformity assessment procedures of the LVD may be used where the
item is within scope of the LVD (e.g., electrical equipment operating
from 80VDC) [art. 10.2]. If a product is not within scope of the LVD on
its own (e.g., operating from 12 VDC), one must use the conformity
assessment procedures defined in the RTTED (I think).
In the RTTED the only assessment procedure that does not require a
notified body is 'production control' (Annex II). The Production
Control method (Annex II) is *not* allowed for equipment with radio
transmitters [art. 10.3,4,5].
So if I have a very low voltage device (e.g. 12 volts) with a data
transmission function I must, at first glance, use RTTED conformity
assessment methods (and thereby a Notified Body), to assess the LVD
concerns.
I have already had my widget assessed for radio spectrum issues and EMC
issues by Notified Bodies. It looks like I need a notified body for the
LVD stuff too. If the voltages were higher, I could self declare LVD
compliance. This does not make sense. What am I misunderstanding?
Regards,
Lauren Crane
KLA-Tencor
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