[PSES] AW: [PSES] Notice about LVD compliance in a DoC for machinery?

[Dürrer Bernd]

Hi Oliver,

the Machinery Directive 2006/42/EC defines in Annex I, 1.5.1: "The safety 
objectives set out in Directive 73/23/EEC shall apply to machinery. However, 
the obligations concerning conformity assessment and the placing on the market 
and/or putting into service of machinery with regard to electrical hazards are 
governed solely by this Directive." 
(https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1582639746482&uri=CELEX:32006L0042#d1e32-35-1).

Please note that the mentioned standard EN 60204-1 is listed in the OJEU both 
under the Machinery Directive 
(https://ec.europa.eu/growth/system/files/2021-10/2006_42%20Machinery%20-%20Summary%20list%20of%20harmonised%20standards%20-%20Generated%20on%2015.10.2021.pdf)
 and under the Low Voltage Directive 
(https://ec.europa.eu/docsroom/documents/48357). However, to demonstrate 
compliance with the safety objectives of the Low Voltage Directive in a 
Declaration of Conformity with the Machinery Directive, there is no objection 
to reference any other harmonised standard that is listed in the OJEU under the 
LVD only (e.g. EN 61800-5-1).

Annex II of the Machinery Directive 
(https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1582639746482&uri=CELEX:32006L0042#d1e32-65-1)
 specifies the contents of the Declaration of Conformity, including point 4: "a 
sentence expressly declaring that the machinery fulfils all the relevant 
provisions of this Directive and where appropriate, a similar sentence 
declaring the conformity with other Directives and/or relevant provisions with 
which the machinery complies. These references must be those of the texts 
published in the Official Journal of the European Union". So, in your 
Declaration of Conformity with the Machinery Directive, you might add a few 
words that according to Machinery Directive 2006/42/EC, Annex I, 1.5.1, the 
product complies with the safety objectives of Low Voltage Directive 2014/35/EU.

Kind regards,

Bernd

-Ursprüngliche Nachricht-
Von: Oliver Betz 
Gesendet: Montag, 17. Januar 2022 17:41
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: [PSES] Notice about LVD compliance in a DoC for machinery?

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Hi all,

the "Guide to application of the Machinery Directive 2006/42/EC", Edition 2.2: 
https://eur04.safelinks.protection.outlook.com/?url=https%3A%2F%2Fec.europa.eu%2Fdocsroom%2Fdocuments%2F38022&data=04%7C01%7C%7Cbc7d4bfc28ba4faa6bd308d9d9d829cf%7C39288a38ff19432c80111cd9d0dff445%7C0%7C0%7C637780345575135877%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C3000&sdata=wnsRZdO5NT2wOizAh3ikhS%2BINGHE75dg1LgyHbF%2FL6I%3D&reserved=0
 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

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Re: [PSES] Notice about LVD compliance in a DoC for machinery?

[Douglas E Powell]

I have had resistance to placing both directives on a single DoC. Mostly
from strong proponents of the MD who believe that all equipment is under
their control. It was the same people who told me that even a mechanical
writing instrument such as a ball point pen is "machinery".

It should be noted however, that since the MD specifically invokes
Directive 73/23/EEC (LVD) for equipment with an electrical supply, you are
already covered in that case. To put it another way, the MD does not
replace the LVD, it incorporates it. However, as mentioned before, the
authorities may not be aware of this nuance.

By the way, the MD's reference to the LVD out of date and the LVD is now
2014/35/EU. So I might suggest if you include both LVD directives in your
documentation by stating something like Directive 73/23/EEC
(LVD) superseded by 2014/35/EU (LVD).

What a mess

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com
LinkedIn 



On Mon, Jan 17, 2022 at 10:25 AM MIKE SHERMAN 
wrote:

> While I pay close attention to the Guide, I am doubtful that going against
> its guidance to, in effect, over document, is sufficient to invalidate a
> DoC.
>
> I have not ever encountered resistance to listing both MSD and LVD---has
> anyone on this listserv?
>
> Mike Sherman
>
> On 01/17/2022 10:54 AM Charles Grasso  wrote:
>
>
> Other that the fact that the statement is  "the manufacturer’s EC
> Declaration of
> conformity *shall not* refer to the LVD but to the MD".?
>
> My guess is that you could invalidate the DoC if you violate that
> requirement.
>
>
> Chas
>
> On Mon, Jan 17, 2022 at 9:41 AM Oliver Betz  wrote:
>
> This message originated outside of DISH and was sent by:
> owner-emc-p...@listserv.ieee.org
>
> 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
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> emc-p...@ieee.org>
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>
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>
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> Mike Cantwell 
>
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>
>
>
> --
>
> Charles Grasso
>
> Dish Technologies
>
>  (c) 303-204-2974
>
> (h) 303-317-5530
>
> (e ) charles.gra...@dish.com
>
> (e2) chasgra...@gmail.com
> -
> 
>
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>
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>
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> -
> 
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> emc-p...@ieee.org>
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Re: [PSES] Notice about LVD compliance in a DoC for machinery?

[Julia Curson]

We have also had issues with Turkish customs interpretation of the Directives 
and it’s nice to know we are not alone.

I’m curious now and hoping the knowledgable readership can explain, how does 
the law work in Turkey/ EU around these interpretations if they are off base? 
How do they get normalised usually?

Thanks,
Julia

> On 17 Jan 2022, at 19:39, Oliver Betz  wrote:
> 
> Charlie Blackham wrote:
> 
>> The issue is that the legal bit stating that only the MD applies and not
>> the LVD is in the MD (below) and not included in the list of exemptions
>> in Annex II of the LVD
>> 
>> 1.5. RISKS DUE TO OTHER HAZARDS
>> 
>> 1.5.1. */Electricity supply/*
>> 
>> Where machinery has an electricity supply, it must be designed,
>> constructed and equipped in such a way that
>> all hazards of an electrical nature are or can be prevented.
>> 
>> The safety objectives set out in Directive 73/23/EEC shall apply to
>> machinery. However, the obligations
>> concerning conformity assessment and the placing on the market and/or
>> putting into service of machinery
>> with regard to electrical hazards are governed solely by this Directive.
> 
> these obligations are fulfilled (by applying the harmonized standards),
> and only mentioning an additional, effectively "non-applicable"
> directive shouldn't change this in my opinion.
> 
>> My view is that Turkish customs are incorrect, but there’s little point
>> in trying to argue with them,
> 
> thanks for the confirmation, this is exactly my view of the situation.
> 
> Thanks also to the other posters.
> 
> 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 
> 
> 
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> 
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Re: [PSES] Notice about LVD compliance in a DoC for machinery?

[Oliver Betz]

Charlie Blackham wrote:


The issue is that the legal bit stating that only the MD applies and not
the LVD is in the MD (below) and not included in the list of exemptions
in Annex II of the LVD

1.5. RISKS DUE TO OTHER HAZARDS

1.5.1. */Electricity supply/*

Where machinery has an electricity supply, it must be designed,
constructed and equipped in such a way that
all hazards of an electrical nature are or can be prevented.

The safety objectives set out in Directive 73/23/EEC shall apply to
machinery. However, the obligations
concerning conformity assessment and the placing on the market and/or
putting into service of machinery
with regard to electrical hazards are governed solely by this Directive.


these obligations are fulfilled (by applying the harmonized standards),
and only mentioning an additional, effectively "non-applicable"
directive shouldn't change this in my opinion.


My view is that Turkish customs are incorrect, but there’s little point
in trying to argue with them,


thanks for the confirmation, this is exactly my view of the situation.

Thanks also to the other posters.

Oliver

-

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Re: [PSES] Notice about LVD compliance in a DoC for machinery?

[MIKE SHERMAN]

While I pay close attention to the Guide, I am doubtful that going against its 
guidance to, in effect, over document, is sufficient to invalidate a DoC.

I have not ever encountered resistance to listing both MSD and LVD---has anyone 
on this listserv?

Mike Sherman


> On 01/17/2022 10:54 AM Charles Grasso  wrote:
> 
> 
> Other that the fact that the statement is  "the manufacturer’s EC 
> Declaration of
> conformity shall not refer to the LVD but to the MD".?
> 
> My guess is that you could invalidate the DoC if you violate that 
> requirement.
> 
> 
> Chas
> 
> On Mon, Jan 17, 2022 at 9:41 AM Oliver Betz  mailto:list...@gmx.net > wrote:
> 
> > > This message originated outside of DISH and was sent by: 
> owner-emc-p...@listserv.ieee.org mailto:owner-emc-p...@listserv.ieee.org
> > 
> > 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 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 (including how to 
> > unsubscribe)
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> > 
> > For policy questions, send mail to:
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> > David Heald: mailto:dhe...@gmail.com >
> > 
> > > 
> 
> --
> 
> Charles Grasso
> 
> Dish Technologies
> 
>  (c) 303-204-2974
> 
> (h) 303-317-5530
> 
> (e ) charles.gra...@dish.com mailto:charles.gra...@dish.com
> 
> (e2) chasgra...@gmail.com mailto:chasgra...@gmail.com
> 
> -
> 
> 
> This message is from the IEEE Product Safety Engineering Society emc-pstc 
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> mailto:emc-p...@ieee.org >
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Re: [PSES] Notice about LVD compliance in a DoC for machinery?

[MIKE SHERMAN]

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  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 
> 
> 
> All emc-pstc postings are archived and searchable on the web at:
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> 
> 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/
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> List rules: http://www.ieee-pses.org/listrules.html
> 
> For help, send mail to the list administrators:
> Scott Douglas 
> Mike Cantwell 
> 
> For policy questions, send mail to:
> Jim Bacher:  
> David Heald: 

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Re: [PSES] Notice about LVD compliance in a DoC for machinery?

[Charlie Blackham]

Oliver

The issue is that the legal bit stating that only the MD applies and not the 
LVD is in the MD (below) and not included in the list of exemptions in Annex II 
of the LVD

1.5. RISKS DUE TO OTHER HAZARDS
1.5.1. Electricity supply
Where machinery has an electricity supply, it must be designed, constructed and 
equipped in such a way that
all hazards of an electrical nature are or can be prevented.
The safety objectives set out in Directive 73/23/EEC shall apply to machinery. 
However, the obligations
concerning conformity assessment and the placing on the market and/or putting 
into service of machinery
with regard to electrical hazards are governed solely by this Directive.

(noting that 73/23/EEC was the first iteration of the LVD)

My view is that Turkish customs are incorrect, but there’s little point in 
trying to argue with them, so I would send them a DoC that they are happy with, 
listing the relevant standard(s) you have applied.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
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From: Charles Grasso 
Sent: 17 January 2022 16:55
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] Notice about LVD compliance in a DoC for machinery?

Other that the fact that the statement is  "the manufacturer’s EC Declaration of
conformity shall not refer to the LVD but to the MD".?

My guess is that you could invalidate the DoC if you violate that requirement.


Chas

On Mon, Jan 17, 2022 at 9:41 AM Oliver Betz 
mailto:list...@gmx.net>> wrote:
This message originated outside of DISH and was sent by: 
owner-emc-p...@listserv.ieee.org

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

-

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--
Charles Grasso
Dish Technologies
 (c) 303-204-2974
(h) 303-317-5530
(e ) charles.gra...@dish.com
(e2) chasgra...@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>>

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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For help, send mail to the list administrators:
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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 


All emc-pstc postings are archived and searchable on the web at:
htt

Re: [PSES] Notice about LVD compliance in a DoC for machinery?

[Charles Grasso]

Other that the fact that the statement is  "the manufacturer’s EC
Declaration of
conformity *shall not* refer to the LVD but to the MD".?

My guess is that you could invalidate the DoC if you violate that
requirement.


Chas

On Mon, Jan 17, 2022 at 9:41 AM Oliver Betz  wrote:

> This message originated outside of DISH and was sent by:
> owner-emc-p...@listserv.ieee.org
>
> 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 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher:  
> David Heald: 
>


-- 

Charles Grasso

Dish Technologies

 (c) 303-204-2974

(h) 303-317-5530

(e ) charles.gra...@dish.com

(e2) chasgra...@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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

[PSES] Notice about LVD compliance in a DoC for machinery?

[Oliver Betz]

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 

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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: