Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-19 Thread John Woodgate
In message 
, 
dated Mon, 19 Nov 2012, "McInturff, Gary"  
writes:



I'm also just curious what countries don't use Arabic numerals?


Almost all countries that are not Arabic, in fact! 'Our' numerals are a 
corrupted version of true Arabic numerals.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-19 Thread Peter_Kelleher
In fact, the Note 3 at the bottom of the OJ listing itself provides a hint as 
to what is expected in referencing the standard:



Note 3: In case of amendments, the referenced standard is EN C:, its 
previous amendments, if any, and the new, quoted amendment...



While the Note is there to offer guidance on how to handle amendments, it seems 
reasonable to infer that the same format would apply to the base standard as 
well.



The important point is to make an unambiguous reference so that the reader of 
the DoC knows  exactly what standard you applied.



If the standard numbers and amendments are  listed along with their respective 
years of publication* on the DoC, that will constitute an unambiguous reference.

The title of the standard is not necessary (and may not even be helpful) to 
make an unambiguous reference.



So:



EN 60950-1:2006 + A11:2009 + A12:2011 is an unambiguous reference.



Examples of ambiguous references would be:

'EN 60950'

'EN 60950-1 +applicable amendments'



I have never seen a case where an authority challenged an unambiguous reference 
such as the above with or without the title of the standard listed.



Regards



Peter.





*One could probably argue that the year of the amendments is not necessary if 
the base standard is correctly identified. i.e. There will only ever by one 
'A11' to  EN 60950-1:2006 irrespective of what year it is published.









-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Kunde, Brian
Sent: 19 November 2012 14:10
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EU-DoC - list of applied standards with full title



I think this all begs the question, has anyone experienced any problems with 
their EU DOC by not providing the Standard's Title? If so, what was the 
objection and what was necessary to resolve it?



The official titles of directives and standards are often way too long and 
often more confusing then descriptive.



We reference directives and standards on our EU DOC by their number and date 
and follow it with a brief description and sometimes additional useful 
information. Such as:



EN 61010-1:2010   Safety of Laboratory Equipment



Or



EN55011:2007+A2:2007RF EmissionsGroup 1, Class A





The directives requirements are, "a reference to the harmonized standards 
used", so I would think as long as you provide enough information so it is 
clear what the standards are you should be ok.



We think about what information our customers and others might want to see in 
the DOC and include it if we can. The more descriptive we are the less 
questions we get from the field, which saves us time and money.



We have used this approach for over 16 years and have not had any problems or 
holdups, so far.



The Other Brian







-Original Message-

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge Knudsen

Sent: Sunday, November 18, 2012 9:22 AM

To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG

Subject: RE: EU-DoC - list of applied standards with full title



Hello Kris,



About 10 years ago my company Niros Telecommunication was contacted by the 
Belgium Authority whom told that the DoC should be written in Dutch as well as 
in French and German.



At that time we had a DoC written in English, German, French and Italian.



We changed to a combination of a short form DoC and one complete DoC written in 
English.



Short form in English:

Hereby, [Name of manufacturer], declares that this [type of equipment] is in 
compliance with the essential requirements and other relevant provisions of 
Directive 1999/5/EC.



The short form DoC can be found at the link below:



http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e

n.htm

See "23. Form of the manufacturers' declaration to be put into the user's 
manual"



We used this form for DoC for the ATEX directive as well.



Best regards



Helge Knudsen



Former Test & Approval manager

Niros Telecommunication

Denmark





-Original Message-

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier 
Kristiaan

Sent: 18. november 2012 14:13

To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG

Subject: RE: EU-DoC - list of applied standards with full title



Nick,



My country, Belgium, has 3 official national languages, Dutch, French and 
German. The most recent draft of the Belgian transposition proposal of the RoHS 
Directive states now that the EU DoC should be drawn up in a language easily 
understandable by authorities. While the authorities have the right to request 
a translation in one of the official languages, it allows the use of English. 
Hopefull other countries follow that example as it worked well for > 20 years.



Best regards,

Kris Carpentier



-Original Message-

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams

Sent: zondag 18 november 2012 11:

Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-19 Thread Ken Wyatt
While I was with HP and Agilent, we always listed the standard (as "IEC/EN"), 
the applicable annexes, the date of issue, an abbreviated title and the 
abbreviated test limits. Never had a problem, as far as I know.
___
Kenneth Wyatt
Wyatt Technical Services LLC
Woodland Park, CO
Email Me! | Web Site | Blog
The EMC Blog (T&M World)
Subscribe to Newsletter
Connect with me on LinkedIn

On Nov 19, 2012, at 9:30 AM, McInturff, Gary wrote:

> I'm also just curious what countries don't use Arabic numerals? I would have 
> been able to understand what standard was in play from what you sent below if 
> you had sent it in Dutch, or Spanish. Group and class
> Groep 1, klasse A and Grupo 1, clase A, took about 30 seconds to actually 
> translate and I suspect that I can remember them the next time I see them in 
> this form. 
> Requiring the name in the local language is killing a fly with a 
> sledgehammer. 
> Gary
> 
> 
> -Original Message-
> From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
> Sent: Monday, November 19, 2012 6:10 AM
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: Re: [PSES] EU-DoC - list of applied standards with full title
> 
> I think this all begs the question, has anyone experienced any problems with 
> their EU DOC by not providing the Standard's Title? If so, what was the 
> objection and what was necessary to resolve it?
> 
> The official titles of directives and standards are often way too long and 
> often more confusing then descriptive.
> 
> We reference directives and standards on our EU DOC by their number and date 
> and follow it with a brief description and sometimes additional useful 
> information. Such as:
> 
> EN 61010-1:2010   Safety of Laboratory Equipment
> 
> Or
> 
> EN55011:2007+A2:2007RF EmissionsGroup 1, Class A
> 
> 
> The directives requirements are, "a reference to the harmonized standards 
> used", so I would think as long as you provide enough information so it is 
> clear what the standards are you should be ok.
> 
> We think about what information our customers and others might want to see in 
> the DOC and include it if we can. The more descriptive we are the less 
> questions we get from the field, which saves us time and money.
> 
> We have used this approach for over 16 years and have not had any problems or 
> holdups, so far.
> 
> The Other Brian
> 
> 
> 
> -Original Message-
> From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge Knudsen
> Sent: Sunday, November 18, 2012 9:22 AM
> To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: RE: EU-DoC - list of applied standards with full title
> 
> Hello Kris,
> 
> About 10 years ago my company Niros Telecommunication was contacted by the 
> Belgium Authority whom told that the DoC should be written in Dutch as well 
> as in French and German.
> 
> At that time we had a DoC written in English, German, French and Italian.
> 
> We changed to a combination of a short form DoC and one complete DoC written 
> in English.
> 
> Short form in English:
> Hereby, [Name of manufacturer], declares that this [type of equipment] is in 
> compliance with the essential requirements and other relevant provisions of 
> Directive 1999/5/EC.
> 
> The short form DoC can be found at the link below:
> 
> http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
> n.htm
> See "23. Form of the manufacturers' declaration to be put into the user's 
> manual"
> 
> We used this form for DoC for the ATEX directive as well.
> 
> Best regards
> 
> Helge Knudsen
> 
> Former Test & Approval manager
> Niros Telecommunication
> Denmark
> 
> 
> -Original Message-
> From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier 
> Kristiaan
> Sent: 18. november 2012 14:13
> To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: RE: EU-DoC - list of applied standards with full title
> 
> Nick,
> 
> My country, Belgium, has 3 official national languages, Dutch, French and 
> German. The most recent draft of the Belgian transposition proposal of the 
> RoHS Directive states now that the EU DoC should be drawn up in a language 
> easily understandable by authorities. While the authorities have the right to 
> request a translation in one of the official languages, it allows the use of 
> English. Hopefull other countries follow that example as it worked well for > 
> 20 years.
> 
> Best regards,
> Kris Carpentier
> 
> -Original Message-
> From: emc-p...@ieee.org [mailto:emc-p...@ieee.

Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-19 Thread Steven Brody
In the realm of industrial use products on the DoC or Do we had the number
and name of the standard(s) that were used to confirm conformance to the
Directive.  While market surveillance was never a problem for us, and
customs in one EU Member State only questioned our product once, and that
due to their misinterpretation of the product type, we found that more often
it was the customer who asked what the standards were when we only used the
number.  The question usually came from someone in Purchasing or Quality
when they got their copy of the DoC or DoI when the product arrived on their
doorstep. 

>From then on it was decided to use name in conjunction with the number.  And
since we had templates for the DoC or DoI and only changed the variables
(serial number, date, DoC or DoI document number, etc.) it was not a
problem. 

Steve Brody
sgbr...@comcast.net
stev...@productehsconsultng.com
www.ProductEHSConsulting.com 


-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Monday, November 19, 2012 9:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU-DoC - list of applied standards with full title

I think this all begs the question, has anyone experienced any problems with
their EU DOC by not providing the Standard's Title? If so, what was the
objection and what was necessary to resolve it?

The official titles of directives and standards are often way too long and
often more confusing then descriptive.

We reference directives and standards on our EU DOC by their number and date
and follow it with a brief description and sometimes additional useful
information. Such as:

EN 61010-1:2010   Safety of Laboratory Equipment

Or

EN55011:2007+A2:2007RF EmissionsGroup 1, Class A


The directives requirements are, "a reference to the harmonized standards
used", so I would think as long as you provide enough information so it is
clear what the standards are you should be ok.

We think about what information our customers and others might want to see
in the DOC and include it if we can. The more descriptive we are the less
questions we get from the field, which saves us time and money.

We have used this approach for over 16 years and have not had any problems
or holdups, so far.

The Other Brian



-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge
Knudsen
Sent: Sunday, November 18, 2012 9:22 AM
To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EU-DoC - list of applied standards with full title

Hello Kris,

About 10 years ago my company Niros Telecommunication was contacted by the
Belgium Authority whom told that the DoC should be written in Dutch as well
as in French and German.

At that time we had a DoC written in English, German, French and Italian.

We changed to a combination of a short form DoC and one complete DoC written
in English.

Short form in English:
Hereby, [Name of manufacturer], declares that this [type of equipment] is in
compliance with the essential requirements and other relevant provisions of
Directive 1999/5/EC.

The short form DoC can be found at the link below:

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm
See "23. Form of the manufacturers' declaration to be put into the user's
manual"

We used this form for DoC for the ATEX directive as well.

Best regards

Helge Knudsen

Former Test & Approval manager
Niros Telecommunication
Denmark


-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier
Kristiaan
Sent: 18. november 2012 14:13
To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EU-DoC - list of applied standards with full title

Nick,

My country, Belgium, has 3 official national languages, Dutch, French and
German. The most recent draft of the Belgian transposition proposal of the
RoHS Directive states now that the EU DoC should be drawn up in a language
easily understandable by authorities. While the authorities have the right
to request a translation in one of the official languages, it allows the use
of English. Hopefull other countries follow that example as it worked well
for > 20 years.

Best regards,
Kris Carpentier

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick
Williams
Sent: zondag 18 november 2012 11:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: EU-DoC - list of applied standards with full title

It's actually a requirement of some of the directives, not just an addition
brought in by transposition in certain countries. Generally, where the
Directive requires the Declaration to accompany the product, it must be
translated in to the language of the country of the end user.

I guess the Commissiion's logic is that the instructions will need to be
translated into the same language(s) so it's not a significant add

Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-19 Thread McInturff, Gary
I'm also just curious what countries don't use Arabic numerals? I would have 
been able to understand what standard was in play from what you sent below if 
you had sent it in Dutch, or Spanish. Group and class
Groep 1, klasse A and Grupo 1, clase A, took about 30 seconds to actually 
translate and I suspect that I can remember them the next time I see them in 
this form. 
Requiring the name in the local language is killing a fly with a sledgehammer. 
Gary


-Original Message-
From: Kunde, Brian [mailto:brian_ku...@lecotc.com] 
Sent: Monday, November 19, 2012 6:10 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU-DoC - list of applied standards with full title

I think this all begs the question, has anyone experienced any problems with 
their EU DOC by not providing the Standard's Title? If so, what was the 
objection and what was necessary to resolve it?

The official titles of directives and standards are often way too long and 
often more confusing then descriptive.

We reference directives and standards on our EU DOC by their number and date 
and follow it with a brief description and sometimes additional useful 
information. Such as:

EN 61010-1:2010   Safety of Laboratory Equipment

Or

EN55011:2007+A2:2007RF EmissionsGroup 1, Class A


The directives requirements are, "a reference to the harmonized standards 
used", so I would think as long as you provide enough information so it is 
clear what the standards are you should be ok.

We think about what information our customers and others might want to see in 
the DOC and include it if we can. The more descriptive we are the less 
questions we get from the field, which saves us time and money.

We have used this approach for over 16 years and have not had any problems or 
holdups, so far.

The Other Brian



-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge Knudsen
Sent: Sunday, November 18, 2012 9:22 AM
To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EU-DoC - list of applied standards with full title

Hello Kris,

About 10 years ago my company Niros Telecommunication was contacted by the 
Belgium Authority whom told that the DoC should be written in Dutch as well as 
in French and German.

At that time we had a DoC written in English, German, French and Italian.

We changed to a combination of a short form DoC and one complete DoC written in 
English.

Short form in English:
Hereby, [Name of manufacturer], declares that this [type of equipment] is in 
compliance with the essential requirements and other relevant provisions of 
Directive 1999/5/EC.

The short form DoC can be found at the link below:

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm
See "23. Form of the manufacturers' declaration to be put into the user's 
manual"

We used this form for DoC for the ATEX directive as well.

Best regards

Helge Knudsen

Former Test & Approval manager
Niros Telecommunication
Denmark


-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier 
Kristiaan
Sent: 18. november 2012 14:13
To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EU-DoC - list of applied standards with full title

Nick,

My country, Belgium, has 3 official national languages, Dutch, French and 
German. The most recent draft of the Belgian transposition proposal of the RoHS 
Directive states now that the EU DoC should be drawn up in a language easily 
understandable by authorities. While the authorities have the right to request 
a translation in one of the official languages, it allows the use of English. 
Hopefull other countries follow that example as it worked well for > 20 years.

Best regards,
Kris Carpentier

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams
Sent: zondag 18 november 2012 11:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: EU-DoC - list of applied standards with full title

It's actually a requirement of some of the directives, not just an addition 
brought in by transposition in certain countries. Generally, where the 
Directive requires the Declaration to accompany the product, it must be 
translated in to the language of the country of the end user.

I guess the Commissiion's logic is that the instructions will need to be 
translated into the same language(s) so it's not a significant additional 
burden to require the DofC to be translated as well.

Nick.



On 18 Nov 2012, at 07:56, John Woodgate  wrote:

> In message
<867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com>,
dated Sat, 17 Nov 2012, Carpentier Kristiaan 
 writes:
>
>> Some countries require in their national transposition that the EU
>> DoC is
issued in the local language. Although most are still in draft: Franc

Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-19 Thread Kunde, Brian
I think this all begs the question, has anyone experienced any problems with 
their EU DOC by not providing the Standard's Title? If so, what was the 
objection and what was necessary to resolve it?

The official titles of directives and standards are often way too long and 
often more confusing then descriptive.

We reference directives and standards on our EU DOC by their number and date 
and follow it with a brief description and sometimes additional useful 
information. Such as:

EN 61010-1:2010   Safety of Laboratory Equipment

Or

EN55011:2007+A2:2007RF EmissionsGroup 1, Class A


The directives requirements are, "a reference to the harmonized standards 
used", so I would think as long as you provide enough information so it is 
clear what the standards are you should be ok.

We think about what information our customers and others might want to see in 
the DOC and include it if we can. The more descriptive we are the less 
questions we get from the field, which saves us time and money.

We have used this approach for over 16 years and have not had any problems or 
holdups, so far.

The Other Brian



-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Helge Knudsen
Sent: Sunday, November 18, 2012 9:22 AM
To: 'Carpentier Kristiaan'; 'Nick Williams'; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EU-DoC - list of applied standards with full title

Hello Kris,

About 10 years ago my company Niros Telecommunication was contacted by the 
Belgium Authority whom told that the DoC should be written in Dutch as well as 
in French and German.

At that time we had a DoC written in English, German, French and Italian.

We changed to a combination of a short form DoC and one complete DoC written in 
English.

Short form in English:
Hereby, [Name of manufacturer], declares that this [type of equipment] is in 
compliance with the essential requirements and other relevant provisions of 
Directive 1999/5/EC.

The short form DoC can be found at the link below:

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm
See "23. Form of the manufacturers' declaration to be put into the user's 
manual"

We used this form for DoC for the ATEX directive as well.

Best regards

Helge Knudsen

Former Test & Approval manager
Niros Telecommunication
Denmark


-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier 
Kristiaan
Sent: 18. november 2012 14:13
To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EU-DoC - list of applied standards with full title

Nick,

My country, Belgium, has 3 official national languages, Dutch, French and 
German. The most recent draft of the Belgian transposition proposal of the RoHS 
Directive states now that the EU DoC should be drawn up in a language easily 
understandable by authorities. While the authorities have the right to request 
a translation in one of the official languages, it allows the use of English. 
Hopefull other countries follow that example as it worked well for > 20 years.

Best regards,
Kris Carpentier

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams
Sent: zondag 18 november 2012 11:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: EU-DoC - list of applied standards with full title

It's actually a requirement of some of the directives, not just an addition 
brought in by transposition in certain countries. Generally, where the 
Directive requires the Declaration to accompany the product, it must be 
translated in to the language of the country of the end user.

I guess the Commissiion's logic is that the instructions will need to be 
translated into the same language(s) so it's not a significant additional 
burden to require the DofC to be translated as well.

Nick.



On 18 Nov 2012, at 07:56, John Woodgate  wrote:

> In message
<867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com>,
dated Sat, 17 Nov 2012, Carpentier Kristiaan 
 writes:
>
>> Some countries require in their national transposition that the EU
>> DoC is
issued in the local language. Although most are still in draft: France in 
French, Portugal in Portuguese, Germany in German,  etc&..
>>
>> In worst case, we have some 24 languages in EU, so lots of fun for
translation.
>
> Now that IS a hardship for manufacturers. The way to deal with it is
> for
manufacturers' associations to petition the Commission for a clarification of 
the 'reference' requirement to mean just EN X:

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
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All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-18 Thread Helge Knudsen
Hello Kris,

About 10 years ago my company Niros Telecommunication was contacted by the
Belgium Authority whom told that the DoC should be written in Dutch as well
as in French and German.

At that time we had a DoC written in English, German, French and Italian.

We changed to a combination of a short form DoC and one complete DoC written
in English.  

Short form in English:
Hereby, [Name of manufacturer], declares that this [type of equipment] is in
compliance with the essential requirements and other relevant provisions of
Directive 1999/5/EC.

The short form DoC can be found at the link below:

http://ec.europa.eu/enterprise/sectors/rtte/documents/interpretation/index_e
n.htm
See "23. Form of the manufacturers' declaration to be put into the user's
manual"

We used this form for DoC for the ATEX directive as well.

Best regards

Helge Knudsen

Former Test & Approval manager
Niros Telecommunication
Denmark


-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Carpentier
Kristiaan
Sent: 18. november 2012 14:13
To: Nick Williams; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: EU-DoC - list of applied standards with full title

Nick,

My country, Belgium, has 3 official national languages, Dutch, French and
German. The most recent draft of the Belgian transposition proposal of the
RoHS Directive states now that the EU DoC should be drawn up in a language
easily understandable by authorities. While the authorities have the right
to request a translation in one of the official languages, it allows the use
of English. Hopefull other countries follow that example as it worked well
for > 20 years.

Best regards, 
Kris Carpentier

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick
Williams
Sent: zondag 18 november 2012 11:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: EU-DoC - list of applied standards with full title

It's actually a requirement of some of the directives, not just an addition
brought in by transposition in certain countries. Generally, where the
Directive requires the Declaration to accompany the product, it must be
translated in to the language of the country of the end user. 

I guess the Commissiion's logic is that the instructions will need to be
translated into the same language(s) so it's not a significant additional
burden to require the DofC to be translated as well. 

Nick. 



On 18 Nov 2012, at 07:56, John Woodgate  wrote:

> In message
<867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com>,
dated Sat, 17 Nov 2012, Carpentier Kristiaan
 writes:
> 
>> Some countries require in their national transposition that the EU DoC is
issued in the local language. Although most are still in draft: France in
French, Portugal in Portuguese, Germany in German,  etc&..  
>> 
>> In worst case, we have some 24 languages in EU, so lots of fun for
translation.
> 
> Now that IS a hardship for manufacturers. The way to deal with it is for
manufacturers' associations to petition the Commission for a clarification
of the 'reference' requirement to mean just EN X:

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Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-18 Thread Carpentier Kristiaan
Nick,

My country, Belgium, has 3 official national languages, Dutch, French and 
German. The most recent draft of the Belgian transposition proposal of the RoHS 
Directive states now that the EU DoC should be drawn up in a language easily 
understandable by authorities. While the authorities have the right to request 
a translation in one of the official languages, it allows the use of English. 
Hopefull other countries follow that example as it worked well for > 20 years.

Best regards, 
Kris Carpentier

-Original Message-
From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams
Sent: zondag 18 november 2012 11:14
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: EU-DoC - list of applied standards with full title

It's actually a requirement of some of the directives, not just an addition 
brought in by transposition in certain countries. Generally, where the 
Directive requires the Declaration to accompany the product, it must be 
translated in to the language of the country of the end user. 

I guess the Commissiion's logic is that the instructions will need to be 
translated into the same language(s) so it's not a significant additional 
burden to require the DofC to be translated as well. 

Nick. 



On 18 Nov 2012, at 07:56, John Woodgate  wrote:

> In message 
> <867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com>, dated 
> Sat, 17 Nov 2012, Carpentier Kristiaan  
> writes:
> 
>> Some countries require in their national transposition that the EU DoC is 
>> issued in the local language. Although most are still in draft: France in 
>> French, Portugal in Portuguese, Germany in German,  etc&..  
>> 
>> In worst case, we have some 24 languages in EU, so lots of fun for 
>> translation.
> 
> Now that IS a hardship for manufacturers. The way to deal with it is for 
> manufacturers' associations to petition the Commission for a clarification of 
> the 'reference' requirement to mean just EN X:

-

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Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-18 Thread John Woodgate
In message , 
dated Sun, 18 Nov 2012, Nick Williams  
writes:


I guess the Commissiion's logic is that the instructions will need to 
be translated into the same language(s) so it's not a significant 
additional burden to require the DofC to be translated as well.


The titles of standards MUST NOT be translated, they must be the 
official titles in each language, and it may not be easy to find these.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-18 Thread Nick Williams
It's actually a requirement of some of the directives, not just an addition 
brought in by transposition in certain countries. Generally, where the 
Directive requires the Declaration to accompany the product, it must be 
translated in to the language of the country of the end user. 

I guess the Commissiion's logic is that the instructions will need to be 
translated into the same language(s) so it's not a significant additional 
burden to require the DofC to be translated as well. 

Nick. 



On 18 Nov 2012, at 07:56, John Woodgate  wrote:

> In message 
> <867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com>, dated 
> Sat, 17 Nov 2012, Carpentier Kristiaan  
> writes:
> 
>> Some countries require in their national transposition that the EU DoC is 
>> issued in the local language. Although most are still in draft: France in 
>> French, Portugal in Portuguese, Germany in German,  etc&..  
>> 
>> In worst case, we have some 24 languages in EU, so lots of fun for 
>> translation.
> 
> Now that IS a hardship for manufacturers. The way to deal with it is for 
> manufacturers' associations to petition the Commission for a clarification of 
> the 'reference' requirement to mean just EN X:

-

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Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-18 Thread John Woodgate
In message 
<867f4b6a1672e541a94676d556793acd1b66ce1...@mopesmbx01.eu.thmulti.com>, 
dated Sat, 17 Nov 2012, Carpentier Kristiaan 
 writes:


Some countries require in their national transposition that the EU DoC 
is issued in the local language. Although most are still in draft: 
France in French, Portugal in Portuguese, Germany in German,  etc&..  


In worst case, we have some 24 languages in EU, so lots of fun for 
translation.


Now that IS a hardship for manufacturers. The way to deal with it is for 
manufacturers' associations to petition the Commission for a 
clarification of the 'reference' requirement to mean just EN X:

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-17 Thread Carpentier Kristiaan
Michael,

You may also know that the RoHS Recast Directive 2011/65/EU is the first 
Directive using the NLF, coming into force in Jan. 2013.
Some countries require in their national transposition that the EU DoC is 
issued in the local language. Although most are still in draft: France in 
French, Portugal in Portuguese, Germany in German,  etc.
In worst case, we have some 24 languages in EU, so lots of fun for translation. 
One good point: ETSI has all titles of its standards translated online, see 
last pages of each standard.

Best regards,
Kris Carpentier

From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Michael Loerzer
Sent: zaterdag 17 november 2012 21:11
To: IEEE PSES
Subject: EU-DoC - list of applied standards with full title

Hello,

I have my personal opion but different experiences with market surveillance 
authorities with respect to the following question:

Decision 768/2008/EC (Annex III) or all existing new approach directives 
specifies the content of an EU-DoC as follows.

References to the relevant harmonised standards used or references to the 
specifications in relation to which conformity is declared

What does "references" mean?


· EN :year/month AND

· the title?

ISO/IEC 17050-1 requires the title but a standard is not a legal requirement.

Best regards

Dipl.-Ing. Michael Loerzer
Managing Director
Regulatory Affairs Specialist

Globalnorm GmbH
Kurfürstenstr. 112
10787 Berlin

Phone +49 30 3229027-51
Cell +49 170 3229027
Fax +49 30 3229027-59
Mailmichael.loer...@globalnorm.de

» globalnorm.de

Globalnorm GmbH, Sitz der Gesellschaft: Kurfürstenstr. 112, 10787 Berlin
Geschäftsführer: Dipl.-Ing. Michael Loerzer
Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448

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Re: [PSES] EU-DoC - list of applied standards with full title

2012-11-17 Thread John Woodgate
In message <001901cdc4ff$a4da0ab0$ee8e2010$@globalnorm.de>, dated Sat, 
17 Nov 2012, Michael Loerzer  writes:


I have my personal opion but different experiences with market 
surveillance authorities with respect to the following question:


Is there any difficulty in including the title? If not, it is better not 
to risk an objection by not including it.

--
OOO - Own Opinions Only. See www.jmwa.demon.co.uk
The longer it takes to make a point, the more obtuse it proves to be.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] EU-DoC - list of applied standards with full title

2012-11-17 Thread Michael Loerzer
Hello,

 

I have my personal opion but different experiences with market surveillance
authorities with respect to the following question:

 

Decision 768/2008/EC (Annex III) or all existing new approach directives
specifies the content of an EU-DoC as follows.

 

References to the relevant harmonised standards used or references to the
specifications in relation to which conformity is declared

 

What does “references” mean?

 

· EN :year/month AND

· the title?

 

ISO/IEC 17050-1 requires the title but a standard is not a legal
requirement.

 

Best regards

 

Dipl.-Ing. Michael Loerzer

Managing Director
Regulatory Affairs Specialist

 

Globalnorm GmbH

Kurfürstenstr. 112

10787 Berlin

 

Phone +49 30 3229027-51

Cell +49 170 3229027

Fax +49 30 3229027-59

Mail 
michael.loer...@globalnorm.de

 

  » globalnorm.de

 

Globalnorm GmbH, Sitz der Gesellschaft: Kurfürstenstr. 112, 10787 Berlin

Geschäftsführer: Dipl.-Ing. Michael Loerzer

Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448

 


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