[PSES] SV: [PSES] Declaration of Conformity
Guys IoT products, they seem to not be a included in this directive. And that’s because of its low power consumptions nature ? BR Amund Fra: Charlie Blackham Sendt: 1. juni 2024 21:11 Til: EMC-PSTC@LISTSERV.IEEE.ORG Emne: Re: [PSES] Declaration of Conformity Scott The Ecodesign Directive applies to products within scope of a Commission Regulation implementing Directive 2009/125/EC These products must then be labelled in accordance with the relevant Commission Delegated Regulation on how to energy label that product. You don’t declare compliance with a labelling method, you just label in accordance with it. Lists of relevant Regulations at https://energy.ec.europa.eu/topics/energy-efficiency/energy-label-and-ecodesign/list-energy-efficient-products-regulations-product-group_en Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Scott Xe mailto:scott...@gmail.com> > Sent: Saturday, June 1, 2024 2:33 AM To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] Declaration of Conformity Hello Experts, According to the Ecodesign Directive (EU) 2009/125, manufacturers must draw up a declaration of conformity for covered products. However, the Energy Labelling Regulation (EU) 2017/1369 does not explicitly mention this requirement. Is a declaration of conformity also mandatory for products covered under the Energy Labelling Regulation (EU) 2017/1369 as part of the compliance process? Cheers, Scott _ 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-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ <https://www.mail-archive.com/emc-pstc@listserv.ieee.org/%20> Website: https://ewh.ieee.org/soc/pses/ <https://ewh.ieee.org/soc/pses/> Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) <https://ewh.ieee.org/soc/pses/list.html> List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net <mailto:msherma...@comcast.net> Rick Linford at: linf...@ieee.org <mailto:linf...@ieee.org> For policy questions, send mail to: Jim Bacher at: j.bac...@ieee.org <mailto:j.bac...@ieee.org> _ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC <https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1> =1 _ 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-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ <https://www.mail-archive.com/emc-pstc@listserv.ieee.org/%20> Website: https://ewh.ieee.org/soc/pses/ <https://ewh.ieee.org/soc/pses/> Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) <https://ewh.ieee.org/soc/pses/list.html> List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net <mailto:msherma...@comcast.net> Rick Linford at: linf...@ieee.org <mailto:linf...@ieee.org> For policy questions, send mail to: Jim Bacher at: j.bac...@ieee.org <mailto:j.bac...@ieee.org> _ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC <https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1> =1 - 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-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher: _ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
Re: [PSES] Declaration of Conformity
Dear Charlie, Thanks for your reply. As some of ecodesign regulations do not require energy labelling, appreciate your useful link which gives clear indications which ecodesign regulations do not require energy labelling. Best regards, Scott On Sun, 2 Jun 2024 at 03:10, Charlie Blackham wrote: > Scott > > > > The Ecodesign Directive applies to products within scope of a Commission > Regulation implementing Directive 2009/125/EC > > > > These products must then be labelled in accordance with the relevant > Commission Delegated Regulation on how to energy label that product. > > > > You don’t declare compliance with a labelling method, you just label in > accordance with it. > > > > Lists of relevant Regulations at > > > https://energy.ec.europa.eu/topics/energy-efficiency/energy-label-and-ecodesign/list-energy-efficient-products-regulations-product-group_en > > > > Best regards > > Charlie > > > > *Charlie Blackham* > > *Sulis Consultants Ltd* > > *Tel: +44 (0)7946 624317* > > *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> * > > Registered in England and Wales, number 05466247 > > > > *From:* Scott Xe > *Sent:* Saturday, June 1, 2024 2:33 AM > *To:* EMC-PSTC@LISTSERV.IEEE.ORG > *Subject:* [PSES] Declaration of Conformity > > > > Hello Experts, > > > > According to the Ecodesign Directive (EU) 2009/125, manufacturers must > draw up a declaration of conformity for covered products. However, the > Energy Labelling Regulation (EU) 2017/1369 does not explicitly mention this > requirement. > > > > Is a declaration of conformity also mandatory for products covered under > the Energy Labelling Regulation (EU) 2017/1369 as part of the compliance > process? > > > > Cheers, > > > > Scott > -- > > 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-PSTC@LISTSERV.IEEE.ORG > > All emc-pstc postings are archived and searchable on the web at: > https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ > <https://www.mail-archive.com/emc-pstc@listserv.ieee.org/%20> > > Website: https://ewh.ieee.org/soc/pses/ > Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to > unsubscribe) <https://ewh.ieee.org/soc/pses/list.html> > List rules: https://ewh.ieee.org/soc/pses/listrules.html > > For help, send mail to the list administrators: > Mike Sherman at: msherma...@comcast.net > Rick Linford at: linf...@ieee.org > > For policy questions, send mail to: > Jim Bacher at: j.bac...@ieee.org > -- > > To unsubscribe from the EMC-PSTC list, click the following link: > https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1 > - 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-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher: _ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
Re: [PSES] Declaration of Conformity
Scott The Ecodesign Directive applies to products within scope of a Commission Regulation implementing Directive 2009/125/EC These products must then be labelled in accordance with the relevant Commission Delegated Regulation on how to energy label that product. You don’t declare compliance with a labelling method, you just label in accordance with it. Lists of relevant Regulations at https://energy.ec.europa.eu/topics/energy-efficiency/energy-label-and-ecodesign/list-energy-efficient-products-regulations-product-group_en Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Scott Xe Sent: Saturday, June 1, 2024 2:33 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Declaration of Conformity Hello Experts, According to the Ecodesign Directive (EU) 2009/125, manufacturers must draw up a declaration of conformity for covered products. However, the Energy Labelling Regulation (EU) 2017/1369 does not explicitly mention this requirement. Is a declaration of conformity also mandatory for products covered under the Energy Labelling Regulation (EU) 2017/1369 as part of the compliance process? Cheers, Scott 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-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/<https://www.mail-archive.com/emc-pstc@listserv.ieee.org/%20> Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe)<https://ewh.ieee.org/soc/pses/list.html> List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net<mailto:msherma...@comcast.net> Rick Linford at: linf...@ieee.org<mailto:linf...@ieee.org> For policy questions, send mail to: Jim Bacher at: j.bac...@ieee.org<mailto:j.bac...@ieee.org> To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1 - 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-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher: _ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
[PSES] Declaration of Conformity
Hello Experts, According to the Ecodesign Directive (EU) 2009/125, manufacturers must draw up a declaration of conformity for covered products. However, the Energy Labelling Regulation (EU) 2017/1369 does not explicitly mention this requirement. Is a declaration of conformity also mandatory for products covered under the Energy Labelling Regulation (EU) 2017/1369 as part of the compliance process? Cheers, Scott - 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-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher: _ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
[PSES] Fw: Re: [PSES] ISED Requirements for Self-Declaration of Conformity
Doug, applicable CSA reg is RSS-247. We put "ICES-003" on our label. Brian -- Forwarded Message -- From: Douglas Nix Subject: Re: [PSES] ISED Requirements for Self-Declaration of Conformity Date: Thu, 22 Feb 2024 15:55:30 -0500 Hi Brian, Do you know which ICES standard applies to your product? You can start here if you dont know quite where to start. If you know what ICES standard applies, youll find the requirements for labelling and declaration in the relevant document. Heres the link to that part of the ISED website in case you dont have it yet. A good place to start is with the documents RSS-Gen, General Requirements for Compliance of Radio Apparatus, and ICES-Gen, General Requirements for Compliance of Interference-Causing Equipment. Doug NixKitchener, Ontario, canadad...@mac.com+1 (519) 729-5704 On Feb 22, 2024, at 13:54, Brian Gregory wrote: Hello fellow EMC Nerds, I had posted a time or two on our EMC issues with a unit that has a class B certified WiFi/BT module. With improved results compared to the originally approved unit, we've been able to attest to compliance via the SELF DECLARATION of CONFORMITY (SDoC) process as defined in the FCC guidance documents for our unit under the Class 1 Permissive Change (C1PC) rules, re: Part 47 / § 15.101. Does ISED have a similar SDoC process for Canadian compliance for devices qualifying under FCC C1PC rules? thanks, Colorado Brian 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-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher at: j.bac...@ieee.org To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1 - 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-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher: _ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
Re: [PSES] ISED Requirements for Self-Declaration of Conformity
Hi Brian, You will find similar procedures for Permissive Changes in ISED RSP-100 https://ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/radio-standards-procedures-rsp/rsp-100-certification-radio-apparatus-and-broadcasting-equipment Larry K. Stillings Compliance Worldwide, Inc. Test Locally, Sell Globally and Launch Your Products Around the World! FCC - Wireless - Telecom - CE Marking - International Approvals - Product Safety 357 Main Street Sandown, NH 03873 (603) 887 3903 Fax 887-6445 complianceworldwide.com<https://complianceworldwide.com> <https://complianceworldwide.com> Privileged/Confidential Information may be contained in this message. If you are not the addressee indicated in this message (or responsible for delivery of the message to such person), you may not copy or deliver this message to anyone. In such case, you should destroy this message and kindly notify the sender by reply email. Please advise immediately if you or your employer do not consent to Internet email for messages of this kind. Opinions, conclusions and other information in this message that do not relate to the official business of my firm shall be understood as neither given nor endorsed by it. From: Brian Gregory Sent: Thursday, February 22, 2024 1:55 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] ISED Requirements for Self-Declaration of Conformity Hello fellow EMC Nerds, I had posted a time or two on our EMC issues with a unit that has a class B certified WiFi/BT module. With improved results compared to the originally approved unit, we've been able to attest to compliance via the SELF DECLARATION of CONFORMITY (SDoC) process as defined in the FCC guidance documents for our unit under the Class 1 Permissive Change (C1PC) rules, re: Part 47 / § 15.101. Does ISED have a similar SDoC process for Canadian compliance for devices qualifying under FCC C1PC rules? thanks, Colorado Brian 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-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/<https://www.mail-archive.com/emc-pstc@listserv.ieee.org/%20> Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe)<https://ewh.ieee.org/soc/pses/list.html> List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net<mailto:msherma...@comcast.net> Rick Linford at: linf...@ieee.org<mailto:linf...@ieee.org> For policy questions, send mail to: Jim Bacher at: j.bac...@ieee.org<mailto:j.bac...@ieee.org> To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1 - 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-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher: _ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
Re: [PSES] ISED Requirements for Self-Declaration of Conformity
Hi Brian, Do you know which ICES standard applies to your product? You can start here <https://ised-isde.canada.ca/site/certification-engineering-bureau/en/wireless-equipment-standards-knowledge-center/equipment-standards-and-certification-overview> if you don’t know quite where to start. If you know what ICES standard applies, you’ll find the requirements for labelling and declaration in the relevant document. Here’s the link to that part of the ISED website <https://ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/interference-causing-equipment-standards-ices> in case you don’t have it yet. A good place to start is with the documents RSS-Gen, General Requirements for Compliance of Radio Apparatus <https://www.ic.gc.ca/eic/site/smt-gst.nsf/vwapj/RSS-Gen-i5-A2-2021-02EN.pdf/$FILE/RSS-Gen-i5-A2-2021-02EN.pdf>, and ICES-Gen, General Requirements for Compliance of Interference-Causing Equipment <https://ised-isde.canada.ca/site/spectrum-management-telecommunications/en/devices-and-equipment/interference-causing-equipment-standards-ices/ices-gen-general-requirements-compliance-interference-causing-equipment>. Doug Nix Kitchener, Ontario, Canada d...@mac.com +1 (519) 729-5704 > On Feb 22, 2024, at 13:54, Brian Gregory wrote: > > > Hello fellow EMC Nerds, > > I had posted a time or two on our EMC issues with a unit that has a class B > certified WiFi/BT module. With improved results compared to the originally > approved unit, we've been able to attest to compliance via the SELF > DECLARATION of CONFORMITY (SDoC) process as defined in the FCC guidance > documents for our unit under the Class 1 Permissive Change (C1PC) rules, re: > Part 47 / § 15.101. > > Does ISED have a similar SDoC process for Canadian compliance for devices > qualifying under FCC C1PC rules? > > thanks, > > Colorado Brian > > 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-PSTC@LISTSERV.IEEE.ORG > > All emc-pstc postings are archived and searchable on the web at: > https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ > > Website: https://ewh.ieee.org/soc/pses/ <https://ewh.ieee.org/soc/pses/> > Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to > unsubscribe) <https://ewh.ieee.org/soc/pses/list.html> > List rules: https://ewh.ieee.org/soc/pses/listrules.html > > For help, send mail to the list administrators: > Mike Sherman at: msherma...@comcast.net <mailto:msherma...@comcast.net> > Rick Linford at: linf...@ieee.org <mailto:linf...@ieee.org> > For policy questions, send mail to: > Jim Bacher at: j.bac...@ieee.org <mailto:j.bac...@ieee.org> > To unsubscribe from the EMC-PSTC list, click the following link: > https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1 > - 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-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher: _ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
[PSES] ISED Requirements for Self-Declaration of Conformity
Hello fellow EMC Nerds, I had posted a time or two on our EMC issues with a unit that has a class B certified WiFi/BT module. With improved results compared to the originally approved unit, we've been able to attest to compliance via the SELF DECLARATION of CONFORMITY (SDoC) process as defined in the FCC guidance documents for our unit under the Class 1 Permissive Change (C1PC) rules, re: Part 47 / § 15.101. Does ISED have a similar SDoC process for Canadian compliance for devices qualifying under FCC C1PC rules? thanks, Colorado Brian - 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-PSTC@LISTSERV.IEEE.ORG All emc-pstc postings are archived and searchable on the web at: https://www.mail-archive.com/emc-pstc@listserv.ieee.org/ Website: https://ewh.ieee.org/soc/pses/ Instructions: https://ewh.ieee.org/soc/pses/list.html (including how to unsubscribe) List rules: https://ewh.ieee.org/soc/pses/listrules.html For help, send mail to the list administrators: Mike Sherman at: msherma...@comcast.net Rick Linford at: linf...@ieee.org For policy questions, send mail to: Jim Bacher: _ To unsubscribe from the EMC-PSTC list, click the following link: https://listserv.ieee.org/cgi-bin/wa?SUBED1=EMC-PSTC=1
Re: [PSES] EU Declaration of Conformity (DoC)
Scott CE marking requires a DoC For example – Article 10 of the RED: Obligations of manufacturers 3.Manufacturers shall draw up the technical documentation referred to in Article 21 and carry out the relevant conformity assessment procedure referred to in Article 17 or have it carried out. Where compliance of radio equipment with the applicable requirements has been demonstrated by that conformity assessment procedure, manufacturers shall draw up an EU declaration of conformity and affix the CE marking Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Scott Xe Sent: 25 February 2021 10:33 To: Charlie Blackham Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU Declaration of Conformity (DoC) Dear Charlie, Thanks for your advice! Does CE Mark link with DoC? For example, REACH regulation does not require CE Mark whereas it requires DoS. For CE Marking, does it require DoC? On Thu, 25 Feb 2021 at 00:10, Charlie Blackham mailto:char...@sulisconsultants.com>> wrote: Scott The list of applicable Directives that are covered by CE marking can be found at https://ec.europa.eu/growth/single-market/ce-marking/manufacturers_en There are a number of other Directives and Regulations that may be mandatory for your product, but they are not covered by CE marking Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Scott Xe mailto:scott...@gmail.com>> Sent: 24 February 2021 13:46 To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] EU Declaration of Conformity (DoC) Does the DoC only provide references to the directives or regulations that require DoC? Other non-required directives or regulations should not be included in the DoC. For examples, GPSD, packaging waste, battery, energy label, etc. Thanks and regards, Scott - 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)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 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:
Re: [PSES] EU Declaration of Conformity (DoC)
Dear Charlie, Thanks for your advice! Does CE Mark link with DoC? For example, REACH regulation does not require CE Mark whereas it requires DoS. For CE Marking, does it require DoC? On Thu, 25 Feb 2021 at 00:10, Charlie Blackham wrote: > Scott > > > > The list of applicable Directives that are covered by CE marking can be > found at > https://ec.europa.eu/growth/single-market/ce-marking/manufacturers_en > > > > There are a number of other Directives and Regulations that may be > mandatory for your product, but they are not covered by CE marking > > > > Best regards > > Charlie > > > > *Charlie Blackham* > > *Sulis Consultants Ltd* > > *Tel: +44 (0)7946 624317* > > *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> * > > Registered in England and Wales, number 05466247 > > > > *From:* Scott Xe > *Sent:* 24 February 2021 13:46 > *To:* EMC-PSTC@LISTSERV.IEEE.ORG > *Subject:* [PSES] EU Declaration of Conformity (DoC) > > > > Does the DoC only provide references to the directives or regulations that > require DoC? Other non-required directives or regulations should not be > included in the DoC. For examples, GPSD, packaging waste, battery, energy > label, etc. > > > > Thanks and regards, > > > > Scott > > - > > > 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) <http://www.ieee-pses.org/list.html> > 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 > - 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:
Re: [PSES] EU Declaration of Conformity (DoC)
Hi Dan, We put almost all applicable directives or regulations in one DoC for a long period of time without any questions from MSAs. It is a common practice in the industry. Recently we got an inquiry about inadequacy of putting energy label regulation in the DoC and expect us to remove it. They are right that the energy label regulation does not require DoC whereas the eco-design does. Thus bring it up for comments from the group. On Wed, 24 Feb 2021 at 23:43, Dan Roman wrote: > Hi Scott, > > > > I think what you are really asking is what is the legally required > minimum? If yes, then Directives like the GPSD, which does not in its text > require a DoC (or CE Marking), would not require a DoC and would not need > to be listed on a DoC that may be issued to cover other Directives or > Regulations. I do not think though that there are restrictions that would > prevent you from putting more than what is the minimum legal requirement > should you desire to do so. So I do not think that listing the GPSC on a > DoC is illegal. Would be interested in hearing from others on the topic > though. > > > > Stay safe, stay well. > > > > Dan > > > > *From:* Scott Xe [mailto:scott...@gmail.com] > *Sent:* Wednesday, February 24, 2021 8:46 AM > *To:* EMC-PSTC@LISTSERV.IEEE.ORG > *Subject:* [PSES] EU Declaration of Conformity (DoC) > > > > Does the DoC only provide references to the directives or regulations that > require DoC? Other non-required directives or regulations should not be > included in the DoC. For examples, GPSD, packaging waste, battery, energy > label, etc. > > > > Thanks and regards, > > > > Scott > > - > > > 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) <http://www.ieee-pses.org/list.html> > 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 > - 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:
Re: [PSES] EU Declaration of Conformity (DoC)
Scott The list of applicable Directives that are covered by CE marking can be found at https://ec.europa.eu/growth/single-market/ce-marking/manufacturers_en There are a number of other Directives and Regulations that may be mandatory for your product, but they are not covered by CE marking Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Scott Xe Sent: 24 February 2021 13:46 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] EU Declaration of Conformity (DoC) Does the DoC only provide references to the directives or regulations that require DoC? Other non-required directives or regulations should not be included in the DoC. For examples, GPSD, packaging waste, battery, energy label, etc. Thanks and regards, Scott - 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)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 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:
Re: [PSES] EU Declaration of Conformity (DoC)
Hi Scott, I think what you are really asking is what is the legally required minimum? If yes, then Directives like the GPSD, which does not in its text require a DoC (or CE Marking), would not require a DoC and would not need to be listed on a DoC that may be issued to cover other Directives or Regulations. I do not think though that there are restrictions that would prevent you from putting more than what is the minimum legal requirement should you desire to do so. So I do not think that listing the GPSC on a DoC is illegal. Would be interested in hearing from others on the topic though. Stay safe, stay well. Dan From: Scott Xe [mailto:scott...@gmail.com] Sent: Wednesday, February 24, 2021 8:46 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] EU Declaration of Conformity (DoC) Does the DoC only provide references to the directives or regulations that require DoC? Other non-required directives or regulations should not be included in the DoC. For examples, GPSD, packaging waste, battery, energy label, etc. Thanks and regards, Scott - 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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org> > Mike Cantwell mailto:mcantw...@ieee.org> > For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org> > David Heald mailto: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 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] EU Declaration of Conformity (DoC)
Does the DoC only provide references to the directives or regulations that require DoC? Other non-required directives or regulations should not be included in the DoC. For examples, GPSD, packaging waste, battery, energy label, etc. Thanks and regards, Scott - 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:
Re: [PSES] EN 62311:2008 : proper statement in European Declaration of Conformity
On Sun, 31 Jan 2021 11:41:10 -0700, Richard Georgerian wrote: > The European Journal has listed only the EN 62311:2008, whereas at the > Cenelec webpage it has EN IEC 62311:2020. The "EN" in, EN IEC 62311:2020, > implies that it is a harmonized standard and should be in the European > Journal. Not all "EN" will be harmonized under European Directives/Regulations. > But I am not sure why the "IEC" is in the name or what it implies > or its significance. As described in clause 4.1 of CENELEC Guide 13 dated 2016-10, https://ftp.cencenelec.eu/CENELEC/Guides/CLC/13_CENELECGuide13.pdf, "EN IEC" now means the EN standard is identical with the corresponding IEC standard. > As for the EU Declaration of Conformity, are we only to > state that a product meets, EN 62311:2008, when in fact, the product was > tested to the 2020 version, or the latest version, even though the latest > version is not in the European Journal? I believe manufactures can choose to apply harmonized standards or non-harmonized standards, although only the harmonized standards will give presumption of conformity. Although compliance with the newer non-harmonized standard necessary means compliance with the older harmonized standard, if you can demonstrate compliance with both editions of the standard, maybe you can references older edition, newer edition or both editions in your DoC. Regards, Tom - 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] EN 62311:2008 : proper statement in European Declaration of Conformity
Greetings all, The European Journal has listed only the EN 62311:2008, whereas at the Cenelec webpage it has EN IEC 62311:2020. The "EN" in, EN IEC 62311:2020, implies that it is a harmonized standard and should be in the European Journal. But I am not sure why the "IEC" is in the name or what it implies or its significance. As for the EU Declaration of Conformity, are we only to state that a product meets, EN 62311:2008, when in fact, the product was tested to the 2020 version, or the latest version, even though the latest version is not in the European Journal? For reference: European Journal, EN 62311:2008 (https://ec.europa.eu/growth/single-market/european-standards/harmonised-sta ndards/low-voltage_en) Cenelec webpage (https://www.cenelec.eu/dyn/www/f?p=104:110:2318015863696101FSP_ORG_ID,F SP_PROJECT,FSP_LANG_ID:1258483,64203,25), I did search on past PSES emailing postings on the topic of EN 62311 and did not find anything on this specific inquiry. Any assistance and guidance would be most appreciated. Thank-you, .Richard Georgerian Compliance Engineer HID Global - 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:
Re: [PSES] Product Declaration of Conformity with external PSU...
Hi Matthew, See below inline comments. From: Matthew Wilson | GBE Sent: Wednesday, 10 April 2019 11:51 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Product Declaration of Conformity with external PSU... A consumer product is powered by AA cells but also can derive its power from a 'wall wart' mains-DC PSU via a DC jack input on the product. The client who is the manufacturer of the product (as per the EU directive) has decided to supply a third-party wall-wart PSU in the box with the product. The PSU does not carry the product manufacturer's logo but that of the PSU manufacturer (or possibly its importer/distributor assuming the responsibility of manufacturer because it will inevitably be made in Far East). Scott: If the EPS is supplied together with the main unit, LVD is applicable. On main unit, add a marking “ Use only power supply x” as a best practice. Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case. Scott: As power supply is part of unit, one DoC is sufficient to cover and you are the manufacturer/importer in the EU. If outside EU, AR is required to include. Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures? Scott: Yes, EPS falls into the product group of Eco-design regulation but no energy label required. It is a common practice to use one DoC for all applicable harmonised directives/regulations. You are accountable for the EPS so you have to ensure it is safe unless the EPS is sold separately. Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC? Any thoughts welcome thanks. Regards all. Disclaimer: This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please delete it from your system, do not use or disclose the information in any way and notify the sender immediately. The contents of this message may contain personal views which are not the views of the company, unless specifically stated. GB Electronics (UK) Ltd is a company registered in England and Wales under number 06210991. Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West Sussex, BN12 4QY. - 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) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org> > Mike Cantwell mailto:mcantw...@ieee.org> > For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org> > David Heald mailto: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 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:
Re: [PSES] Product Declaration of Conformity with external PSU...
Irrespective of the voltage the product needs to be safe. So the LVD may not apply but you still need to meet GPSD. Best Regards Matthew Sent from Knox Portal Mobile - Original Message - Sender : John Woodgate Date : 2019-04-10 20:54 (GMT+1) Title : Re: [PSES] Product Declaration of Conformity with external PSU... I still don't see why having a power supply in the same box causes a battery-operated product to be subject to the LVD. It just doesn't seem sufficient reason to justify the cost of producing a test report form that has about 1000 'not applicable' entries. I agree with you about having lower voltage limits in the LVD being inappropriate, but I think there is a case for retaining the limits that justify 'Low Voltage' being in the title. It was probably OK to have lower voltage limits when the first edition was being drafted but even at the time of first publication we had products with lead-acid batteries on board that could readily burn under fault conditions. Now we have Li-ion, and maybe even more energetic batteries soon. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2019-04-10 20:15, Gert Gremmen wrote: The message was also for the group, my mistake... It depends, If the product is sold with a manufacturer provided adapter, then the product has a mains connection. -> LVD (it is not because there is a connector between power supply and equipment that it becomes safe) If the product is sold without, it has only the ELV DC connection. -> No LVD LVD is about more than just insulation from the mains. The whole concept of voltage limits in the LVD is wrong, the idea that a device is inherently safe if supplied by 24 volts (for example) is evidently wrong; this is also why those limits has been removed in the RED. Gert On 10-4-2019 19:32, John Woodgate wrote: Hello, Gert. Did you mean to reply only to me or to the mailing list? I don't understand your reasoning. The product itself runs from ELV DC, so, even though there is a power supply next to it in the box, surely the LVD doesn't apply? It does, of course, apply to the power supply that is supplied with it. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2019-04-10 17:51, Gert Gremmen / Ce-test wrote: It depends.. If the power supply is an inherent part of the product as “put on the market” then the lvd should apply. If not, so the customer is supposed to buy an adapter himself , then the product is supposed to be a dc supplied product and if this supply voltage is outside the limits for the lvd, such as 5 or 12 voltDC , then the lvd does not apply Gert Verstuurd vanaf mijn iPhone Op 10 apr. 2019 om 18:03 heeft John Woodgate <j...@woodjohn.uk> het volgende geschreven: I think: Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case. The product is outside the LVD. Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures? The ECO Directive applies to the power supply, not the product. Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC? It seems a logical solution, and I doubt that it is explicitly prohibited. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate an
Re: [PSES] Product Declaration of Conformity with external PSU...
I still don't see why having a power supply in the same box causes a battery-operated product to be subject to the LVD. It just doesn't seem sufficient reason to justify the cost of producing a test report form that has about 1000 'not applicable' entries. I agree with you about having lower voltage limits in the LVD being inappropriate, but I think there is a case for retaining the limits that justify 'Low Voltage' being in the title. It was probably OK to have lower voltage limits when the first edition was being drafted but even at the time of first publication we had products with lead-acid batteries on board that could readily burn under fault conditions. Now we have Li-ion, and maybe even more energetic batteries soon. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2019-04-10 20:15, Gert Gremmen wrote: The message was also for the group, my mistake... It depends, If the product is sold with a manufacturer provided adapter, then the product has a mains connection. -> LVD (it is not because there is a connector between power supply and equipment that it becomes safe) If the product is sold without, it has only the ELV DC connection. -> No LVD LVD is about more than just insulation from the mains. The whole concept of voltage limits in the LVD is wrong, the idea that a device is inherently safe if supplied by 24 volts (for example) is evidently wrong; this is also why those limits has been removed in the RED. Gert On 10-4-2019 19:32, John Woodgate wrote: Hello, Gert. Did you mean to reply only to me or to the mailing list? I don't understand your reasoning. The product itself runs from ELV DC, so, even though there is a power supply next to it in the box, surely the LVD doesn't apply? It does, of course, apply to the power supply that is supplied with it. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associateswww.woodjohn.uk Rayleigh, Essex UK On 2019-04-10 17:51, Gert Gremmen / Ce-test wrote: It depends.. If the power supply is an inherent part of the product as “put on the market” then the lvd should apply. If not, so the customer is supposed to buy an adapter himself , then the product is supposed to be a dc supplied product and if this supply voltage is outside the limits for the lvd, such as 5 or 12 voltDC , then the lvd does not apply Gert Verstuurd vanaf mijn iPhone Op 10 apr. 2019 om 18:03 heeft John Woodgate <mailto:j...@woodjohn.uk>> het volgende geschreven: I think: /Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case./ The product is outside the LVD/.// / /Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures?/ The ECO Directive applies to the power supply, not the product. /Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC?/ It seems a logical solution, and I doubt that it is explicitly prohibited. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associateswww.woodjohn.uk Rayleigh, Essex UK On 2019-04-10 16:51, Matthew Wilson | GBE wrote: A consumer product is powered by AA cells but also can derive its power from a 'wall wart' mains-DC PSU via a DC jack input on the product. The client who is the manufacturer of the product (as per the EU directive) has decided to supply a third-party wall-wart PSU in the box with the product. The PSU does not carry the product manufacturer's logo but that of the PSU manufacturer (or possibly its importer/distributor assuming the responsibility of manufacturer because it will inevitably be made in Far East). Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case. Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures? Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC? Any thoughts welcome thanks. Regards all. Disclaimer:This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please delete it from your system, do not use or disclose the information in any way and notify the sender immediately. The contents
Re: [PSES] Product Declaration of Conformity with external PSU...
The message was also for the group, my mistake... It depends, If the product is sold with a manufacturer provided adapter, then the product has a mains connection. -> LVD (it is not because there is a connector between power supply and equipment that it becomes safe) If the product is sold without, it has only the ELV DC connection. -> No LVD LVD is about more than just insulation from the mains. The whole concept of voltage limits in the LVD is wrong, the idea that a device is inherently safe if supplied by 24 volts (for example) is evidently wrong; this is also why those limits has been removed in the RED. Gert On 10-4-2019 19:32, John Woodgate wrote: Hello, Gert. Did you mean to reply only to me or to the mailing list? I don't understand your reasoning. The product itself runs from ELV DC, so, even though there is a power supply next to it in the box, surely the LVD doesn't apply? It does, of course, apply to the power supply that is supplied with it. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associateswww.woodjohn.uk Rayleigh, Essex UK On 2019-04-10 17:51, Gert Gremmen / Ce-test wrote: It depends.. If the power supply is an inherent part of the product as “put on the market” then the lvd should apply. If not, so the customer is supposed to buy an adapter himself , then the product is supposed to be a dc supplied product and if this supply voltage is outside the limits for the lvd, such as 5 or 12 voltDC , then the lvd does not apply Gert Verstuurd vanaf mijn iPhone Op 10 apr. 2019 om 18:03 heeft John Woodgate <mailto:j...@woodjohn.uk>> het volgende geschreven: I think: /Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case./ The product is outside the LVD/.// / /Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures?/ The ECO Directive applies to the power supply, not the product. /Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC?/ It seems a logical solution, and I doubt that it is explicitly prohibited. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associateswww.woodjohn.uk Rayleigh, Essex UK On 2019-04-10 16:51, Matthew Wilson | GBE wrote: A consumer product is powered by AA cells but also can derive its power from a 'wall wart' mains-DC PSU via a DC jack input on the product. The client who is the manufacturer of the product (as per the EU directive) has decided to supply a third-party wall-wart PSU in the box with the product. The PSU does not carry the product manufacturer's logo but that of the PSU manufacturer (or possibly its importer/distributor assuming the responsibility of manufacturer because it will inevitably be made in Far East). Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case. Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures? Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC? Any thoughts welcome thanks. Regards all. Disclaimer:This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please delete it from your system, do not use or disclose the information in any way and notify the sender immediately. The contents of this message may contain personal views which are not the views of the company, unless specifically stated. GB Electronics (UK) Ltd is a company registered in England and Wales under number 06210991. Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West Sussex, BN12 4QY. - 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: htt
Re: [PSES] Product Declaration of Conformity with external PSU...
I think: /Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case./ The product is outside the LVD/.// / /Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures?/ The ECO Directive applies to the power supply, not the product. /Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC?/ It seems a logical solution, and I doubt that it is explicitly prohibited. // Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2019-04-10 16:51, Matthew Wilson | GBE wrote: A consumer product is powered by AA cells but also can derive its power from a 'wall wart' mains-DC PSU via a DC jack input on the product. The client who is the manufacturer of the product (as per the EU directive) has decided to supply a third-party wall-wart PSU in the box with the product. The PSU does not carry the product manufacturer's logo but that of the PSU manufacturer (or possibly its importer/distributor assuming the responsibility of manufacturer because it will inevitably be made in Far East). Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case. Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures? Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC? Any thoughts welcome thanks. Regards all. Disclaimer:This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please delete it from your system, do not use or disclose the information in any way and notify the sender immediately. The contents of this message may contain personal views which are not the views of the company, unless specifically stated. GB Electronics (UK) Ltd is a company registered in England and Wales under number 06210991. Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West Sussex, BN12 4QY. - 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) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 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] Product Declaration of Conformity with external PSU...
A consumer product is powered by AA cells but also can derive its power from a 'wall wart' mains-DC PSU via a DC jack input on the product. The client who is the manufacturer of the product (as per the EU directive) has decided to supply a third-party wall-wart PSU in the box with the product. The PSU does not carry the product manufacturer's logo but that of the PSU manufacturer (or possibly its importer/distributor assuming the responsibility of manufacturer because it will inevitably be made in Far East). Should the product's EU Declaration of Conformity list the LVD directive? If so is it acceptable to list 'LVD only with specific 'manufacturer ABC' 'model XYZ' PSU as a clause in the DoC? I've not ever seen that done but don't see why that couldn't be the case. Should the product's EU Declaration of Conformity also list the 2009/125/EC Ecodesign directive in respect of the PSU implementing measures? Maybe there should be two Declarations of Conformity in the box? One for the product and one for the PSU, where the latter is a copy of the PSU manufacturer's DoC? Any thoughts welcome thanks. Regards all. Matthew Wilson Technical Director GB Electronics (UK) Ltd matthew.wil...@gbelectronics.com https://gbelectronics.uk +44 (0)1903 244 500 Ascot House//Mulberry Close//Woods Way Goring-by-Sea//West Sussex//BN12 4QY//UK Disclaimer: This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If you have received this email in error please delete it from your system, do not use or disclose the information in any way and notify the sender immediately. The contents of this message may contain personal views which are not the views of the company, unless specifically stated. GB Electronics (UK) Ltd is a company registered in England and Wales under number 06210991. Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West Sussex, BN12 4QY. - 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:
Re: [PSES] Spare parts requiring an EU declaration of Conformity.
Hello John. The problem is we have over 7000 different spare assemblies and I don't really want to issue a DoC for each one. Previous product DoCs have had to list each model in the range rather than just specifying the product range series. Regards; Ian McBurney Lead Compliance Engineer Allen & Heath Ltd. Kernick Industrial estate, Penryn, Cornwall. TR10 9LU. UK. Tel: 01326 372070 Email: ian.mcbur...@allen-heath.com From: John Woodgate Sent: 18 January 2019 15:39 To: McBurney, Ian ; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Spare parts requiring an EU declaration of Conformity. Your simplest course is not to argue but give them the DoC they want. As you say, Turkey is not in the EU, so it could, if it wanted, require a DoC written on parchment, with gold lettering. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk> Rayleigh, Essex UK On 2019-01-18 09:50, McBurney, Ian wrote: Dear Colleagues. Can anyone point me to the relevant section in the EU directives regarding the shipping of spares into the EU? We are shipping a spare PSU PCB assembly into Turkey and the Turkish customs want a Declaration of Conformity document. I know Turkey is not in the EU but they are demanding this documentation. I thought that spare parts/assemblies did not require a Declaration of Conformity document if the part was an identical replacement and is being fitted into an already CE marked product. Many thanks in advance. Ian McBurney Lead Compliance Engineer Allen & Heath Ltd. Kernick Industrial estate, Penryn, Cornwall. TR10 9LU. UK. Tel: 01326 372070 Email: ian.mcbur...@allen-heath.com<mailto:ian.mcbur...@allen-heath.com> Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. Any views expressed in this email are those of the individual and not necessarily those of the company. - 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)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto:dhe...@gmail.com>> Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. Any views expressed in this email are those of the individual and not necessarily those of the company. - 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:
Re: [PSES] Spare parts requiring an EU declaration of Conformity.
For what it's worth, the Blue Guide says: Products which have been repaired or exchanged (for example following a defect), without changing the original performance, purpose or type, are not to be considered as new products according to Union harmonisation legislation. Thus, such products do not need to undergo conformity assessment again, whether or not the original product was placed on the market before or after the legislation entered into force. This applies even if the product has been temporarily exported to a third county for the repair operations. Such operations are often carried out by replacing a defective or worn item by a spare part, which is either identical, or at least similar, to the original part (for example modifications may have taken place due to technical progress, or discontinued production of the old part) or the entire identical unit. Thus, maintenance operations are basically excluded from the scope of the Union harmonisation legislation. Jim James L. Knighten, Ph.D. [cid:image001.png@01D4AF12.7992C140] 17095 Via Del Campo San Diego, CA 92127 858-485-2537 From: McBurney, Ian Sent: Friday, January 18, 2019 1:50 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Spare parts requiring an EU declaration of Conformity. [External Email] Dear Colleagues. Can anyone point me to the relevant section in the EU directives regarding the shipping of spares into the EU? We are shipping a spare PSU PCB assembly into Turkey and the Turkish customs want a Declaration of Conformity document. I know Turkey is not in the EU but they are demanding this documentation. I thought that spare parts/assemblies did not require a Declaration of Conformity document if the part was an identical replacement and is being fitted into an already CE marked product. Many thanks in advance. Ian McBurney Lead Compliance Engineer Allen & Heath Ltd. Kernick Industrial estate, Penryn, Cornwall. TR10 9LU. UK. Tel: 01326 372070 Email: ian.mcbur...@allen-heath.com<mailto:ian.mcbur...@allen-heath.com> Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. Any views expressed in this email are those of the individual and not necessarily those of the company. - 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)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 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:
Re: [PSES] Spare parts requiring an EU declaration of Conformity.
The fact remains that Turkey can demand anything it likes. Offer them a single DoC that lists all 7000 assemblies, but skip the parchment and gold lettering. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2019-01-18 15:53, McBurney, Ian wrote: Hello John. The problem is we have over 7000 different spare assemblies and I don’t really want to issue a DoC for each one. Previous product DoCs have had to list each model in the range rather than just specifying the product range series. Regards; Ian McBurney Lead Compliance Engineer Allen & Heath Ltd. Kernick Industrial estate, Penryn, Cornwall. TR10 9LU. UK. Tel: 01326 372070 Email: ian.mcbur...@allen-heath.com *From:*John Woodgate *Sent:* 18 January 2019 15:39 *To:* McBurney, Ian ; EMC-PSTC@LISTSERV.IEEE.ORG *Subject:* Re: [PSES] Spare parts requiring an EU declaration of Conformity. Your simplest course is not to argue but give them the DoC they want. As you say, Turkey is not in the EU, so it could, if it wanted, require a DoC written on parchment, with gold lettering. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk> Rayleigh, Essex UK On 2019-01-18 09:50, McBurney, Ian wrote: Dear Colleagues. Can anyone point me to the relevant section in the EU directives regarding the shipping of spares into the EU? We are shipping a spare PSU PCB assembly into Turkey and the Turkish customs want a Declaration of Conformity document. I know Turkey is not in the EU but they are demanding this documentation. I thought that spare parts/assemblies did not require a Declaration of Conformity document if the part was an identical replacement and is being fitted into an already CE marked product. Many thanks in advance. Ian McBurney Lead Compliance Engineer Allen & Heath Ltd. Kernick Industrial estate, Penryn, Cornwall. TR10 9LU. UK. Tel: 01326 372070 Email: ian.mcbur...@allen-heath.com <mailto:ian.mcbur...@allen-heath.com> Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. Any views expressed in this email are those of the individual and not necessarily those of the company. - 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 <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/ <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 mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto:dhe...@gmail.com>> Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. Any views expressed in this email are those of the individual and not necessarily those of the company. - 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:
Re: [PSES] Spare parts requiring an EU declaration of Conformity.
Your simplest course is not to argue but give them the DoC they want. As you say, Turkey is not in the EU, so it could, if it wanted, require a DoC written on parchment, with gold lettering. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk Rayleigh, Essex UK On 2019-01-18 09:50, McBurney, Ian wrote: Dear Colleagues. Can anyone point me to the relevant section in the EU directives regarding the shipping of spares into the EU? We are shipping a spare PSU PCB assembly into Turkey and the Turkish customs want a Declaration of Conformity document. I know Turkey is not in the EU but they are demanding this documentation. I thought that spare parts/assemblies did not require a Declaration of Conformity document if the part was an identical replacement and is being fitted into an already CE marked product. Many thanks in advance. Ian McBurney Lead Compliance Engineer Allen & Heath Ltd. Kernick Industrial estate, Penryn, Cornwall. TR10 9LU. UK. Tel: 01326 372070 Email: ian.mcbur...@allen-heath.com Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. Any views expressed in this email are those of the individual and not necessarily those of the company. - 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) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas mailto:sdoug...@ieee.org>> Mike Cantwell mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher mailto:j.bac...@ieee.org>> David Heald mailto: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 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] Spare parts requiring an EU declaration of Conformity.
Dear Colleagues. Can anyone point me to the relevant section in the EU directives regarding the shipping of spares into the EU? We are shipping a spare PSU PCB assembly into Turkey and the Turkish customs want a Declaration of Conformity document. I know Turkey is not in the EU but they are demanding this documentation. I thought that spare parts/assemblies did not require a Declaration of Conformity document if the part was an identical replacement and is being fitted into an already CE marked product. Many thanks in advance. Ian McBurney Lead Compliance Engineer Allen & Heath Ltd. Kernick Industrial estate, Penryn, Cornwall. TR10 9LU. UK. Tel: 01326 372070 Email: ian.mcbur...@allen-heath.com Allen & Heath Ltd is a registered business in England and Wales, Company number: 4163451. Any views expressed in this email are those of the individual and not necessarily those of the company. - 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] AW: EU Declaration of Conformity
Hi Andy, yes, the DoC has to be updated. For products already placed on the market before the new directive entered into force, the old DoC is still valid (as defined in Article 25 of the new EMC directive). The identical product, if it is manufactured and placed on the market after the new directive entered into force, needs an updated DoC, otherwise it will be formally non-compliant as defined in Article 22. Kind regards, Bernd Von: McCallum, Andy [mailto:andy.mccal...@mottmac.com] Gesendet: Dienstag, 3. Januar 2017 15:41 An: EMC-PSTC@LISTSERV.IEEE.ORG Betreff: [PSES] EU Declaration of Conformity Hi Should all DoC be updated now to reflect the new EMC directive? The Blue Guide in section 2.10 suggests DoC for old directive are still valid but then goes on to say: “As of their entry into force, the EU Declaration of conformity will need to include the reference to the new Directives for the products placed on the market to be considered as compliant.” Andy McCallum BEng (Hons), MIET, CEng Senior EMC Engineer T +44 (0)1332 220878 M 07720264505 F +44 (0)1332 220835 mailto:andy.mccal...@mottmac.com Mott MacDonald Clair House Stores Road Derby DE21 4BD United Kingdom http://www.mottmac.com/ | https://twitter.com/mottmacdonald | https://www.linkedin.com/company/7253 | https://www.facebook.com/mottmacdonaldgroup | https://www.youtube.com/user/mottmacdonaldgroup Mott MacDonald Limited. Registered in England and Wales no. 1243967. Registered office: Mott MacDonald House, 8-10 Sydenham Road, Croydon CR0 2EE, United Kingdom The information contained in this e-mail is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. If you are not the intended recipient of this e-mail, the use of this information or any disclosure, copying or distribution is prohibited and may be unlawful. If you received this in error, please contact the sender and delete the material from any computer. - 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 List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <mailto:sdoug...@ieee.org> Mike Cantwell <mailto:mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <mailto:j.bac...@ieee.org> David Heald <mailto:dhe...@gmail.com> WILO SE Nortkirchenstrasse 100, 44263 Dortmund Amtsgericht Dortmund, HRB 21356 www.wilo.com Vorstand/Executive Board: Oliver Hermes (Vorsitzender/Chairman), Dr. Markus Beukenberg, Carsten Krumm, Eric Lachambre, Mathias Weyers Aufsichtsratsvorsitzender/Chairman of the Supervisory Board: Prof. Dr. Norbert Wieselhuber Dieses Dokument ist vertraulich zu behandeln. Die Weitergabe sowie Vervielfaeltigung, Verwertung und Mitteilung seines Inhalts ist nur mit unserer ausdruecklichen Genehmigung gestattet. Alle Rechte vorbehalten, insbesondere fuer den Fall der Schutzrechtsanmeldung. This document has to be treated confidentially. Its contents are not to be passed on, duplicated, exploited or disclosed without our expressed permission. All rights reserved, especially the right to apply for protective rights. - 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>
[PSES] EU Declaration of Conformity
Hi Should all DoC be updated now to reflect the new EMC directive? The Blue Guide in section 2.10 suggests DoC for old directive are still valid but then goes on to say: “As of their entry into force, the EU Declaration of conformity will need to include the reference to the new Directives for the products placed on the market to be considered as compliant.” Andy McCallum BEng (Hons), MIET, CEng Senior EMC Engineer T +44 (0)1332 220878 M 07720264505 F +44 (0)1332 220835 andy.mccal...@mottmac.com<mailto:andy.mccal...@mottmac.com> [https://www.mottmac.com/download/file/12617?defaultFile=%2FDefaultImages%2FdefaultImage.png=False=127=true] Mott MacDonald Clair House Stores Road Derby DE21 4BD United Kingdom Website<http://www.mottmac.com/> | Twitter<https://twitter.com/mottmacdonald> | LinkedIn<https://www.linkedin.com/company/7253> | Facebook<https://www.facebook.com/mottmacdonaldgroup> | YouTube<https://www.youtube.com/user/mottmacdonaldgroup> Mott MacDonald Limited. Registered in England and Wales no. 1243967. Registered office: Mott MacDonald House, 8-10 Sydenham Road, Croydon CR0 2EE, United Kingdom The information contained in this e-mail is intended only for the person or entity to which it is addressed and may contain confidential and/or privileged material. If you are not the intended recipient of this e-mail, the use of this information or any disclosure, copying or distribution is prohibited and may be unlawful. If you received this in error, please contact the sender and delete the material from any computer. - 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>
[PSES] CE Declaration of Conformity
Hi folks, I design and manufacture light machinery that includes some sub-assemblies which we purchase and integrate. The sub-assemblies come with their own DoI. In particular I may integrate automatic and non-automatic weighing scales that would come with a DoI or DoC for the machinery and directive and a DoC or DoI for the EMC, 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives. I do not modify the weighing functionality of the scales nor do I do any additional certification on them. The metrology directives require special marking, the CE mark as well as the M mark and notified body ID which come already on the units I integrate. There are no weighing devices that I directly manufacturer that are part of the machinery. What I'm not clear on is whether I should claim compliance to the 2004/22/EC Measuring Instruments and 2009/23/EC Non-automatic Weighing Instruments directives on my DoC and/or product nameplate for the complete machine or whether I should just include the OEM's DoC along with my DoC in the paperwork supplied with the machine (and technical file). I don't know if this situation is different than any are CE marked component within the machine but it would seem so. The EU directives do not actually apply directly to many components that the OEM marks and claims compliance to CE to make it easier for system builders like me. (Some actually state that on their DoCs). The Metrology directives are specific to the scales. Does anyone have any experience with this or something similar? thanks David P. Nyffenegger, PMP, SM-IEEE Product Development Manager - 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
Re: [PSES] CE Declaration of Conformity
Dunno, as my only experience was doing some power converters for an industrial scale. My customer used the WELMEC organization to advise on scoped directives and standards and marks. Have you read 2014/32/EU ? Brian -Original Message- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Friday, January 16, 2015 10:14 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CE Declaration of Conformity Hi folks, I design and manufacture light machinery that includes some sub-assemblies which we purchase and integrate. The sub-assemblies come with their own DoI. In particular I may integrate automatic and non-automatic weighing scales that would come with a DoI or DoC for the machinery and directive and a DoC or DoI for the EMC, 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives. I do not modify the weighing functionality of the scales nor do I do any additional certification on them. The metrology directives require special marking, the CE mark as well as the M mark and notified body ID which come already on the units I integrate. There are no weighing devices that I directly manufacturer that are part of the machinery. What I'm not clear on is whether I should claim compliance to the 2004/22/EC Measuring Instruments and 2009/23/EC Non-automatic Weighing Instruments directives on my DoC and/or product nameplate for the complete machine or whether I should just include the OEM's DoC along with my DoC in the paperwork supplied with the machine (and technical file). I don't know if this situation is different than any are CE marked component within the machine but it would seem so. The EU directives do not actually apply directly to many components that the OEM marks and claims compliance to CE to make it easier for system builders like me. (Some actually state that on their DoCs). The Metrology directives are specific to the scales. Does anyone have any experience with this or something similar? thanks David P. Nyffenegger, PMP, SM-IEEE Product Development Manager - 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
Re: [PSES] CE Declaration of Conformity
Dave A DoI is only defined for the Machinery Directive, it has no application for other directives (though perhaps your suppliers are not aware of this). I would not pass-on a supplier's paperwork (e.g., DoCs) with your own product, but retain them in your technical file as a partial basis for your own declarations. Declare to 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives if you believe your product is in scope. Incorporating a component in scope can effectively repurpose it out of scope. For example if you incorporate a gas meter (generally sold for monitoring and billing consumers) into a product just to measure gas feed into e.g., a toxic gas burner (and no public interest is involved per se), then I do not think it would be in scope of 20014/22/EC for that use. Regards, Lauren Crane KLA-Tencor -Original Message- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Friday, January 16, 2015 12:14 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CE Declaration of Conformity Hi folks, I design and manufacture light machinery that includes some sub-assemblies which we purchase and integrate. The sub-assemblies come with their own DoI. In particular I may integrate automatic and non-automatic weighing scales that would come with a DoI or DoC for the machinery and directive and a DoC or DoI for the EMC, 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives. I do not modify the weighing functionality of the scales nor do I do any additional certification on them. The metrology directives require special marking, the CE mark as well as the M mark and notified body ID which come already on the units I integrate. There are no weighing devices that I directly manufacturer that are part of the machinery. What I'm not clear on is whether I should claim compliance to the 2004/22/EC Measuring Instruments and 2009/23/EC Non-automatic Weighing Instruments directives on my DoC and/or product nameplate for the complete machine or whether I should just include the OEM's DoC along with my DoC in the paperwork supplied with the machine (and technical file). I don't know if this situation is different than any are CE marked component within the machine but it would seem so. The EU directives do not actually apply directly to many components that the OEM marks and claims compliance to CE to make it easier for system builders like me. (Some actually state that on their DoCs). The Metrology directives are specific to the scales. Does anyone have any experience with this or something similar? thanks David P. Nyffenegger, PMP, SM-IEEE Product Development Manager - 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
Re: [PSES] CE Declaration of Conformity
The supplied DoI is for the machinery directive (and EMC). They actually supply a separate DoC for the weighing directive. I miss-stated that in my original email. I suppose that logic trumps the requirement that all declarations are supposed to be together. They could have combined the weighing and EMC declarations. -Dave -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: Friday, January 16, 2015 1:41 PM To: Nyffenegger, Dave; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: CE Declaration of Conformity Dave A DoI is only defined for the Machinery Directive, it has no application for other directives (though perhaps your suppliers are not aware of this). I would not pass-on a supplier's paperwork (e.g., DoCs) with your own product, but retain them in your technical file as a partial basis for your own declarations. Declare to 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives if you believe your product is in scope. Incorporating a component in scope can effectively repurpose it out of scope. For example if you incorporate a gas meter (generally sold for monitoring and billing consumers) into a product just to measure gas feed into e.g., a toxic gas burner (and no public interest is involved per se), then I do not think it would be in scope of 20014/22/EC for that use. Regards, Lauren Crane KLA-Tencor -Original Message- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Friday, January 16, 2015 12:14 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CE Declaration of Conformity Hi folks, I design and manufacture light machinery that includes some sub-assemblies which we purchase and integrate. The sub-assemblies come with their own DoI. In particular I may integrate automatic and non-automatic weighing scales that would come with a DoI or DoC for the machinery and directive and a DoC or DoI for the EMC, 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives. I do not modify the weighing functionality of the scales nor do I do any additional certification on them. The metrology directives require special marking, the CE mark as well as the M mark and notified body ID which come already on the units I integrate. There are no weighing devices that I directly manufacturer that are part of the machinery. What I'm not clear on is whether I should claim compliance to the 2004/22/EC Measuring Instruments and 2009/23/EC Non-automatic Weighing Instruments directives on my DoC and/or product nameplate for the complete machine or whether I should just include the OEM's DoC along with my DoC in the paperwork supplied with the machine (and technical file). I don't know if this situation is different than any are CE marked component within the machine but it would seem so. The EU directives do not actually apply directly to many components that the OEM marks and claims compliance to CE to make it easier for system builders like me. (Some actually state that on their DoCs). The Metrology directives are specific to the scales. Does anyone have any experience with this or something similar? thanks David P. Nyffenegger, PMP, SM-IEEE Product Development Manager - 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
Re: [PSES] CE Declaration of Conformity
This makes sense. Thanks -Dave -Original Message- From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: Friday, January 16, 2015 2:46 PM To: Nyffenegger, Dave Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Declaration of Conformity Surely if you declare compliance with any particular Directive on your Declaration then you must follow the attestation procedures for that Directive. On the basis of a quick look, there is no attestation route under the NAWID which does not require some form of Notified Body intervention. I know that this is not completely true for the MID, but in practice most measuring instruments do require NB intervention for CE marking under the MID. Therefore, it seems to me that unless you engage an NB to help you declare compliance for your complete machine, you cannot include a declaration of compliance to the NWAID or the MID on the Declaration of the complete machine. The Machinery Directive says that you also need to identify any other applicable Directives on your Declaration: 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.” (2006/42/EC annex II (1 )A item 4). A strict reading of this means you have to declare compliance with the NWAID in addition to the Machienry Directive, but applying my logic above that would imply involving an NB to be involved in attestation of the complete machine, something I’m sure you won’t want to do. My advice is to issue a Declaration in which you claim compliance only for those Directives where you have competed the correct attestation procedure (likely to be Machinery, EMC and RoHS in this case) and supply a copy of the weighing machine’s DofC alongside your machinery DofC. If you attempt to ‘badge' the weighing machine as your own by not supplying the OEM’s Declaration then I think you will need to comply with the NWAID and/or the MID which means applying the relevant procedures from these directives. Nick. On 16 Jan 2015, at 18:13, Nyffenegger, Dave dave.nyffeneg...@bhemail.com wrote: Hi folks, I design and manufacture light machinery that includes some sub-assemblies which we purchase and integrate. The sub-assemblies come with their own DoI. In particular I may integrate automatic and non-automatic weighing scales that would come with a DoI or DoC for the machinery and directive and a DoC or DoI for the EMC, 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives. I do not modify the weighing functionality of the scales nor do I do any additional certification on them. The metrology directives require special marking, the CE mark as well as the M mark and notified body ID which come already on the units I integrate. There are no weighing devices that I directly manufacturer that are part of the machinery. What I'm not clear on is whether I should claim compliance to the 2004/22/EC Measuring Instruments and 2009/23/EC Non-automatic Weighing Instruments directives on my DoC and/or product nameplate for the complete machine or whether I should just include the OEM's DoC along with my DoC in the paperwork supplied with the machine (and technical file). I don't know if this situation is different than any are CE marked component within the machine but it would seem so. The EU directives do not actually apply directly to many components that the OEM marks and claims compliance to CE to make it easier for system builders like me. (Some actually state that on their DoCs). The Metrology directives are specific to the scales. Does anyone have any experience with this or something similar? thanks David P. Nyffenegger, PMP, SM-IEEE Product Development Manager - 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
Re: [PSES] CE Declaration of Conformity
Surely if you declare compliance with any particular Directive on your Declaration then you must follow the attestation procedures for that Directive. On the basis of a quick look, there is no attestation route under the NAWID which does not require some form of Notified Body intervention. I know that this is not completely true for the MID, but in practice most measuring instruments do require NB intervention for CE marking under the MID. Therefore, it seems to me that unless you engage an NB to help you declare compliance for your complete machine, you cannot include a declaration of compliance to the NWAID or the MID on the Declaration of the complete machine. The Machinery Directive says that you also need to identify any other applicable Directives on your Declaration: 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.” (2006/42/EC annex II (1 )A item 4). A strict reading of this means you have to declare compliance with the NWAID in addition to the Machienry Directive, but applying my logic above that would imply involving an NB to be involved in attestation of the complete machine, something I’m sure you won’t want to do. My advice is to issue a Declaration in which you claim compliance only for those Directives where you have competed the correct attestation procedure (likely to be Machinery, EMC and RoHS in this case) and supply a copy of the weighing machine’s DofC alongside your machinery DofC. If you attempt to ‘badge' the weighing machine as your own by not supplying the OEM’s Declaration then I think you will need to comply with the NWAID and/or the MID which means applying the relevant procedures from these directives. Nick. On 16 Jan 2015, at 18:13, Nyffenegger, Dave dave.nyffeneg...@bhemail.com wrote: Hi folks, I design and manufacture light machinery that includes some sub-assemblies which we purchase and integrate. The sub-assemblies come with their own DoI. In particular I may integrate automatic and non-automatic weighing scales that would come with a DoI or DoC for the machinery and directive and a DoC or DoI for the EMC, 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives. I do not modify the weighing functionality of the scales nor do I do any additional certification on them. The metrology directives require special marking, the CE mark as well as the M mark and notified body ID which come already on the units I integrate. There are no weighing devices that I directly manufacturer that are part of the machinery. What I'm not clear on is whether I should claim compliance to the 2004/22/EC Measuring Instruments and 2009/23/EC Non-automatic Weighing Instruments directives on my DoC and/or product nameplate for the complete machine or whether I should just include the OEM's DoC along with my DoC in the paperwork supplied with the machine (and technical file). I don't know if this situation is different than any are CE marked component within the machine but it would seem so. The EU directives do not actually apply directly to many components that the OEM marks and claims compliance to CE to make it easier for system builders like me. (Some actually state that on their DoCs). The Metrology directives are specific to the scales. Does anyone have any experience with this or something similar? thanks David P. Nyffenegger, PMP, SM-IEEE Product Development Manager - 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
Re: [PSES] CE Declaration of Conformity
As an aside, I wish that many other directives would include the DoI concept for components - and then we might be able to get away from the type of comment about a component that has a CE marking and a DoC and so it must be OK and we don't need to do anything else (like ensuring that when installed in the final product then that product does still meet the end-product standard?). John Allen W.London, UK. -Original Message- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: 16 January 2015 20:05 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Declaration of Conformity The supplied DoI is for the machinery directive (and EMC). They actually supply a separate DoC for the weighing directive. I miss-stated that in my original email. I suppose that logic trumps the requirement that all declarations are supposed to be together. They could have combined the weighing and EMC declarations. -Dave -Original Message- From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: Friday, January 16, 2015 1:41 PM To: Nyffenegger, Dave; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: CE Declaration of Conformity Dave A DoI is only defined for the Machinery Directive, it has no application for other directives (though perhaps your suppliers are not aware of this). I would not pass-on a supplier's paperwork (e.g., DoCs) with your own product, but retain them in your technical file as a partial basis for your own declarations. Declare to 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives if you believe your product is in scope. Incorporating a component in scope can effectively repurpose it out of scope. For example if you incorporate a gas meter (generally sold for monitoring and billing consumers) into a product just to measure gas feed into e.g., a toxic gas burner (and no public interest is involved per se), then I do not think it would be in scope of 20014/22/EC for that use. Regards, Lauren Crane KLA-Tencor -Original Message- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Friday, January 16, 2015 12:14 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CE Declaration of Conformity Hi folks, I design and manufacture light machinery that includes some sub-assemblies which we purchase and integrate. The sub-assemblies come with their own DoI. In particular I may integrate automatic and non-automatic weighing scales that would come with a DoI or DoC for the machinery and directive and a DoC or DoI for the EMC, 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives. I do not modify the weighing functionality of the scales nor do I do any additional certification on them. The metrology directives require special marking, the CE mark as well as the M mark and notified body ID which come already on the units I integrate. There are no weighing devices that I directly manufacturer that are part of the machinery. What I'm not clear on is whether I should claim compliance to the 2004/22/EC Measuring Instruments and 2009/23/EC Non-automatic Weighing Instruments directives on my DoC and/or product nameplate for the complete machine or whether I should just include the OEM's DoC along with my DoC in the paperwork supplied with the machine (and technical file). I don't know if this situation is different than any are CE marked component within the machine but it would seem so. The EU directives do not actually apply directly to many components that the OEM marks and claims compliance to CE to make it easier for system builders like me. (Some actually state that on their DoCs). The Metrology directives are specific to the scales. Does anyone have any experience with this or something similar? thanks David P. Nyffenegger, PMP, SM-IEEE Product Development Manager - 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
Re: [PSES] Definition of Declaration of Conformity
Hi Scott, CE Marking and associated Declaration of Conformity is complicated when viewed as a whole but greatly simplifies when considered for just a single product (including variants). Its almost impossible to give a universal answer because whilst there are commonalities between Directives, there are also some very significant differences. If you could be specific about your products, an appropriate concise answer should be possible. One tip, many DoCs are in the public domain on the Internet and a targeted Google search will show you how others do it. For example, suppose you made Bluetooth headsets, try this Google search (including the quotation marks).Youll see plenty of recent (2013-2014) examples ofDoCs, including from companies youd expect to be getting this sort of thing right (but thats no guarantee I hasten to add!). Omit or modify the date range for (..) for a broadertime-span. Declaration of Conformitybluetoothheadset1999/5/EC filetype:pdf 2013..2014 Hope this helps, Tony. Sent:Tuesday, June 24, 2014 at 5:30 PM From:Scott Xe scott...@gmail.com To:EMC-PSTC@LISTSERV.IEEE.ORG Subject:[PSES] Definition of Declaration of Conformity In the field, lots of people such as customers, market surveillances, customs, etc. are asking for a DoC on particular product and/or its variants in Europe. What is the exact meaning of the DoC? Is it the one to support the compliance of CE mark? Or the compliance of all legal requirements (more than CE mark) relevant to the product. Is there a uniform format satisfying the essential requirements? Who is the valid issuer? Do they need to be a company located in Europe? Thanks and regards, Scott - 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 emcp...@radiusnorth.net 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
Re: [PSES] Definition of Declaration of Conformity
Hello Tony, You have a good example, RTTE Directive. This directive requires a declaration in operating instructions. According to CE marking, it requires a DoC for new approach directives. RTTE is under CE mark scope and accordingly there are two DoCs required. For other regulation such as RoHS, WEEE, REACH, Food Safety, etc. we need to follow individual regulation/directives. In reality, should we issue one covering all directives/regulation. It also simplify the process between buyers and suppliers. Regards, Scott On 25/6/14 7:45 pm, Anthony Thomson ton...@europe.com wrote: Hi Scott, CE Marking and associated Declaration of Conformity is complicated when viewed as a whole but greatly simplifies when considered for just a single product (including variants). It's almost impossible to give a 'universal' answer because whilst there are commonalities between Directives, there are also some very significant differences. If you could be specific about your products, an appropriate concise answer should be possible. One tip, many DoC's are in the public domain on the Internet and a targeted Google search will show you how others do it. For example, suppose you made Bluetooth headsets, try this Google search (including the quotation marks). You'll see plenty of recent (2013-2014) examples of DoC's, including from companies you'd expect to be getting this sort of thing right (but that's no guarantee I hasten to add!). Omit or modify the date range for (..) for a broader time-span. Declaration of Conformity bluetooth headset 1999/5/EC filetype:pdf 2013..2014 Hope this helps, Tony. Sent: Tuesday, June 24, 2014 at 5:30 PM From: Scott Xe scott...@gmail.com To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Definition of Declaration of Conformity In the field, lots of people such as customers, market surveillances, customs, etc. are asking for a DoC on particular product and/or its variants in Europe. What is the exact meaning of the DoC? Is it the one to support the compliance of CE mark? Or the compliance of all legal requirements (more than CE mark) relevant to the product. Is there a uniform format satisfying the essential requirements? Who is the valid issuer? Do they need to be a company located in Europe? Thanks and regards, Scott - 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 emcp...@radiusnorth.net 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) http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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 emcp...@radiusnorth.net Mike
Re: [PSES] Definition of Declaration of Conformity
Hi John, The info is clear that DoC is required for CE marking. When someone asks for DoC, that is to say a DoC for CE marking? We do not need to put the compliance of other legal requirements. Regards, Scott On 25/6/14 2:02 am, Tyra, John john_t...@bose.com wrote: There is a lot of guidance on the internet related to CE Marking and DoC's https://www.gov.uk/ce-marking http://ec.europa.eu/enterprise/policies/single-market-goods/cemarking/ http://www.ce-marking.org/what-is-ce-marking.html -Original Message- From: Scott Xe [mailto:scott...@gmail.com] Sent: Tuesday, June 24, 2014 12:30 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Definition of Declaration of Conformity In the field, lots of people such as customers, market surveillances, customs, etc. are asking for a DoC on particular product and/or its variants in Europe. What is the exact meaning of the DoC? Is it the one to support the compliance of CE mark? Or the compliance of all legal requirements (more than CE mark) relevant to the product. Is there a uniform format satisfying the essential requirements? Who is the valid issuer? Do they need to be a company located in Europe? Thanks and regards, Scott - 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 emcp...@radiusnorth.net 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Definition of Declaration of Conformity
In simplified terms you need to make sure your product meets all the applicable Directives and test to the standards that apply under those Directives if applicable. This could include but not limited to Safety, EMC RTTE, RoHs, Energy Efficiency etc. as applicable. There are other options to show compliance but testing to established standards as listed under the applicable Directive is the easiest way to show compliance IMHO You must also create Technical Construction File (TCF) to support your DoC . Be aware the CE Mark must be on your product unless it is too small which allows for marking of packaging and in your user instructions. The CE Mark has some minimum dimensions that must be adhered to. We recently had issues in one of the EU countries as our CE mark was slightly out of registration so some countries can be picky about this. Be aware that this is general guidance and may not be applicable to your product -Original Message- From: Scott Xe [mailto:scott...@gmail.com] Sent: Wednesday, June 25, 2014 9:54 AM To: Tyra, John; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Definition of Declaration of Conformity Hi John, The info is clear that DoC is required for CE marking. When someone asks for DoC, that is to say a DoC for CE marking? We do not need to put the compliance of other legal requirements. Regards, Scott On 25/6/14 2:02 am, Tyra, John john_t...@bose.com wrote: There is a lot of guidance on the internet related to CE Marking and DoC's https://www.gov.uk/ce-marking http://ec.europa.eu/enterprise/policies/single-market-goods/cemarking/ http://www.ce-marking.org/what-is-ce-marking.html -Original Message- From: Scott Xe [mailto:scott...@gmail.com] Sent: Tuesday, June 24, 2014 12:30 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Definition of Declaration of Conformity In the field, lots of people such as customers, market surveillances, customs, etc. are asking for a DoC on particular product and/or its variants in Europe. What is the exact meaning of the DoC? Is it the one to support the compliance of CE mark? Or the compliance of all legal requirements (more than CE mark) relevant to the product. Is there a uniform format satisfying the essential requirements? Who is the valid issuer? Do they need to be a company located in Europe? Thanks and regards, Scott - 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 emcp...@radiusnorth.net 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Definition of Declaration of Conformity
Whilst it's (only) a guide, section 4.4 of the recently updated Blue Guide has quite a bit of information on EU Declaration of Conformity: http://ec.europa.eu/enterprise/policies/single-market-goods/documents/internal-market-for-products/new-legislative-framework/index_en.htm#h2-3 As previously noted, and stated therein, there's no single format as not all directives require the same things. Regards Charlie -Original Message- From: Scott Xe [mailto:scott...@gmail.com] Sent: 25 June 2014 14:54 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Definition of Declaration of Conformity Hi John, The info is clear that DoC is required for CE marking. When someone asks for DoC, that is to say a DoC for CE marking? We do not need to put the compliance of other legal requirements. Regards, Scott On 25/6/14 2:02 am, Tyra, John john_t...@bose.com wrote: There is a lot of guidance on the internet related to CE Marking and DoC's https://www.gov.uk/ce-marking http://ec.europa.eu/enterprise/policies/single-market-goods/cemarking/ http://www.ce-marking.org/what-is-ce-marking.html -Original Message- From: Scott Xe [mailto:scott...@gmail.com] Sent: Tuesday, June 24, 2014 12:30 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Definition of Declaration of Conformity In the field, lots of people such as customers, market surveillances, customs, etc. are asking for a DoC on particular product and/or its variants in Europe. What is the exact meaning of the DoC? Is it the one to support the compliance of CE mark? Or the compliance of all legal requirements (more than CE mark) relevant to the product. Is there a uniform format satisfying the essential requirements? Who is the valid issuer? Do they need to be a company located in Europe? Thanks and regards, Scott - 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 emcp...@radiusnorth.net 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 emcp...@radiusnorth.net 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] Definition of Declaration of Conformity
In the field, lots of people such as customers, market surveillances, customs, etc. are asking for a DoC on particular product and/or its variants in Europe. What is the exact meaning of the DoC? Is it the one to support the compliance of CE mark? Or the compliance of all legal requirements (more than CE mark) relevant to the product. Is there a uniform format satisfying the essential requirements? Who is the valid issuer? Do they need to be a company located in Europe? Thanks and regards, Scott - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Definition of Declaration of Conformity
There is a lot of guidance on the internet related to CE Marking and DoC's https://www.gov.uk/ce-marking http://ec.europa.eu/enterprise/policies/single-market-goods/cemarking/ http://www.ce-marking.org/what-is-ce-marking.html -Original Message- From: Scott Xe [mailto:scott...@gmail.com] Sent: Tuesday, June 24, 2014 12:30 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Definition of Declaration of Conformity In the field, lots of people such as customers, market surveillances, customs, etc. are asking for a DoC on particular product and/or its variants in Europe. What is the exact meaning of the DoC? Is it the one to support the compliance of CE mark? Or the compliance of all legal requirements (more than CE mark) relevant to the product. Is there a uniform format satisfying the essential requirements? Who is the valid issuer? Do they need to be a company located in Europe? Thanks and regards, Scott - 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 emcp...@radiusnorth.net 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Definition of Declaration of Conformity
John has provided the essential stuff. Some of my employer's customers seem to get the Declaration of Conformity confused with a (contractual) 'Certificate of Conformity'. Methinks the important stuff is framed by the how the document meets the directives' requirements for the basis of the presumption of conformity. So the meaning will vary with the scoped directive(s). Am not aware of any uniform format for a D of C., but ISO17050-x does provide the basics. NLF-based stuff describes responsibilities for various parties different than the older stuff. Brian -Original Message- From: Tyra, John [mailto:john_t...@bose.com] Sent: Tuesday, June 24, 2014 11:03 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Definition of Declaration of Conformity There is a lot of guidance on the internet related to CE Marking and DoC's https://www.gov.uk/ce-marking http://ec.europa.eu/enterprise/policies/single-market-goods/cemarking/ http://www.ce-marking.org/what-is-ce-marking.html -Original Message- From: Scott Xe [mailto:scott...@gmail.com] Sent: Tuesday, June 24, 2014 12:30 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Definition of Declaration of Conformity In the field, lots of people such as customers, market surveillances, customs, etc. are asking for a DoC on particular product and/or its variants in Europe. What is the exact meaning of the DoC? Is it the one to support the compliance of CE mark? Or the compliance of all legal requirements (more than CE mark) relevant to the product. Is there a uniform format satisfying the essential requirements? Who is the valid issuer? Do they need to be a company located in Europe? Thanks and regards, Scott - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EU Declaration of Conformity
Thanks. The explanatory pages seem to be consistent with my interpretation. -Dave From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: Friday, February 28, 2014 3:54 PM To: Nyffenegger, Dave Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU Declaration of Conformity Dave, The person 'authorised to compile the technical file' does not have to be the Authorised Representative. The manufacturer's DofC signatory does not have to be located within the EU. Our explanatory pages at www.doceupoint.euhttp://www.doceupoint.eu may help to clarify the requirements. [Apologies if the latter point is seen to be advertising, but the pages in question directly address the OPs questions and I think it is more appropriate to provide a web link than to paste the content here]. Regards Nick. On 27 Feb 2014, at 18:32, Nyffenegger, Dave dave.nyffeneg...@bhemail.commailto:dave.nyffeneg...@bhemail.com wrote: Hello PSES Forum, I'm looking for some feedback interpreting the DIRECTIVE 2006/42/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2006. Article 3 defines: (i) 'manufacturer' means any natural or legal person who designs and/or manufactures machinery or partly completed machinery covered by this Directive and is responsible for the conformity of the machinery or the partly completed machinery with this Directive with a view to its being placed on the market, under his own name or trademark or for his own use. In the absence of a manufacturer as defined above, any natural or legal person who places on the market or puts into service machinery or partly completed machinery covered by this Directive shall be considered a manufacturer; (j) 'authorised representative' means any natural or legal person established in the Community who has received a written mandate from the manufacturer to perform on his behalf all or part of the obligations and formalities connected with this Directive; ANNEX II declares The EC declaration of conformity must contain the following particulars: 2. name and address of the person authorised to compile the technical file, who must be established in the Community; . 10. the identity and signature of the person empowered to draw up the declaration on behalf of the manufacturer or his authorised representative. It's not clear to me if the person authorised to compile the technical file is intended to be one and the same as 'authorised representative' or not. I have often heard the that signature on the DoC also needed to come from a member of the Community. The way I read the directive that is only the case for or his authorised representative. The Directive also states the signature can be the person empowered to draw up the declaration on behalf of the manufacturer . There is nothing in the declaration that requires the manufacturer or person empowered by the manufacturer to be a member of the Community. Does anyone know if there have been any further clarifications or interpretations on this? David P. Nyffenegger, PMP, SM-IEEE Product Development Manager Bell and Howell 3791 South Alston Avenue Durham, NC 27713 Phone: 919.767.6419 Web: www.bellhowell.nethttp://www.bellhowell.net Nick Williams Director Direct line: +44 1298 873811 Mobile: +44 7702 995135 email: nick.willi...@conformance.co.ukmailto:nick.willi...@conformance.co.uk - Conformance Ltd - Product safety, approvals and CE-marking consultants The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.ukhttp://www.conformance.co.uk Registered in England, Company No. 3478646 - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EU Declaration of Conformity
Dave et all Note that however correct the interpretation (of Nick Williams reference) may be, that it's not an authoritative reference with legal value (if you needed one ). and there is probably none. These interpretations are open to discussion, and may lead to different results dependent on where (read : in what country/court) the interpretation is sought. All this said: I do strongly agree with you and Nick here, but we do not know for what reason this question has risen... Gert Gremmen Van: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Verzonden: zaterdag 1 maart 2014 4:34 Aan: EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: Re: [PSES] EU Declaration of Conformity Thanks. The explanatory pages seem to be consistent with my interpretation. -Dave From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: Friday, February 28, 2014 3:54 PM To: Nyffenegger, Dave Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU Declaration of Conformity Dave, The person 'authorised to compile the technical file' does not have to be the Authorised Representative. The manufacturer's DofC signatory does not have to be located within the EU. Our explanatory pages at www.doceupoint.eu may help to clarify the requirements. [Apologies if the latter point is seen to be advertising, but the pages in question directly address the OPs questions and I think it is more appropriate to provide a web link than to paste the content here]. Regards Nick. On 27 Feb 2014, at 18:32, Nyffenegger, Dave dave.nyffeneg...@bhemail.com wrote: Hello PSES Forum, I'm looking for some feedback interpreting the DIRECTIVE 2006/42/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2006. Article 3 defines: (i) 'manufacturer' means any natural or legal person who designs and/or manufactures machinery or partly completed machinery covered by this Directive and is responsible for the conformity of the machinery or the partly completed machinery with this Directive with a view to its being placed on the market, under his own name or trademark or for his own use. In the absence of a manufacturer as defined above, any natural or legal person who places on the market or puts into service machinery or partly completed machinery covered by this Directive shall be considered a manufacturer; (j) 'authorised representative' means any natural or legal person established in the Community who has received a written mandate from the manufacturer to perform on his behalf all or part of the obligations and formalities connected with this Directive; ANNEX II declares The EC declaration of conformity must contain the following particulars: 2. name and address of the person authorised to compile the technical file, who must be established in the Community; . 10. the identity and signature of the person empowered to draw up the declaration on behalf of the manufacturer or his authorised representative. It's not clear to me if the person authorised to compile the technical file is intended to be one and the same as 'authorised representative' or not. I have often heard the that signature on the DoC also needed to come from a member of the Community. The way I read the directive that is only the case for or his authorised representative. The Directive also states the signature can be the person empowered to draw up the declaration on behalf of the manufacturer . There is nothing in the declaration that requires the manufacturer or person empowered by the manufacturer to be a member of the Community. Does anyone know if there have been any further clarifications or interpretations on this? David P. Nyffenegger, PMP, SM-IEEE Product Development Manager Bell and Howell 3791 South Alston Avenue Durham, NC 27713 Phone: 919.767.6419 Web: www.bellhowell.net Nick Williams Director Direct line: +44 1298 873811 Mobile: +44 7702 995135 email: nick.willi...@conformance.co.uk - Conformance Ltd - Product safety, approvals and CE-marking consultants The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk Registered in England, Company No. 3478646 - 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) http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html
Re: [PSES] EU Declaration of Conformity
I've not raised the questions for anything other than understanding the intent and the options. We've not had any challenges. Historically we as a US manufacturer have used the same person as both an Authorized Representative to sign the DoC and to provide the technical file and we have used two different persons in the EU on the same DoC this. What we haven't done is use an internal empowered US based signatory to make the declaration and a person in the EU responsible for the technical file. This seems to be the simplest approach as there is no needed to go back and forth with signatures. -Dave From: ce-test, qualified testing bv - Gert Gremmen [mailto:g.grem...@cetest.nl] Sent: Saturday, March 01, 2014 4:51 AM To: Nyffenegger, Dave; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EU Declaration of Conformity Dave et all Note that however correct the interpretation (of Nick Williams reference) may be, that it's not an authoritative reference with legal value (if you needed one ). and there is probably none. These interpretations are open to discussion, and may lead to different results dependent on where (read : in what country/court) the interpretation is sought. All this said: I do strongly agree with you and Nick here, but we do not know for what reason this question has risen... Gert Gremmen Van: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Verzonden: zaterdag 1 maart 2014 4:34 Aan: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: Re: [PSES] EU Declaration of Conformity Thanks. The explanatory pages seem to be consistent with my interpretation. -Dave From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: Friday, February 28, 2014 3:54 PM To: Nyffenegger, Dave Cc: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EU Declaration of Conformity Dave, The person 'authorised to compile the technical file' does not have to be the Authorised Representative. The manufacturer's DofC signatory does not have to be located within the EU. Our explanatory pages at www.doceupoint.euhttp://www.doceupoint.eu may help to clarify the requirements. [Apologies if the latter point is seen to be advertising, but the pages in question directly address the OPs questions and I think it is more appropriate to provide a web link than to paste the content here]. Regards Nick. On 27 Feb 2014, at 18:32, Nyffenegger, Dave dave.nyffeneg...@bhemail.commailto:dave.nyffeneg...@bhemail.com wrote: Hello PSES Forum, I'm looking for some feedback interpreting the DIRECTIVE 2006/42/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2006. Article 3 defines: (i) 'manufacturer' means any natural or legal person who designs and/or manufactures machinery or partly completed machinery covered by this Directive and is responsible for the conformity of the machinery or the partly completed machinery with this Directive with a view to its being placed on the market, under his own name or trademark or for his own use. In the absence of a manufacturer as defined above, any natural or legal person who places on the market or puts into service machinery or partly completed machinery covered by this Directive shall be considered a manufacturer; (j) 'authorised representative' means any natural or legal person established in the Community who has received a written mandate from the manufacturer to perform on his behalf all or part of the obligations and formalities connected with this Directive; ANNEX II declares The EC declaration of conformity must contain the following particulars: 2. name and address of the person authorised to compile the technical file, who must be established in the Community; . 10. the identity and signature of the person empowered to draw up the declaration on behalf of the manufacturer or his authorised representative. It's not clear to me if the person authorised to compile the technical file is intended to be one and the same as 'authorised representative' or not. I have often heard the that signature on the DoC also needed to come from a member of the Community. The way I read the directive that is only the case for or his authorised representative. The Directive also states the signature can be the person empowered to draw up the declaration on behalf of the manufacturer . There is nothing in the declaration that requires the manufacturer or person empowered by the manufacturer to be a member of the Community. Does anyone know if there have been any further clarifications or interpretations on this? David P. Nyffenegger, PMP, SM-IEEE Product Development Manager Bell and Howell 3791 South Alston Avenue Durham, NC 27713 Phone: 919.767.6419 Web: www.bellhowell.nethttp://www.bellhowell.net Nick Williams Director Direct line: +44 1298 873811 Mobile: +44 7702 995135 email: nick.willi...@conformance.co.ukmailto:nick.willi...@conformance.co.uk
Re: [PSES] EU Declaration of Conformity
Dave, The person ‘authorised to compile the technical file’ does not have to be the Authorised Representative. The manufacturer’s DofC signatory does not have to be located within the EU. Our explanatory pages at www.doceupoint.eu may help to clarify the requirements. [Apologies if the latter point is seen to be advertising, but the pages in question directly address the OPs questions and I think it is more appropriate to provide a web link than to paste the content here]. Regards Nick. On 27 Feb 2014, at 18:32, Nyffenegger, Dave dave.nyffeneg...@bhemail.com wrote: Hello PSES Forum, I'm looking for some feedback interpreting the DIRECTIVE 2006/42/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2006. Article 3 defines: (i) 'manufacturer' means any natural or legal person who designs and/or manufactures machinery or partly completed machinery covered by this Directive and is responsible for the conformity of the machinery or the partly completed machinery with this Directive with a view to its being placed on the market, under his own name or trademark or for his own use. In the absence of a manufacturer as defined above, any natural or legal person who places on the market or puts into service machinery or partly completed machinery covered by this Directive shall be considered a manufacturer; (j) 'authorised representative' means any natural or legal person established in the Community who has received a written mandate from the manufacturer to perform on his behalf all or part of the obligations and formalities connected with this Directive; ANNEX II declares The EC declaration of conformity must contain the following particulars: 2. name and address of the person authorised to compile the technical file, who must be established in the Community; . 10. the identity and signature of the person empowered to draw up the declaration on behalf of the manufacturer or his authorised representative. It's not clear to me if the person authorised to compile the technical file is intended to be one and the same as 'authorised representative' or not. I have often heard the that signature on the DoC also needed to come from a member of the Community. The way I read the directive that is only the case for or his authorised representative. The Directive also states the signature can be the person empowered to draw up the declaration on behalf of the manufacturer . There is nothing in the declaration that requires the manufacturer or person empowered by the manufacturer to be a member of the Community. Does anyone know if there have been any further clarifications or interpretations on this? David P. Nyffenegger, PMP, SM-IEEE Product Development Manager Bell and Howell 3791 South Alston Avenue Durham, NC 27713 Phone: 919.767.6419 Web: www.bellhowell.net Nick Williams Director Direct line: +44 1298 873811 Mobile: +44 7702 995135 email: nick.willi...@conformance.co.uk - Conformance Ltd - Product safety, approvals and CE-marking consultants The Old Methodist Chapel, Great Hucklow, Buxton, SK17 8RG England Tel. +44 1298 873800, Fax. +44 1298 873801, www.conformance.co.uk Registered in England, Company No. 3478646 - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] EU Declaration of Conformity
Hello PSES Forum, I'm looking for some feedback interpreting the DIRECTIVE 2006/42/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2006. Article 3 defines: (i) 'manufacturer' means any natural or legal person who designs and/or manufactures machinery or partly completed machinery covered by this Directive and is responsible for the conformity of the machinery or the partly completed machinery with this Directive with a view to its being placed on the market, under his own name or trademark or for his own use. In the absence of a manufacturer as defined above, any natural or legal person who places on the market or puts into service machinery or partly completed machinery covered by this Directive shall be considered a manufacturer; (j) 'authorised representative' means any natural or legal person established in the Community who has received a written mandate from the manufacturer to perform on his behalf all or part of the obligations and formalities connected with this Directive; ANNEX II declares The EC declaration of conformity must contain the following particulars: 2. name and address of the person authorised to compile the technical file, who must be established in the Community; . 10. the identity and signature of the person empowered to draw up the declaration on behalf of the manufacturer or his authorised representative. It's not clear to me if the person authorised to compile the technical file is intended to be one and the same as 'authorised representative' or not. I have often heard the that signature on the DoC also needed to come from a member of the Community. The way I read the directive that is only the case for or his authorised representative. The Directive also states the signature can be the person empowered to draw up the declaration on behalf of the manufacturer . There is nothing in the declaration that requires the manufacturer or person empowered by the manufacturer to be a member of the Community. Does anyone know if there have been any further clarifications or interpretations on this? David P. Nyffenegger, PMP, SM-IEEE Product Development Manager Bell and Howell 3791 South Alston Avenue Durham, NC 27713 Phone: 919.767.6419 Web: www.bellhowell.net - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Declaration of Conformity
I agree with you and I am in favor of providing the DoC to the customer (preferably before purchase); however, it is an unnecessary burden on the manufacturer to have to put the DoC in the Instruction Manual as the MD states. Let me provide the DoC to my customer in a way that is best for me and my customer. Instruction Manuals are printed and packed months in advance and built in quantity. If the DoC information changes, I'm shipping old DoCs with my product or I have to rework my Manual Packs with the new DoC which is costly. So I would prefer not having to include this information in the Manual. So how we do it is simply publish the content of the DoC in our manuals (as the MD allows), making the information as generic as possible and leaving out any dates or numbers or signatures that are likely to change, and provide our customers with the official DoC through our Sales/Marketing channels if requested. I think this is the approach a lot of companies are taking. As we hear about proposed future requirement of other Directives wanting to make the DoC more unique for each product built and sold, it would make providing the DoC in a bound manual completely impossible and impractical. Thanks for the information and references. The Other Brian From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: Tuesday, December 03, 2013 10:47 AM To: Kunde, Brian Cc: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Declaration of Conformity The reason for this is that the workplace safety requirements introduced under Article 137 of the TFEU require an employer to ensure that equipment which they supply for the use of their employees complies with the applicable essential requirements. The Declaration is a useful piece of paper to assist an employer in this task. Nick. On 3 Dec 2013, at 00:11, Kunde, Brian brian_ku...@lecotc.commailto:brian_ku...@lecotc.com wrote: The MD requires the DoC (not DoI) or a document calling out the content of the DoC to be provided in the Instruction Manual. The purpose of this requirement is not clear to me but it says it so you have to do it. LECO Corporation Notice: This communication may contain confidential information intended for the named recipient(s) only. If you received this by mistake, please destroy it and notify us of the error. Thank you. - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Declaration of Conformity
The reason for this is that the workplace safety requirements introduced under Article 137 of the TFEU require an employer to ensure that equipment which they supply for the use of their employees complies with the applicable essential requirements. The Declaration is a useful piece of paper to assist an employer in this task. Nick. On 3 Dec 2013, at 00:11, Kunde, Brian brian_ku...@lecotc.com wrote: The MD requires the DoC (not DoI) or a document calling out the content of the DoC to be provided in the Instruction Manual. The purpose of this requirement is not clear to me but it says it so you have to do it. - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Declaration of Conformity
Perhaps discussion of DoI vs. DoC is getting tangled. A DoI is a concept only available to the MD, and because it is related to a machine that is partly complete, it must include a list of the MD Annex I essential heath and safety requirements that have been applied and fulfilled. The assumption being that some have not been fulfilled because the machine is only partly completed. In my experience, people often misunderstand the fine point details associated with partly completed machinery declarations because they are not necessarily aligned with common sense. Download the MD guide and give it a read. http://ec.europa.eu/enterprise/sectors/mechanical/files/machinery/guide-appl-2006-42-ec-2nd-201006_en.pdf Regards, Lauren Crane KLA-Tencor From: Mark Schmidt mark.schm...@dornerworks.commailto:mark.schm...@dornerworks.com To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Sent: Monday, November 25, 2013 2:14:23 PM Subject: [PSES] Declaration of Conformity Hello List, I need some help. I am very new to the Machinery Directive and my customer received a non-conformance from their customer about their DoC. It appears that my customer’s distributor generated a DoI, and it appears that it needs to be a DoC and most importantly their complaint is that it should include a list of which EHSRs are met or not met. Where or how do I determine if these are met or not. Is there a good place to reference? Any help is appreciated like I said I am a newbie when it comes to the Machinery Directive. Thanks, Mark Schmidt - 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 LT;emc-p...@ieee.orgmailto:emc-p...@ieee.orgGT; 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)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas LT;emcp...@radiusnorth.netmailto:emcp...@radiusnorth.netGT; Mike Cantwell LT;mcantw...@ieee.orgmailto:mcantw...@ieee.orgGT; For policy questions, send mail to: Jim Bacher LT;j.bac...@ieee.orgmailto:j.bac...@ieee.orgGT; David Heald LT;dhe...@gmail.commailto:dhe...@gmail.comGT; - 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.orgmailto: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)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto: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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Declaration of Conformity
It is a requirement of the Machinery Directive that a copy of the declaration be supplied with each machine. Whether it should be a DoI or DoC will depend on the circumstances, but either way it should be something that the manufacturer does, so I can't see why the customer's distributor has to generate the document at all? Lauren is correct - a DoC means that all applicable EHSRs have been met. As they all have, it doesn't need to list them. A DoI means some have not, so you need to tell the user what is met and what therefore is not. Crucially, the recipient of a DoI has to carry out further work to bring the equipment into full compliance, so they need to know what that work involves. JohnC _ From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: 02 December 2013 15:58 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Declaration of Conformity Perhaps discussion of DoI vs. DoC is getting tangled. A DoI is a concept only available to the MD, and because it is related to a machine that is partly complete, it must include a list of the MD Annex I essential heath and safety requirements that have been applied and fulfilled. The assumption being that some have not been fulfilled because the machine is only partly completed. In my experience, people often misunderstand the fine point details associated with partly completed machinery declarations because they are not necessarily aligned with common sense. Download the MD guide and give it a read. http://ec.europa.eu/enterprise/sectors/mechanical/files/machinery/guide-appl -2006-42-ec-2nd-201006_en.pdf Regards, Lauren Crane KLA-Tencor _ From: Mark Schmidt mark.schm...@dornerworks.com To: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Monday, November 25, 2013 2:14:23 PM Subject: [PSES] Declaration of Conformity Hello List, I need some help. I am very new to the Machinery Directive and my customer received a non-conformance from their customer about their DoC. It appears that my customer's distributor generated a DoI, and it appears that it needs to be a DoC and most importantly their complaint is that it should include a list of which EHSRs are met or not met. Where or how do I determine if these are met or not. Is there a good place to reference? Any help is appreciated like I said I am a newbie when it comes to the Machinery Directive. Thanks, Mark Schmidt - 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 LT;emc-p...@ieee.orgGT; 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 LT;emcp...@radiusnorth.netGT; Mike Cantwell LT;mcantw...@ieee.orgGT; For policy questions, send mail to: Jim Bacher LT;j.bac...@ieee.orgGT; David Heald LT;dhe...@gmail.comGT; - 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 emcp...@radiusnorth.net 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) http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list
Re: [PSES] Declaration of Conformity
Thanks to all that have responded - overwhelming responses with very insightful information. I will continue my investigation into my customers problems with this directive which (in my opinion) is somewhat undefined or is lacking exactness. This in turn propagates misinterpretation. Thanks to all, Mark From: John Cotman [mailto:john.cot...@conformance.co.uk] Sent: Monday, December 02, 2013 12:42 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Declaration of Conformity It is a requirement of the Machinery Directive that a copy of the declaration be supplied with each machine. Whether it should be a DoI or DoC will depend on the circumstances, but either way it should be something that the manufacturer does, so I can't see why the customer's distributor has to generate the document at all? Lauren is correct - a DoC means that all applicable EHSRs have been met. As they all have, it doesn't need to list them. A DoI means some have not, so you need to tell the user what is met and what therefore is not. Crucially, the recipient of a DoI has to carry out further work to bring the equipment into full compliance, so they need to know what that work involves. JohnC From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: 02 December 2013 15:58 To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Declaration of Conformity Perhaps discussion of DoI vs. DoC is getting tangled. A DoI is a concept only available to the MD, and because it is related to a machine that is partly complete, it must include a list of the MD Annex I essential heath and safety requirements that have been applied and fulfilled. The assumption being that some have not been fulfilled because the machine is only partly completed. In my experience, people often misunderstand the fine point details associated with partly completed machinery declarations because they are not necessarily aligned with common sense. Download the MD guide and give it a read. http://ec.europa.eu/enterprise/sectors/mechanical/files/machinery/guide-appl-2006-42-ec-2nd-201006_en.pdf Regards, Lauren Crane KLA-Tencor From: Mark Schmidt mark.schm...@dornerworks.commailto:mark.schm...@dornerworks.com To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Sent: Monday, November 25, 2013 2:14:23 PM Subject: [PSES] Declaration of Conformity Hello List, I need some help. I am very new to the Machinery Directive and my customer received a non-conformance from their customer about their DoC. It appears that my customer's distributor generated a DoI, and it appears that it needs to be a DoC and most importantly their complaint is that it should include a list of which EHSRs are met or not met. Where or how do I determine if these are met or not. Is there a good place to reference? Any help is appreciated like I said I am a newbie when it comes to the Machinery Directive. Thanks, Mark Schmidt - 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 LT;emc-p...@ieee.orgmailto:emc-p...@ieee.orgGT; 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)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas LT;emcp...@radiusnorth.netmailto:emcp...@radiusnorth.netGT; Mike Cantwell LT;mcantw...@ieee.orgmailto:mcantw...@ieee.orgGT; For policy questions, send mail to: Jim Bacher LT;j.bac...@ieee.orgmailto:j.bac...@ieee.orgGT; David Heald LT;dhe...@gmail.commailto:dhe...@gmail.comGT; - 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.orgmailto: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)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell
Re: [PSES] Declaration of Conformity
The MD requires the DoC (not DoI) or a document calling out the content of the DoC to be provided in the Instruction Manual. The purpose of this requirement is not clear to me but it says it so you have to do it. I would request additional information from the customer if you can. What exactly did they not like about the information they received. I've had customers reject a DoC only to find out after jumping through many hoops that they were wrong. The Other Brian Sent from my Windows Phone From: John Cotman Sent: 12/2/2013 1:10 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Declaration of Conformity It is a requirement of the Machinery Directive that a copy of the declaration be supplied with each machine. Whether it should be a DoI or DoC will depend on the circumstances, but either way it should be something that the manufacturer does, so I can’t see why “the customer’s distributor” has to generate the document at all? Lauren is correct – a DoC means that all applicable EHSRs have been met. As they all have, it doesn’t need to list them. A DoI means some have not, so you need to tell the user what is met and what therefore is not. Crucially, the recipient of a DoI has to carry out further work to bring the equipment into full compliance, so they need to know what that work involves. JohnC From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com] Sent: 02 December 2013 15:58 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Declaration of Conformity Perhaps discussion of DoI vs. DoC is getting tangled. A DoI is a concept only available to the MD, and because it is related to a machine that is partly complete, it must include a list of the MD Annex I essential heath and safety requirements that have been applied and fulfilled. The assumption being that some have not been fulfilled because the machine is only partly completed. In my experience, people often misunderstand the fine point details associated with partly completed machinery declarations because they are not necessarily aligned with common sense. Download the MD guide and give it a read. http://ec.europa.eu/enterprise/sectors/mechanical/files/machinery/guide-appl-2006-42-ec-2nd-201006_en.pdf Regards, Lauren Crane KLA-Tencor From: Mark Schmidt mark.schm...@dornerworks.commailto:mark.schm...@dornerworks.com To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Sent: Monday, November 25, 2013 2:14:23 PM Subject: [PSES] Declaration of Conformity Hello List, I need some help. I am very new to the Machinery Directive and my customer received a non-conformance from their customer about their DoC. It appears that my customer’s distributor generated a DoI, and it appears that it needs to be a DoC and most importantly their complaint is that it should include a list of which EHSRs are met or not met. Where or how do I determine if these are met or not. Is there a good place to reference? Any help is appreciated like I said I am a newbie when it comes to the Machinery Directive. Thanks, Mark Schmidt - 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 LT;emc-p...@ieee.orgmailto:emc-p...@ieee.orgGT; 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)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas LT;emcp...@radiusnorth.netmailto:emcp...@radiusnorth.netGT; Mike Cantwell LT;mcantw...@ieee.orgmailto:mcantw...@ieee.orgGT; For policy questions, send mail to: Jim Bacher LT;j.bac...@ieee.orgmailto:j.bac...@ieee.orgGT; David Heald LT;dhe...@gmail.commailto:dhe...@gmail.comGT; - 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.orgmailto: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)http://www.ieee-pses.org/list.html List rules: http://www.ieee-pses.org
Re: [PSES] Declaration of Conformity
Mark -- This is indeed puzzling. The EHSRs are all in Annex I of the Machinery Safety Directive (MSD). When you do a DoC, you are typically implicitly and explicitly declaring compliance with all relevant EHSRs. Annex II of the MSD has the requirements for DoC and DoI. However, if you cite a harmonized standard in your declaration as evidence of compliance with EHSRs, and you do not meet all the requirements of that harmonized standard, I've seen the expectation somewhere (others may know this better than I, but the June 2010 Guideline to the MSD is a pretty good reference) that you list the requirements of the harmonnized standard that you do not comply with. Your email does not make it clear where in the chain of commerce your company falls. This affects whether you have the responsibility to create the DoC. Mike Sherman Product Safety and Compliance Engineer Graco Inc. - Original Message - From: Mark Schmidt mark.schm...@dornerworks.com To: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Monday, November 25, 2013 2:14:23 PM Subject: [PSES] Declaration of Conformity Hello List, I need some help. I am very new to the Machinery Directive and my customer received a non-conformance from their customer about their DoC. It appears that my customer’s distributor generated a DoI, and it appears that it needs to be a DoC and most importantly their complaint is that it should include a list of which EHSRs are met or not met. Where or how do I determine if these are met or not. Is there a good place to reference? Any help is appreciated like I said I am a newbie when it comes to the Machinery Directive. Thanks, Mark Schmidt - 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 LT; emc-p...@ieee.org GT; 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 LT; emcp...@radiusnorth.net GT; Mike Cantwell LT; mcantw...@ieee.org GT; For policy questions, send mail to: Jim Bacher LT; j.bac...@ieee.org GT; David Heald LT; dhe...@gmail.com GT; - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] Declaration of Conformity
Hello List, I need some help. I am very new to the Machinery Directive and my customer received a non-conformance from their customer about their DoC. It appears that my customer's distributor generated a DoI, and it appears that it needs to be a DoC and most importantly their complaint is that it should include a list of which EHSRs are met or not met. Where or how do I determine if these are met or not. Is there a good place to reference? Any help is appreciated like I said I am a newbie when it comes to the Machinery Directive. Thanks, Mark Schmidt - 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 emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Class A or Class B on Declaration of Conformity
Thanks for the responses. However, this also brings me to a follow-up question. EN55022 in clause 4.2 states that for Class A ITE a warning shall be included in the instructions for use: Warning. This is a class A product. In a domestic environment this product may cause radio interference in which case the user may be required to take adequate measures. How binding is that requirement? Jim Hulbert From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Bill Owsley Sent: Wednesday, February 13, 2013 10:30 PM To: oconne...@tamuracorp.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Class A or Class B on Declaration of Conformity A number of commercial products that I've worked on met the Class B limits with margin. But since they were commercial products, and were not marketed to the public, marketing stayed with the Class A compliance claims to avoid any confusion for the customs, which meant a sizable margin to the A limit!. Was it more expensive to make those margins to the limits? Just a bit, a lot more care in the layout took care of it. Generally two more layers did it, along with a few layout tricks. And being expensive commercial products with lots of $$ margin to start with, no real concern. And with those margins to the limit, go ahead and make some changes, they probably won't affect the DOC. From: Brian Oconnell oconne...@tamuracorp.commailto:oconne...@tamuracorp.com To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Sent: Wednesday, February 13, 2013 5:35 PM Subject: RE: Class A or Class B on Declaration of Conformity The problem with emissions limits is their use to determine scope and applicability of other non-related directives and standards. Which is basis for some EMC reports that only indicate the equipment meets Class A limit, but the data demonstrates Class B performance. Dinosaur-like DNA found in chicken and turkey meals ? Probably why all unknown/exotic meats taste like chicken. Brian -Original Message- From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.orgmailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: Wednesday, February 13, 2013 2:17 PM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Class A or Class B on Declaration of Conformity Not on the DoC but in your EMC Assessment statement. It could hardly be a requirement on the DoC because that would have to be specified in the Directive. Not all standards have 'Class A' and 'Class B', and those that do don't all define them in the same way. -- SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals - 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.orgmailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald: dhe...@gmail.commailto: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.orgmailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto: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
Re: [PSES] Class A or Class B on Declaration of Conformity
Jim, Good question regarding statements in the standard that is not covered in the Directives. Do you really have to do them? If you are claiming compliance with a directive via compliance to a harmonized standard, may be you do. Here is what CISPR11:2010 says: 5 Classification of ISM equipment 5.1 Information for the user The manufacturer and/or supplier of ISM equipment shall ensure that the user is informed about the class and group of the equipment, either by labelling or by the accompanying documentation. In both cases the manufacturer/supplier shall explain the meaning of both the class and the group in the documentation accompanying the equipment. Now, back to the original question. I like to see the Class (and group if group 2) on the DOCs of equipment we purchase because otherwise it can be hard to find out this information. Also, to make life much easier for myself, I always include the Class (and group if group 2) on our DOCs to avoid the dozen of requests for this information from our customers or potential customers. Finally, I have to ask, why not include the class on the DOC? Unless there is some reason you want to hide the fact that your products are class A and your competitors are class B. ?? Just throwing that our there. Again, to make life easier for myself, I cram as much information on the EU DOC that I can. In the ISM world, not only do you have class A and B, but for EMC you have different environments; residential, commercial, controlled, laboratory, light industrial, heavy industrial. Just by listing the standard on the DOC does not provide much information to our customers. Enjoy Passive Aggressive Relationship Day (no, you don't have to get me anything. No really, I'm fine.) The Other Brian From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Jim Hulbert Sent: Thursday, February 14, 2013 8:49 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Class A or Class B on Declaration of Conformity Thanks for the responses. However, this also brings me to a follow-up question. EN55022 in clause 4.2 states that for Class A ITE a warning shall be included in the instructions for use: Warning. This is a class A product. In a domestic environment this product may cause radio interference in which case the user may be required to take adequate measures. How binding is that requirement? Jim Hulbert From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Bill Owsley Sent: Wednesday, February 13, 2013 10:30 PM To: oconne...@tamuracorp.commailto:oconne...@tamuracorp.com; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Class A or Class B on Declaration of Conformity A number of commercial products that I've worked on met the Class B limits with margin. But since they were commercial products, and were not marketed to the public, marketing stayed with the Class A compliance claims to avoid any confusion for the customs, which meant a sizable margin to the A limit!. Was it more expensive to make those margins to the limits? Just a bit, a lot more care in the layout took care of it. Generally two more layers did it, along with a few layout tricks. And being expensive commercial products with lots of $$ margin to start with, no real concern. And with those margins to the limit, go ahead and make some changes, they probably won't affect the DOC. From: Brian Oconnell oconne...@tamuracorp.commailto:oconne...@tamuracorp.com To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Sent: Wednesday, February 13, 2013 5:35 PM Subject: RE: Class A or Class B on Declaration of Conformity The problem with emissions limits is their use to determine scope and applicability of other non-related directives and standards. Which is basis for some EMC reports that only indicate the equipment meets Class A limit, but the data demonstrates Class B performance. Dinosaur-like DNA found in chicken and turkey meals ? Probably why all unknown/exotic meats taste like chicken. Brian -Original Message- From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.orgmailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: Wednesday, February 13, 2013 2:17 PM To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Class A or Class B on Declaration of Conformity Not on the DoC but in your EMC Assessment statement. It could hardly be a requirement on the DoC because that would have to be specified in the Directive. Not all standards have 'Class A' and 'Class B', and those that do don't all define them in the same way. -- SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals - 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.orgmailto:emc-p
Re: [PSES] Class A or Class B on Declaration of Conformity
In message 7B9D892F88F070469771832D78B3086E062AC1C4@013-BR1MPN1-012.MGDPBI.global.p vt, dated Thu, 14 Feb 2013, Jim Hulbert jim.hulb...@pb.com writes: Thanks for the responses. However, this also brings me to a follow-up question. EN55022 in clause 4.2 states that for Class A ITE a warning shall be included in the instructions for use: ?Warning. This is a class A product. In a domestic environment this product may cause radio interference in which case the user may be required to take adequate measures?. How binding is that requirement? Totally, unless you can get a Notified Body to endorse your omission. Without it, you are not complying with the standard. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Class A or Class B on Declaration of Conformity
A DoC is for compliance with a Directive, not with a standard Your compliance with a Directive may be (almost certainly is) *supported* by a Harmonised Standard, but that's only part of the overall compliance. That said, if you have applied a standard in compiling your technical documentation then you should follow it administrative requirements as well as its test requirements. The statement should go in the user manual and/or on the product depending on the standard, but I don't see why you would want/need to put it on the DoC. If you work in a market segment where this information is important to your customers, I would think that the datasheet / marketing bumpf would be the place to make it more visible. regards Charlie From: Kunde, Brian [brian_ku...@lecotc.com] Sent: 14 February 2013 14:20 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Class A or Class B on Declaration of Conformity Jim, Good question regarding statements in the standard that is not covered in the Directives. Do you really have to do them? If you are claiming compliance with a directive via compliance to a harmonized standard, may be you do. Here is what CISPR11:2010 says: 5 Classification of ISM equipment 5.1 Information for the user The manufacturer and/or supplier of ISM equipment shall ensure that the user is informed about the class and group of the equipment, either by labelling or by the accompanying documentation. In both cases the manufacturer/supplier shall explain the meaning of both the class and the group in the documentation accompanying the equipment. Now, back to the original question. I like to see the Class (and group if group 2) on the DOCs of equipment we purchase because otherwise it can be hard to find out this information. Also, to make life much easier for myself, I always include the Class (and group if group 2) on our DOCs to avoid the dozen of requests for this information from our customers or potential customers. Finally, I have to ask, why not include the class on the DOC? Unless there is some reason you want to hide the fact that your products are class A and your competitors are class B. ?? Just throwing that our there. Again, to make life easier for myself, I cram as much information on the EU DOC that I can. In the ISM world, not only do you have class A and B, but for EMC you have different environments; residential, commercial, controlled, laboratory, light industrial, heavy industrial. Just by listing the standard on the DOC does not provide much information to our customers. Enjoy Passive Aggressive Relationship Day (no, you don’t have to get me anything. No really, I’m fine.) The Other Brian From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Jim Hulbert Sent: Thursday, February 14, 2013 8:49 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Class A or Class B on Declaration of Conformity Thanks for the responses. However, this also brings me to a follow-up question. EN55022 in clause 4.2 states that for Class A ITE a warning shall be included in the instructions for use: “Warning. This is a class A product. In a domestic environment this product may cause radio interference in which case the user may be required to take adequate measures”. How binding is that requirement? Jim Hulbert From: emc-p...@ieee.orgmailto:emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Bill Owsley Sent: Wednesday, February 13, 2013 10:30 PM To: oconne...@tamuracorp.commailto:oconne...@tamuracorp.com; EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Class A or Class B on Declaration of Conformity A number of commercial products that I've worked on met the Class B limits with margin. But since they were commercial products, and were not marketed to the public, marketing stayed with the Class A compliance claims to avoid any confusion for the customs, which meant a sizable margin to the A limit!. Was it more expensive to make those margins to the limits? Just a bit, a lot more care in the layout took care of it. Generally two more layers did it, along with a few layout tricks. And being expensive commercial products with lots of $$ margin to start with, no real concern. And with those margins to the limit, go ahead and make some changes, they probably won't affect the DOC. From: Brian Oconnell oconne...@tamuracorp.commailto:oconne...@tamuracorp.com To: EMC-PSTC@LISTSERV.IEEE.ORGmailto:EMC-PSTC@LISTSERV.IEEE.ORG Sent: Wednesday, February 13, 2013 5:35 PM Subject: RE: Class A or Class B on Declaration of Conformity The problem with emissions limits is their use to determine scope and applicability of other non-related directives and standards. Which is basis for some EMC reports that only indicate the equipment meets Class A limit, but the data demonstrates Class B performance. Dinosaur-like DNA found in chicken and turkey meals
Re: [PSES] Class A or Class B on Declaration of Conformity
Hi Jim, As stated in the standard the text shall be included in the instructions if the device is class A equipment, you cannot omit the text. I believe the same applies for USA. Best regards Helge Knudsen Denmark From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Jim Hulbert Sent: 14. februar 2013 14:49 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Class A or Class B on Declaration of Conformity Thanks for the responses. However, this also brings me to a follow-up question. EN55022 in clause 4.2 states that for Class A ITE a warning shall be included in the instructions for use: Warning. This is a class A product. In a domestic environment this product may cause radio interference in which case the user may be required to take adequate measures. How binding is that requirement? Jim Hulbert From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Bill Owsley Sent: Wednesday, February 13, 2013 10:30 PM To: oconne...@tamuracorp.com; EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Class A or Class B on Declaration of Conformity A number of commercial products that I've worked on met the Class B limits with margin. But since they were commercial products, and were not marketed to the public, marketing stayed with the Class A compliance claims to avoid any confusion for the customs, which meant a sizable margin to the A limit!. Was it more expensive to make those margins to the limits? Just a bit, a lot more care in the layout took care of it. Generally two more layers did it, along with a few layout tricks. And being expensive commercial products with lots of $$ margin to start with, no real concern. And with those margins to the limit, go ahead and make some changes, they probably won't affect the DOC. _ From: Brian Oconnell oconne...@tamuracorp.com To: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Wednesday, February 13, 2013 5:35 PM Subject: RE: Class A or Class B on Declaration of Conformity The problem with emissions limits is their use to determine scope and applicability of other non-related directives and standards. Which is basis for some EMC reports that only indicate the equipment meets Class A limit, but the data demonstrates Class B performance. Dinosaur-like DNA found in chicken and turkey meals ? Probably why all unknown/exotic meats taste like chicken. Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: Wednesday, February 13, 2013 2:17 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Class A or Class B on Declaration of Conformity Not on the DoC but in your EMC Assessment statement. It could hardly be a requirement on the DoC because that would have to be specified in the Directive. Not all standards have 'Class A' and 'Class B', and those that do don't all define them in the same way. -- SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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
Re: [PSES] Class A or Class B on Declaration of Conformity
Thank you again. And to others who have commented. So my conclusions: If EN 55022 is the appropriate standard to apply to your product, Class A or Class B can be included with the standard reference on the DoC, but it's not mandatory to include it. However, if the product assessment (most likely a test report) shows the product complies with Class A limits but not the Class B limits, the warning statement shown in the standard must be included with the user instructions. To the Other Brian - A dozen roses, right?. Jim -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Thursday, February 14, 2013 9:24 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Class A or Class B on Declaration of Conformity In message 7B9D892F88F070469771832D78B3086E062AC1C4@013-BR1MPN1-012.MGDPBI.global.p vt, dated Thu, 14 Feb 2013, Jim Hulbert jim.hulb...@pb.com writes: Thanks for the responses. However, this also brings me to a follow-up question. EN55022 in clause 4.2 states that for Class A ITE a warning shall be included in the instructions for use: ?Warning. This is a class A product. In a domestic environment this product may cause radio interference in which case the user may be required to take adequate measures?. How binding is that requirement? Totally, unless you can get a Notified Body to endorse your omission. Without it, you are not complying with the standard. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Class A or Class B on Declaration of Conformity
In message 7B9D892F88F070469771832D78B3086E062AF24B@013-BR1MPN1-012.MGDPBI.global.p vt, dated Thu, 14 Feb 2013, Jim Hulbert jim.hulb...@pb.com writes: However, if the product assessment (most likely a test report) shows the product complies with Class A limits but not the Class B limits, the warning statement shown in the standard must be included with the user instructions. Unless you are testing in production to the Class B limits, you must include the warning, because some samples will not meet Class B. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Class A or Class B on Declaration of Conformity
2004/108/EC Art. 8.4 does state that the intended environment (when NOT residential) needs to be marked on label/documentation and packing as far as possible. As 55022 in Class A is defined as NOT being Class B, all Class A equipment need to be marked as not suitable for consumer/residential use. Gert Gremmen -Oorspronkelijk bericht- Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate Verzonden: donderdag 14 februari 2013 16:23 Aan: EMC-PSTC@LISTSERV.IEEE.ORG Onderwerp: Re: Class A or Class B on Declaration of Conformity In message 7B9D892F88F070469771832D78B3086E062AF24B@013-BR1MPN1-012.MGDPBI.global. p vt, dated Thu, 14 Feb 2013, Jim Hulbert jim.hulb...@pb.com writes: However, if the product assessment (most likely a test report) shows the product complies with Class A limits but not the Class B limits, the warning statement shown in the standard must be included with the user instructions. Unless you are testing in production to the Class B limits, you must include the warning, because some samples will not meet Class B. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] Class A or Class B on Declaration of Conformity
On CE Declarations of Conformity, where EN 55022 standard has been referenced, is it a requirement that the limit that was applied (class A or class B) also be stated? We show the limit on our DoCs, but some of our OEMs do not. I can't find where it is actually required. Jim Hulbert - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Class A or Class B on Declaration of Conformity
In message 7B9D892F88F070469771832D78B3086E062A6FEA@013-BR1MPN1-012.MGDPBI.global.p vt, dated Wed, 13 Feb 2013, Jim Hulbert jim.hulb...@pb.com writes: On CE Declarations of Conformity, where EN 55022 standard has been referenced, is it a requirement that the limit that was applied (class A or class B) also be stated? We show the limit on our DoCs, but some of our OEMs do not. I can?t find where it is actually required. Not on the DoC but in your EMC Assessment statement. It could hardly be a requirement on the DoC because that would have to be specified in the Directive. Not all standards have 'Class A' and 'Class B', and those that do don't all define them in the same way. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Class A or Class B on Declaration of Conformity
The problem with emissions limits is their use to determine scope and applicability of other non-related directives and standards. Which is basis for some EMC reports that only indicate the equipment meets Class A limit, but the data demonstrates Class B performance. Dinosaur-like DNA found in chicken and turkey meals ? Probably why all unknown/exotic meats taste like chicken. Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: Wednesday, February 13, 2013 2:17 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Class A or Class B on Declaration of Conformity Not on the DoC but in your EMC Assessment statement. It could hardly be a requirement on the DoC because that would have to be specified in the Directive. Not all standards have 'Class A' and 'Class B', and those that do don't all define them in the same way. -- SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Class A or Class B on Declaration of Conformity
The directive requires a dated reference to the specifications under which conformity is declared to ensure the conformity of the apparatus with the provisions of this Directive The EMC guidance document says In most cases, the dated references to the specifications under which conformity is declared, will be those of the European harmonised standards that are applicable to the apparatus in question as listed in the OJEU. If European harmonised standards have not been used or only partially, a reference to the manufacturer's technical documentation needs to be included and a reference to any identifiable non-harmonised standards or specifications that have been applied. There is no hint that you must include the granularity of A or B, just the gross, dated reference of the specification used (EN 12345-2:2010). Regards, Lauren Crane KLA-Tencor From: Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: Wednesday, February 13, 2013 4:02 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Class A or Class B on Declaration of Conformity On CE Declarations of Conformity, where EN 55022 standard has been referenced, is it a requirement that the limit that was applied (class A or class B) also be stated? We show the limit on our DoCs, but some of our OEMs do not. I can't find where it is actually required. Jim Hulbert - 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.orgmailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.netmailto:emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.orgmailto:mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.orgmailto:j.bac...@ieee.org David Heald dhe...@gmail.commailto: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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Class A or Class B on Declaration of Conformity
I seem to recall, being at home and not able to access the doc's, that a notice of Class A restrictions from being installed in residential areas (Class B) needs to be on the outside of box for the consumer to find before buying. Finding that fact after purchase by reading the inside documents is so annoying! From: Crane, Lauren lauren.cr...@kla-tencor.com To: Jim Hulbert jim.hulb...@pb.com; EMC-PSTC@LISTSERV.IEEE.ORG EMC-PSTC@LISTSERV.IEEE.ORG Sent: Wednesday, February 13, 2013 5:44 PM Subject: RE: Class A or Class B on Declaration of Conformity The directive requires “a dated reference to the specifications under which conformity is declared to ensure the conformity of the apparatus with the provisions of this Directive” The EMC guidance document says “In most cases, the dated references to the specifications under which conformity is declared, will be those of the European harmonised standards that are applicable to the apparatus in question as listed in the OJEU. If European harmonised standards have not been used or only partially, a reference to the manufacturer’s technical documentation needs to be included and a reference to any identifiable non-harmonised standards or specifications that have been applied.” There is no hint that you must include the granularity of A or B, just the gross, dated reference of the specification used (EN 12345-2:2010). Regards, Lauren Crane KLA-Tencor From:Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: Wednesday, February 13, 2013 4:02 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Class A or Class B on Declaration of Conformity On CE Declarations of Conformity, where EN 55022 standard has been referenced, is it a requirement that the limit that was applied (class A or class B) also be stated? We show the limit on our DoCs, but some of our OEMs do not. I can’t find where it is actually required. Jim Hulbert - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Class A or Class B on Declaration of Conformity
A number of commercial products that I've worked on met the Class B limits with margin. But since they were commercial products, and were not marketed to the public, marketing stayed with the Class A compliance claims to avoid any confusion for the customs, which meant a sizable margin to the A limit!. Was it more expensive to make those margins to the limits? Just a bit, a lot more care in the layout took care of it. Generally two more layers did it, along with a few layout tricks. And being expensive commercial products with lots of $$ margin to start with, no real concern. And with those margins to the limit, go ahead and make some changes, they probably won't affect the DOC. From: Brian Oconnell oconne...@tamuracorp.com To: EMC-PSTC@LISTSERV.IEEE.ORG Sent: Wednesday, February 13, 2013 5:35 PM Subject: RE: Class A or Class B on Declaration of Conformity The problem with emissions limits is their use to determine scope and applicability of other non-related directives and standards. Which is basis for some EMC reports that only indicate the equipment meets Class A limit, but the data demonstrates Class B performance. Dinosaur-like DNA found in chicken and turkey meals ? Probably why all unknown/exotic meats taste like chicken. Brian -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of John Woodgate Sent: Wednesday, February 13, 2013 2:17 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: Class A or Class B on Declaration of Conformity Not on the DoC but in your EMC Assessment statement. It could hardly be a requirement on the DoC because that would have to be specified in the Directive. Not all standards have 'Class A' and 'Class B', and those that do don't all define them in the same way. -- SHOCK HORROR! Dinosaur-like DNA found in chicken and turkey meals - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EC Declaration of Conformity with standards and Amendments
Dear Readers, Indeed the AC is a corrigendum. The same question I asked in another newsgroup and the opposite opinion was given. So its unclear and I decided to contact the CEN - European Committee for Standardization. They replied with this answer: The AC stands for Amending Corrigendum. Starting January 2011, CENELEC corrigenda shall be cited in the Official Journal - considering there was no separate document for these CENELEC corrigenda in the past, it was proposed to indicate them where any, but these shall be found in the amendment of the document itself. No consolidated version will be issued for including a corrigendum. Therefore, two documents will exist separately. In the light of this, you might declare this AC:2011 also on your EC DoC declaration of conformity. But please do check this also with your National Electrotechnical Committee in the Netherlands, the National Electrotechnical Committee. So we will declare the AC: on our EC DoC's Best regards Jan Mobers -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Knighten, Jim L Sent: vrijdag 8 februari 2013 19:37 To: John Woodgate; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC Declaration of Conformity with standards and Amendments Good answer! __ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 - phone 858-485-3788 - fax (unattended) -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Friday, February 08, 2013 4:58 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC Declaration of Conformity with standards and Amendments In message bf5f91292ee1b546aa6b6234356ef8953b1b0f8...@si-mbx02.de.bosch.com, dated Fri, 8 Feb 2013, Mobers Jan (ST-VS/EAP1.4-NL) jan.mob...@nl.bosch.com writes: A question came up for the EC DoC. The applicable standards with version / year need to be mentioned. But what about the some times applicable amendments of the standards so called AC:x. Acs are not amendments, which are designated An (e.g. A2), for 'native' CENELEC standards or amendments prepared by IEC, or Ann (e.g. A13), for amendments by CENELEC of IEC standards. ACs do not have to be quoted in DoCs. They are corrigenda. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk Analogue is the limiting case of digital, with infinite sampling rate and number of bits. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] Recall: [PSES] EC Declaration of Conformity with standards and Amendments
Mobers Jan (ST-VS/EAP1.4-NL) would like to recall the message, [PSES] EC Declaration of Conformity with standards and Amendments. - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EC Declaration of Conformity with standards and Amendments
Dear Readers, Indeed the AC is a corrigendum. The same question was ask in other newsgroups and several opinions. Based on that I contacted the EU Best regards Jan Mobers -Original Message- From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Knighten, Jim L Sent: vrijdag 8 februari 2013 19:37 To: John Woodgate; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] EC Declaration of Conformity with standards and Amendments Good answer! __ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 - phone 858-485-3788 - fax (unattended) -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Friday, February 08, 2013 4:58 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC Declaration of Conformity with standards and Amendments In message bf5f91292ee1b546aa6b6234356ef8953b1b0f8...@si-mbx02.de.bosch.com, dated Fri, 8 Feb 2013, Mobers Jan (ST-VS/EAP1.4-NL) jan.mob...@nl.bosch.com writes: A question came up for the EC DoC. The applicable standards with version / year need to be mentioned. But what about the some times applicable amendments of the standards so called AC:x. Acs are not amendments, which are designated An (e.g. A2), for 'native' CENELEC standards or amendments prepared by IEC, or Ann (e.g. A13), for amendments by CENELEC of IEC standards. ACs do not have to be quoted in DoCs. They are corrigenda. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk Analogue is the limiting case of digital, with infinite sampling rate and number of bits. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
[PSES] EC Declaration of Conformity with standards and Amendments
Dear newsgroups readers A question came up for the EC DoC. The applicable standards with version / year need to be mentioned. But what about the some times applicable amendments of the standards so called AC:x. For instance the EMC: EN 55022:2010 EN 55022:2010/AC:2011 Does the AC:2011 also be mentioned on the EC DoC? Thanks inadvance Jan Mobers - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EC Declaration of Conformity with standards and Amendments
In message bf5f91292ee1b546aa6b6234356ef8953b1b0f8...@si-mbx02.de.bosch.com, dated Fri, 8 Feb 2013, Mobers Jan (ST-VS/EAP1.4-NL) jan.mob...@nl.bosch.com writes: A question came up for the EC DoC. The applicable standards with version / year need to be mentioned. But what about the some times applicable amendments of the standards so called AC:x. Acs are not amendments, which are designated An (e.g. A2), for 'native' CENELEC standards or amendments prepared by IEC, or Ann (e.g. A13), for amendments by CENELEC of IEC standards. ACs do not have to be quoted in DoCs. They are corrigenda. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk Analogue is the limiting case of digital, with infinite sampling rate and number of bits. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] EC Declaration of Conformity with standards and Amendments
Good answer! __ James L. Knighten, Ph.D. EMC Engineer Teradata Corporation 17095 Via Del Campo San Diego, CA 92127 858-485-2537 - phone 858-485-3788 - fax (unattended) -Original Message- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Friday, February 08, 2013 4:58 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] EC Declaration of Conformity with standards and Amendments In message bf5f91292ee1b546aa6b6234356ef8953b1b0f8...@si-mbx02.de.bosch.com, dated Fri, 8 Feb 2013, Mobers Jan (ST-VS/EAP1.4-NL) jan.mob...@nl.bosch.com writes: A question came up for the EC DoC. The applicable standards with version / year need to be mentioned. But what about the some times applicable amendments of the standards so called AC:x. Acs are not amendments, which are designated An (e.g. A2), for 'native' CENELEC standards or amendments prepared by IEC, or Ann (e.g. A13), for amendments by CENELEC of IEC standards. ACs do not have to be quoted in DoCs. They are corrigenda. -- OOO - Own Opinions Only. See www.jmwa.demon.co.uk Analogue is the limiting case of digital, with infinite sampling rate and number of bits. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: [PSES] Need for a EU Signature on a Declaration of Conformity??
To all who replied to my question regarding the need for an EU based signatory to the Declaration of Conformity, Thank You. You confirmed what I already knew. Much appreciated! -- Doug Nix Office: (519) 650-4753 Mobile (519) 729-5704 Skype: cic-inc d...@complianceinsight.ca From: Doug Nix [mailto:d...@mac.com] Sent: Tuesday, December 21, 2010 7:45 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Need for a EU Signature on a Declaration of Conformity?? Colleagues, I have recently heard from a client in the UK, that a Declaration of Conformity is not valid without a signature from an EU entity. I cannot find any legal basis that supports this. Can anyone enlighten me on this? -- Doug Nix Office: (519) 650-4753 Mobile (519) 729-5704 Skype: cic-inc d...@complianceinsight.ca - 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://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
RE: Need for a EU Signature on a Declaration of Conformity??
Quite correct – but, nevertheless, the person/company responsible for importing the item into the EU then takes legal responsibility for ensuring that it does comply with the relevant Directives, and he/she/it will be the prime target of the authorities if it is later found not to do so – and then potentially bear the same penalties as the actual DoC signatory would have done if the authorities had been able to pursue them directly. There may be extenuating circumstances for individuals/small companies which do the importing - on the basis they probably did not have all the knowledge/resources to ensure full compliance and that it was “reasonable” to accept the evidence provided to them by the actual signatory. Such extenuating circumstances would, however, probably not be allowed for companies that did (or at least should!) have had sufficient knowledge/resources to ensure compliance but did not do so. All these offences would be criminal, rather than civil, offences, but it should also be borne in mind that – as well as the criminal penalties - serious non-compliances could place severe financial and public-relations/market-share burdens on the importers if they have to withdraw/recall deficient items or pay damages to injured parties. The latter could well dwarf the actual criminal penalties! L John Allen London, UK From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Ted Eckert Sent: 21 December 2010 17:41 To: Doug Nix; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: Need for a EU Signature on a Declaration of Conformity?? Hi Doug, I believe your client is in error. The Blue Guide http://ec.europa.eu/enterprise/policie /single-market-goods/files/blue-guide/guidepublic_en.pdf only indicates that a person residing the EU is required to sign a DoC if required by a specific CE marking directive. The relevant information starts on page 34 of the Blue Guide http://ec.europa.eu/enterprise/p licies/single-market-goods/files/blue-guide/guidepublic_en.pdf . Note 103 on page 35 states “It is not necessary for the signatory to be domiciled in the Community. A manufacturer established outside the Community is entitled to carry out all the certification procedures at his premises and, therefore, to sign the declaration of conformity, unless otherwise provided for in the directive(s).” The EMC, LVD and RTTE Directives do not require somebody domiciled within the EC to sign the DoC. The new Machinery Directive is slightly different. Annex II section A bullet 2 requires that the DoC include the “name and address of the person authorized to compile the technical file, who must be established in the Community”. However, bullet 10, which stipulates the signatory, does not require that signatory to reside within the EU. Regards, Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. From: Doug Nix [mailto:d...@mac.com] Sent: Tuesday, December 21, 2010 7:45 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Need for a EU Signature on a Declaration of Conformity?? Colleagues, I have recently heard from a client in the UK, that a Declaration of Conformity is not valid without a signature from an EU entity. I cannot find any legal basis that supports this. Can anyone enlighten me on this? -- Doug Nix Office: (519) 650-4753 Mobile (519) 729-5704 Skype: cic-inc d...@complianceinsight.ca - 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://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send
RE: Need for a EU Signature on a Declaration of Conformity??
Hi Doug, I believe your client is in error. The Blue Guide http://ec.europa.eu/enterprise/policie /single-market-goods/files/blue-guide/guidepublic_en.pdf only indicates that a person residing the EU is required to sign a DoC if required by a specific CE marking directive. The relevant information starts on page 34 of the Blue Guide http://ec.europa.eu/enterprise/p licies/single-market-goods/files/blue-guide/guidepublic_en.pdf . Note 103 on page 35 states “It is not necessary for the signatory to be domiciled in the Community. A manufacturer established outside the Community is entitled to carry out all the certification procedures at his premises and, therefore, to sign the declaration of conformity, unless otherwise provided for in the directive(s).” The EMC, LVD and RTTE Directives do not require somebody domiciled within the EC to sign the DoC. The new Machinery Directive is slightly different. Annex II section A bullet 2 requires that the DoC include the “name and address of the person authorized to compile the technical file, who must be established in the Community”. However, bullet 10, which stipulates the signatory, does not require that signatory to reside within the EU. Regards, Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com mailto:ted.eck...@microsoft.com The opinions expressed are my own and do not necessarily reflect those of my employer. From: Doug Nix [mailto:d...@mac.com] Sent: Tuesday, December 21, 2010 7:45 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Need for a EU Signature on a Declaration of Conformity?? Colleagues, I have recently heard from a client in the UK, that a Declaration of Conformity is not valid without a signature from an EU entity. I cannot find any legal basis that supports this. Can anyone enlighten me on this? -- Doug Nix Office: (519) 650-4753 Mobile (519) 729-5704 Skype: cic-inc d...@complianceinsight.ca - 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://product-compliance.oc.ieee.org/ http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net 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://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
Need for a EU Signature on a Declaration of Conformity??
Colleagues, I have recently heard from a client in the UK, that a Declaration of Conformity is not valid without a signature from an EU entity. I cannot find any legal basis that supports this. Can anyone enlighten me on this? -- Doug Nix Office: (519) 650-4753 Mobile (519) 729-5704 Skype: cic-inc d...@complianceinsight.ca - 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://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@radiusnorth.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
Re: EU Declaration of Conformity
In message off2293029.8c0c56e2-on86257774.0066ac0d-86257774.0066e...@amat.com, dated Tue, 3 Aug 2010, lauren_cr...@amat.com writes: Jumping in not having researched the full thread... be sure to see also the new framework directive/regulation on CE Marking that strives to provide legal certainly regarding these various economic actors (manufacturer's, distributors, importers, etc...) Ref Regulation 765/2008, regulation 764/2008 and Council Decision 768/2008/EC ... taking into account that such 'clarifications' often, through the use of complex, imprecise and stilted language, replace uncertainty by total confusion. (;-) -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK If at first you don't succeed, delegate. But I support unbloated email http://www.asciiribbon.org/ - 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.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
Re: EU Declaration of Conformity
Jumping in not having researched the full thread... be sure to see also the new framework directive/regulation on CE Marking that strives to provide legal certainly regarding these various economic actors (manufacturer's, distributors, importers, etc...) Ref Regulation 765/2008, regulation 764/2008 and Council Decision 768/2008/EC Regards, Lauren Crane Applied Materials america - europe - asia Corporate Product EHS www.amat.com lauren crane (mr.) product regulatory analyst (t) +1.512.272.6540 lauren_cr...@amat.com - external use - Save paper and trees! Please consider the environment before printing this e-mail. John Woodgate j...@jmwa.demon.co.uk Sent by: emc-p...@ieee.org 08/03/2010 01:04 PM To EMC-PSTC@LISTSERV.IEEE.ORG cc Subject Re: EU Declaration of Conformity In message AANLkTimvdGX9cMCRa3-4bkQVNzJGC6+n=gbls7fzc...@mail.gmail.com, dated Tue, 3 Aug 2010, Carl Newton emcl...@gmail.com writes: I believe that this last statement, above, may apply to company B that is private-labeling a product manufactured by company A and placing it on the EU market. In this case, Company B assumes the role of the manufacturer and is responsible for it's own DoC. Although it did not do the design, and does not actually manufacture the product, Company B must accept the responsibilities of the manufacturer as defined in the Blue Guide. That is correct, and in that case Company B would be well-advised to carry out sample testing on the incoming product and set up a cast-iron contract with the supplier so as to extract reparations if non-conforming product is shipped. But it does not apply to the case cited by the enquirer, which was about a product manufactured outside the EU and distributed partly by a company within the EU and partly through other channels. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK If at first you don't succeed, delegate. But I support unbloated email http://www.asciiribbon.org/ - 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.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com 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.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher j.bac...@ieee.org David Heald dhe...@gmail.com
Re: EU Declaration of Conformity
In message AANLkTimvdGX9cMCRa3-4bkQVNzJGC6+n=gbls7fzc...@mail.gmail.com, dated Tue, 3 Aug 2010, Carl Newton emcl...@gmail.com writes: I believe that this last statement, above, may apply to company B that is private-labeling a product manufactured by company A and placing it on the EU market. In this case, Company B assumes the role of the manufacturer and is responsible for it's own DoC. Although it did not do the design, and does not actually manufacture the product, Company B must accept the responsibilities of the manufacturer as defined in the Blue Guide. That is correct, and in that case Company B would be well-advised to carry out sample testing on the incoming product and set up a cast-iron contract with the supplier so as to extract reparations if non-conforming product is shipped. But it does not apply to the case cited by the enquirer, which was about a product manufactured outside the EU and distributed partly by a company within the EU and partly through other channels. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK If at first you don't succeed, delegate. But I support unbloated email http://www.asciiribbon.org/ - 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.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@socal.rr.com Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: dhe...@gmail.com
RE: Declaration of Conformity Question
Richard and all, I encourage my customers to include the wording of the DoC in the manual is a way that it will be translated when the manual is translated into the needed languages of use. One implementation of this is to print the DoC info in the manual (not a photocopy of the DoC). The signature is not usually included in this format; the original DoC has that (but it could also be photocopied into the manual). This resolves the issue in a way that provides the needed information for each market when the product is introduced into that market. The original DoC is done in English (one of the languages of the EU). :) br, Pete Peter E Perkins, PE Principal Product Safety Engineer PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 fone/fax p.perk...@ieee.org __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: Declaration of Conformity Question
Richard, Sec. 5.4 of of the EN Blue Guide reads: The EC declaration of conformity must be drawn up in one of the official languages of the Community. If the Community directives contain no further provisions concerning the language of the declaration, the requirements of the Member States to use a specific language must be assessed according to Articles 28 and 30 of the EC Treaty on a case by case basis. However, for products, which are required to be accompanied by the declaration of conformity, it has to be in the official language of the country of use. In these situations a translation should be provided by the manufacturer, the authorised representative or the distributor. Additionally, a copy of the declaration in the original language should be supplied.. Hope this helps. John Richard Pittenger Richard.Pittenger@HOBATo: emc-p...@ieee.org RTCORP.COMcc: Sent by: Subject: Declaration of Conformity Question emc-p...@ieee.org 05/10/2007 09:14 AM Dear Approvals Experts: This question has probably been asked before, but here goes again: Is it required, or advisable, to use multi-lingual Declaration of Confomities, such that all of the information on the Declaration is provided in all of the languages where the product will be marketed? Thanks in advance for your advice on this matter. Regards, Richard I. Pittenger Agency Approval Engineer Food Retail Div. Hobart Troy, Ohio 45374 Ph: 937-332-2621 Fax: 937-332-3204 http://www.hobartcorp.com - --- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This email has been scanned for SPAM content and Viruses by the MessageL abs Email Security System. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __
RE: Declaration of Conformity to new EMC Directive
John, John, and everyone I was intending to comment on a reference to the technical documentation, although I see that it wasn't clear from my reply. The annex of the Directive makes reference to the specifications but not the technical documentation. The Guide makes reference to both. Sorry for the confusion. Best wishes Brian From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of jharring...@f2labs.com Sent: 23 April 2007 14:26 To: j...@jmwa.demon.co.uk; emc-p...@ieee.org Subject: RE: Declaration of Conformity to new EMC Directive John, Brian Annex IV, section 2 EC declaration of conformity, of the new directive includes - a dated reference to the specifications under which conformity is declared to ensure the conformity of the apparatus with the provisions of this Directive. At the risk of sounding like a pedant, there is no mention of harmonised in the above requirement. That seems to suggest that including a dated reference to any and all specifications used is a legislative requirement. Best regards John From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Monday, April 23, 2007 7:17 AM To: emc-p...@ieee.org Subject: Re: Declaration of Conformity to new EMC Directive In message 200704231033.l3naxwhp009...@hormel7.ieee.org, dated Mon, 23 Apr 2007, Brian Jones e...@brianjones.co.uk writes: My text that you quote below is from the Guide. I know that this is not legislation, but the Guide will be read by enforcement authorities as well as manufacturers, so enforcement authorities may be expecting this information on the DoC. I don't disagree, but I think people can use their own judgement. If there are only a few references, then they could be on the DoC. If, however, there are many, the DoC could even look designed to confuse and obscure! In that case, I think it would be perfectly reasonable to state, 'The non-harmonised standards or specifications that have been applied are listed in the above-mentioned technical documentation.' -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk There are benefits from being irrational - just ask the square root of 2. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __
Re: Declaration of Conformity to new EMC Directive
In message C16858ED90BCC74686D26F1CFBFC00EA5EB502@exchange, dated Mon, 23 Apr 2007, jharring...@f2labs.com writes: Annex IV, section 2 EC declaration of conformity, of the new directive includes - a dated reference to the specifications under which conformity is declared to ensure the conformity of the apparatus with the provisions of this Directive. At the risk of sounding like a pedant, there is no mention of harmonised in the above requirement. That seems to suggest that including a dated reference to any and all specifications used is a legislative requirement. But it assumes that there ARE such 'specifications' (whatever they are!), whereas there may not be; the manufacturer can produce the necessary technical documentation without references to any other documents. It would thus be difficult to make the requirement 'stick' in a legal context. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk There are benefits from being irrational - just ask the square root of 2. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __
RE: Declaration of Conformity to new EMC Directive
John, Brian Annex IV, section 2 EC declaration of conformity, of the new directive includes - a dated reference to the specifications under which conformity is declared to ensure the conformity of the apparatus with the provisions of this Directive. At the risk of sounding like a pedant, there is no mention of harmonised in the above requirement. That seems to suggest that including a dated reference to any and all specifications used is a legislative requirement. Best regards John From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: Monday, April 23, 2007 7:17 AM To: emc-p...@ieee.org Subject: Re: Declaration of Conformity to new EMC Directive In message 200704231033.l3naxwhp009...@hormel7.ieee.org, dated Mon, 23 Apr 2007, Brian Jones e...@brianjones.co.uk writes: My text that you quote below is from the Guide. I know that this is not legislation, but the Guide will be read by enforcement authorities as well as manufacturers, so enforcement authorities may be expecting this information on the DoC. I don't disagree, but I think people can use their own judgement. If there are only a few references, then they could be on the DoC. If, however, there are many, the DoC could even look designed to confuse and obscure! In that case, I think it would be perfectly reasonable to state, 'The non-harmonised standards or specifications that have been applied are listed in the above-mentioned technical documentation.' -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk There are benefits from being irrational - just ask the square root of 2. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __
Re: Declaration of Conformity to new EMC Directive
In message 200704231033.l3naxwhp009...@hormel7.ieee.org, dated Mon, 23 Apr 2007, Brian Jones e...@brianjones.co.uk writes: My text that you quote below is from the Guide. I know that this is not legislation, but the Guide will be read by enforcement authorities as well as manufacturers, so enforcement authorities may be expecting this information on the DoC. I don't disagree, but I think people can use their own judgement. If there are only a few references, then they could be on the DoC. If, however, there are many, the DoC could even look designed to confuse and obscure! In that case, I think it would be perfectly reasonable to state, 'The non-harmonised standards or specifications that have been applied are listed in the above-mentioned technical documentation.' -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk There are benefits from being irrational - just ask the square root of 2. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __
RE: Declaration of Conformity to new EMC Directive
John My text that you quote below is from the Guide. I know that this is not legislation, but the Guide will be read by enforcement authorities as well as manufacturers, so enforcement authorities may be expecting this information on the DoC. I therefore think it is wise to include it. It may reduce the chances of having to produce the full technical documentation for inspection. If referenced specifications are changed during the life of the product, I think it is a good idea to update the DoC anyway, as has to be done for harmonised standards past the date of cessation of presumption of conformity. Best wishes Brian Brian Jones EMC Consultant From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of John Woodgate Sent: 23 April 2007 08:57 To: emc-p...@ieee.org Subject: Re: Declaration of Conformity to new EMC Directive In message 200704230740.l3n7e5vl020...@hormel7.ieee.org, dated Mon, 23 Apr 2007, Brian Jones e...@brianjones.co.uk writes: If European harmonised standards have not been used or only partially, a reference to the manufacturer's technical documentation needs to be included and a reference to any identifiable non-harmonised standards or specifications that have been applied. ..which is very close to what I wrote. But if the 'identifiable non-harmonised standards or specifications that have been applied' are referenced in the technical documentation, as they surely must be if it is to be satisfactory, I don't see any need to reference them directly from the DoC, especially since they might change during the life of the product. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk There are benefits from being irrational - just ask the square root of 2. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __
Re: Declaration of Conformity to new EMC Directive
In message 200704230740.l3n7e5vl020...@hormel7.ieee.org, dated Mon, 23 Apr 2007, Brian Jones e...@brianjones.co.uk writes: If European harmonised standards have not been used or only partially, a reference to the manufacturer’s technical documentation needs to be included and a reference to any identifiable non-harmonised standards or specifications that have been applied. ..which is very close to what I wrote. But if the 'identifiable non-harmonised standards or specifications that have been applied' are referenced in the technical documentation, as they surely must be if it is to be satisfactory, I don't see any need to reference them directly from the DoC, especially since they might change during the life of the product. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk There are benefits from being irrational - just ask the square root of 2. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __
RE: Declaration of Conformity to new EMC Directive
John, and everyone Annex IV of 2004/108/EC sets out *minimum* requirements for the content of the DoC. Additional information can be added, although in my view it should not make the required content unclear. The EC Guide http://ec.europa.eu/enterprise/electr_equipment/emc/guides/emc_guide_2007.p df in 3.3.2 on page 34 contains the following guidance: In most cases, the dated references to the specifications under which conformity is declared, will be those of the European harmonised standards that are applicable to the apparatus in question as listed in the OJEU. If European harmonised standards have not been used or only partially, a reference to the manufacturer’s technical documentation needs to be included and a reference to any identifiable non-harmonised standards or specifications that have been applied. The layout of the DoC can take any form as long as the minimum required relevant information is provided. If any of the minimum required content is missing, the DoC is considered not complete and thus not valid and may lead to an appropriate action from the competent authorities of a Member State. There is no need to reference a Notified Body on the DoC, and if the manufacturer has not used a Notified Body, there is nothing to reference anyway! If a Notified Body has issued a statement, I would recommend that a reference to it be included on the DoC. Best wishes Brian Brian Jones EMC Consultant From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of jharring...@f2labs.com Sent: 20 April 2007 17:08 To: emc-p...@ieee.org Subject: Declaration of Conformity to new EMC Directive This is really for Brian Jones (sorry Brian) but I thought I'd post it for general discussion Rightly or wrongly we have become accustom to people listing the harmonised standards they have applied (and even the test lab they used) on their D of C. In the absence of harmonised standards they have listed a TCF file number with a competent body name and certificate / report number. When the new EMC directive comes into force in July what do people write on their D of C when they a) haven't applied all (or any) of the harmonised standards and b) haven't chosen to use a notified body to bless their EMC assessment. Thanks John John Harrington EMC Technical Manager F-Squared Laboratories Tel: 440 834 8926 x 203 Fax: 440 834 8914 Cell: 440 832 0558 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __
Re: Declaration of Conformity to new EMC Directive
Hi, please check chapter 3.2.3 of the new EU Commission EMC guidelines (22nd March 2007): http://ec.europa.eu/enterprise/electr_equipment/emc/guides/emc_guide_2007.pdf Mit freundlichen Grüßen Yours sincerely Dipl.-Ing. Michael Loerzer Managing Director Regulatory Affairs Specialist Fon: +49 30 3229027-50, Direct Call: -51 Mobile: +49 177 3229027 (new) Fax: +49 30 3229027-59 http://www.Globalnorm.de www.Globalnorm.de Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin Geschaeftsfuehrer: Dipl.-Ing. Michael Loerzer Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448 - Original Message - From: jharring...@f2labs.com To: emc-p...@ieee.org Sent: Friday, April 20, 2007 6:07 PM Subject: Declaration of Conformity to new EMC Directive This is really for Brian Jones (sorry Brian) but I thought I'd post it for general discussion Rightly or wrongly we have become accustom to people listing the harmonised standards they have applied (and even the test lab they used) on their D of C. In the absence of harmonised standards they have listed a TCF file number with a competent body name and certificate / report number. When the new EMC directive comes into force in July what do people write on their D of C when they a) haven't applied all (or any) of the harmonised standards and b) haven't chosen to use a notified body to bless their EMC assessment. Thanks John John Harrington EMC Technical Manager F-Squared Laboratories Tel: 440 834 8926 x 203 Fax: 440 834 8914 Cell: 440 832 0558 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: Declaration of Conformity to new EMC Directive
In message C16858ED90BCC74686D26F1CFBFC00EA5EB4E0@exchange, dated Fri, 20 Apr 2007, jharring...@f2labs.com writes: When the new EMC directive comes into force in July what do people write on their D of C when they a) haven't applied all (or any) of the harmonised standards and b) haven't chosen to use a notified body to bless their EMC assessment. I wouldn't presume to keep up with the Joneses, but I think you say how to obtain a copy of your EMC Assessment that shows how you determined that the product conforms. You might consider employing someone who could quite legitimately sign the DoC 'B. Jones'. (;-) -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk There are benefits from being irrational - just ask the square root of 2. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __
Declaration of Conformity to new EMC Directive
This is really for Brian Jones (sorry Brian) but I thought I'd post it for general discussion Rightly or wrongly we have become accustom to people listing the harmonised standards they have applied (and even the test lab they used) on their D of C. In the absence of harmonised standards they have listed a TCF file number with a competent body name and certificate / report number. When the new EMC directive comes into force in July what do people write on their D of C when they a) haven't applied all (or any) of the harmonised standards and b) haven't chosen to use a notified body to bless their EMC assessment. Thanks John John Harrington EMC Technical Manager F-Squared Laboratories Tel: 440 834 8926 x 203 Fax: 440 834 8914 Cell: 440 832 0558 __ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email __ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: EU Declaration of Conformity Shipping Question
In message 7ff7dc23054e7d46b566eb7d2eda7e7421c...@exchsvr01.corp.xl.com, dated Wed, 22 Feb 2006, Stone, Richard rst...@excelswitching.com writes If a manufacturer of a product in the USA sells it to another company in the USA, who is NOW the owner of that product. Who is the responsibilty party in meeting any EU directive? the original manufacturer or the new owner who bought the product and then shipped to the EU. That happens outside the EU and should be determined contractually between the two parties. It's a legal, not a technical or standards, matter. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk 2006 is YMMVI- Your mileage may vary immoderately. John Woodgate - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
Re: EU Declaration of Conformity Shipping Question
In message 3ef8180825045544b765c027d8e950ee0397e...@whl60.e2v.com, dated Wed, 22 Feb 2006, Barker, Neil neil.bar...@e2v.com writes The responsible party is the person or company who first placed the product on the EU market. If the original manufacturer never placed the product on the EU market, then he has no responsibility. Yes, the 'placer' is responsible under EU law, but the 'placer' in the case cited probably does not have the necessary control of the product to bear the responsibility. Since the'placer' is outside the EU, he can (and almost certainly should) place the actual responsibility contractually on the real manufacturer. This is NOT allowed within the EU. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk 2006 is YMMVI- Your mileage may vary immoderately. John Woodgate - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
EU Declaration of Conformity Shipping Question
hello Group, If a manufacturer of a product in the USA sells it to another company in the USA, who is NOW the owner of that product. Who is the responsibilty party in meeting any EU directive? the original manufacturer or the new owner who bought the product and then shipped to the EU. with that, does it have any effect if the new owner puts their logo on the box? I am curious at the responsibilties of each party in a tranaction like this. I ask for two reasons: 1. just a general question 2. what is a directive changes in the time between when the orignal manufacturer got compliance on the product before it was sold to company B within the USA, then say 3 months later, the directive changed and company B doesnt do compliance. thanks for your time... Richard From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Chris Maxwell Sent: Wednesday, February 22, 2006 10:02 AM To: Nick Williams; chris.dup...@elekta.com Cc: Emc-Pstc Subject: RE: 'Evaporation' of compliance certification with time? I don't understand how looking at the age of a Declaration of Conformity will tell you anything. The only reason that a DOC should change is because of a change in the applicable standards. A DOC that's two weeks old could be garbage if the applicable standards hsve changed within those two weeks. On the other hand, a 10 year old DOC may be perfectly fine if there haven't been standard changes during that time. This is just another one of those rules that panders to ease of inspection while being meaningless. Anybody who looks for the age of a DOC is pretty much admitting that they have no idea of what the applicable standards are. Chris Maxwell Nettest, a division of Anritsu From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Nick Williams Sent: Wednesday, February 22, 2006 9:17 AM To: chris.dup...@elekta.com Cc: 'Emc-Pstc' Subject: Re: 'Evaporation' of compliance certification with time? Chris You've dropped into a big debate which is going on in the higher echelons of the EU's enterprise directorate. At present, I don't think any of the new approach directives place an upper limit on the life of a conformity certificate, but there is pressure to include this in some of the Directives (e.g. Machinery) when they are revised, and also to make the certificate issuing bodies responsible for telling their customers when the standards and regulations which affect their products change. The Notified Body groups are (by and large) resisting this change. In my experience, for consumer durables most UK high street retailers want to see a certificate which is no more than 2 years old. Some of the bigger test houses put a 5 year life on their certificates, but this is not done with any authority from the Directives, although I think this is likely to be the upper limit if/when this is introduced in the directives in due course. Of course, this assumes that the product which was originally certified is the one you are still selling. If you make changes to the product, you and your certification body have to agree between you whether or not the original certificate is still valid. That's a whole new can of worms! If you're really interested in this, get yourself added to the DTI's ConCASS mailing list - mail me direct for contact details. Nick. At 12:05 pm + 22/2/06, chris.dup...@elekta.com wrote: Gentlemen, and ladies, and others. Does anyone have an opinion on the longevity of a Compliance Certificate? Take the situation. If we make a product, test it, certify it, and sell this in the normal way, how long can we carry on selling this product (assuming that there are no design changes, but changes due to obsolescent parts or 'more modern' parts) relying on the original test results and certificate to provide evidence of Compliance? My own gut feeling is that three years is perfectly OK, and 20 years is too long, so somewhere in between those two figures may be about right I suppose. Does anyone have an opinion, a precedent, or rationale for this subject? Thankyou for your attention. Chris Dupres. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald:emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list.Website: http://www.ieee-pses.org/ To post
RE: Declaration of Conformity - Clarification Needed
In a previous life we interpreted person responsible for placing on the market as the VP of Marketing. He got _real_ nervous if the product didn't have engineering's full and enthusiastic blessing after that. Brent DeWitt From: emc-p...@ieee.org [mailto:emc-p...@ieee.org]On Behalf Of Chris Maxwell Sent: Tuesday, August 09, 2005 1:10 PM To: emcp...@aol.com; EMC-PSTC@listserv.ieee.org Subject: RE: Declaration of Conformity - Clarification Needed Tim, It’s my understanding that the DOC must be signed by an “Officer of the Company”…someone who has authority to sign legal documents. In my time here, we have bounced this responsibility around a little. We have used various people, such as: the CEO, General Manager and/or Vice President of Engineering. Best regards, Chris Maxwell Design Engineer Nettest _ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of emcp...@aol.com Sent: Tuesday, August 09, 2005 3:55 PM To: EMC-PSTC@listserv.ieee.org Subject: Declaration of Conformity - Clarification Needed Hello, I had to send this message again because it was rejected by the server. I'm wondering who should sign the CE and C-Tick DoC. Does it have to be someone in upper management? Is there any written requirement? Thanks, Tim Pierce This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/listserv/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
