Re: European Power cords
In response to Nick Rouse's comments: I stand to be corrected. Indeed, Member States may thwart the intent of the Directives by doing weird and wonderful things when they transpose/approximate. At times their reasons me not be the purest, but in the UK case, it is clear to the rest of the world that a good plug has a fuse. I believe that every principality has something or other that says that you should use plugs in that country that fit the sockets they are likely going to be plugged in to. The issue in that case is that an ill-fiting plug may cause heating, fire and other unpleasant things. The question now is, if you supply the customer with a box that has a cord and plug that may not fit the local sockets PLUS a cord and plug that WILL fit the local sockets, will that cause enough confusion to lead to unpleasant events. Remember, you meet the letter of the local law that says that you shall provide the proper plug. The issue is whether the improper plug, also included in the package, will be considered likely to cause problems. My take is that this may well vary from country to country. The worst case is if the plug "almost" fits and people who can not read the instructions are going to try. Given the complexities of all the possible combinations, I change my tune and now believe that probably you should not be allowed to give the customer a choice of cords in the box, because it may well be a violation of the LVD essential requirements. Regards, Vic Boersma Vic
Re: European Power cords
The UK measure that relates to power cords is the Plugs and Sockets (safety) Regulations 1994, Statutory Instrument 1994 No. 1768. I have not read this measure but I understand that it requires that mains powered electrical equipment being supplied in the UK and likely to be sold in the UK to domestic consumers must be supplied by the 'first supplier' i.e. manufacturer or importer, with a mains lead with a properly fitted plug. This plug must be either a UK style fused 250V 13A plug to BS 1363A with a correctly rated fuse or a plug to a type approved for use in a EEA member state in which case an approved conversion adaptor to BS1363A again fited with a correctly rated fuse must be supplied. This requirement came into force on 1 Feb 1994. It was not brought in under the Low Voltage Directive (implimented in the UK by Statutory Instrument 1994 No. 3260) but as secondary legislation under the Consummer Protection Act. Such national measures that may be thought to be in conflict with European directives must be submitted to the Commission under Directive 83/139/EEC, as amended, who may order a delay before implimentation to allow for any objection to be raised and dealt with. There were objections from the Commission and others to this measure but they were finally resolved and the measure approved by the Commission. I spoke to Nick Winter who is responsible for the unit at the UK Department of Trade and Industry (DTI) that deals with electrical safety legislation. He told me that in trying to steer the Plugs and Sockets Regulations through the 83/139/EEC mechanism his unit had done a survey of other EEA members states to look for requirements for national style plugs. They found nearly all had some such requirement. Most had, in implimenting the LVD, taken the requirement in Annex 1 1(c) of the directive that 'the electrical equipment, together with its component parts should be made in such a way as to ensure that it can be safely and properly assembled and connected' and implimented it for their state to require that mains connections be made with national style mains plugs and sockets. My conclusion is that it is fine for the distributor in the UK (who as importer becomes first supplier) to substitute UK power cords for US ones for units for sale in the UK. There is a good chance that it would be fine to substitute other other power chords for other destinations but you would have to examine the national laws in each state to be sure. All this demonstrates that Europe is very far from a single market. Vic Boersma says that 'the issue here is not UK Statutes, but EU Directives, which are legally binding laws of the European Union that become mandatory by their transposition into national laws of the Member States.' This misses the point that the directives are not in themselves legally binding on individuals or companies. Member states are treaty bound to 'approximate' national laws to the directives but these approximations, which are legally binding on indivduals in that state, are in many cases just that, approximate. Member states can, via the 83/139/EEC mechanism introduce national measures in derogation of the principal of the free movement of goods and several hundred such measures have been notified under this mechanism. The Commission can bring member states to court for incorrect implimentation of the directives and in one case an individual successfully challenged a member state's implimentation of a directive in the European Court but such litigation is not for the faint hearted. Vic was however much nearer the truth than me in one other matter. In a recent post he used the definition of rated voltage in IEC950 to deduce that the LVD did not apply to equipment that was powered by a voltage below the limit but generated voltages within the limits. I'm still not sure of using IEC950 but the conclusion he came to agreed with the interpretation of phrase 'designed for use with a voltage rating of ...' given by Nick Winter at the DTI. They regard the directive as applying only to equipment powered by voltages within the stated limits Nick Rouse
Re: European Power Cords
Mark, With regard to your No.1, 2, and 3: Check Annex ZB and ZC of your EN60950:1993. I am sure it is not ILLEGAL to ship a different power cord to another country. I have not checked all power cords, but most plugs will not fit another country's socket. Note that Europe has separate standards for the cord and the plug. Thus, you could ship just the appropriate attached cord with leads unterminated. However, several country deviations would require you to provide instructions in their language on how to attach the proper plug. It's easier to provide the appropriate cordset to start with. We have no problem with your No.4 since we provide the appropriate cordsets. However, if your U.S. manufacturer cannot or does not want to stock them in the U.S., then your European entity who "places the equipment in the marketplace" (agent, distributor, etc.) is responsible for providing the proper cordset or the proper instructions on how to connect this equipment in the particular country. Hope this helps. Tania Grant, Octel Communications Corporation __ Reply Separator _____ Subject: European Power Cords Author: "Montrose; Mark" at P_Internet_mail List-Post: emc-pstc@listserv.ieee.org Date:5/20/96 10:17 AM This question relates to the use and application of power cords provided into the EU when shipped from the USA. A company builds one version of a highly configurable product. The user chooses any combination of optional pwbs (over 20 different options) plugged anywhere into a large backplane along with a choice of several different power supply assemblies (universal auto-voltage detect, redundant, non-redundant, etc.). The product is handled by European distributors who order a large number of units for their warehouses for reshipment to any country within Europe, including non-European countries. The manufacturer, located in the USA, has no idea what country the unit will be sold to or how it is finally configured since this is up to the European distributor to configure and sell the unit. The USA manufacturer provides a North American power cord set as a default item to all shipping assemblies, since most units sold are to North America. The company, at no charge, will provide to the distributor a power cord appropriate to the end country's application. This power cord is purchased from a European power cord manufacturer, located in the UK, and dropped shipped to the distributor, also located in the UK (one of several European distributors throughout the continent). The following issues have now been raised by a sales manager in the UK which we are unable to answer. 1. Is it legal to ship North American, 120VAC power cords into the UK, knowing that these cords will be thrown away upon receipt? Please provide the statutory Instrument in UK law that says 120 VAC rated cords are illegal for importation, even if they will never be used. 2. Please provide the UK statutory Instrument (and any other European Country National Law) that mandates products received from North America must contain a power cord appropriate to their national electric requirements, plug specific. 3. In examining the LVD and EN 60950, no mention is made regarding the legal requirement to ship a particular power cord into Europe. The LVD para 3.2.4 mandates electrical requirements and type of cordage required. 4. If the USA manufacturer cannot stock variations of European power cords, then how does your company handle this issue of multiple power cordsets for use worldwide. 5. Are their any other statutory Instruments or requirements related to power cord usage within the EU not addressed above. Thank you. Mark Montrose ma...@hls.com
European Power Cords
Mark Montrose wrote: "RE:European Power Cords This question relates to the use and application of power cords provided into the EU when shipped from the USA. A company builds one version of a highly configurable product. The user chooses any combination of optional pwbs (over 20 different options) plugged anywhere into a large backplane along with a choice of several different power supply assemblies (universal auto-voltage detect, redundant, non-redundant, etc.). The product is handled by European distributors who order a large number of units for their warehouses for reshipment to any country within Europe, including non-European countries. The manufacturer, located in the USA, has no idea what country the unit will be sold to or how it is finally configured since this is up to the European distributor to configure and sell the unit. I don't think the authorities having jurisdiction give a damn about all this. WHO makes the Declaration of Conformity and WHO holds the technical file, the manufacturer or the distributor ??? The USA manufacturer provides a North American power cord set as a default item to all shipping assemblies, since most units sold are to North America. The company, at no charge, will provide to the distributor a power cord appropriate to the end country's application This power cord is purchased from a European power cord manufacturer, located in the UK, and dropped shipped to the distributor, also located in the UK (one of several European distributors throughout the continent). Once again, all this is irrelevant, WHO is the responsible party ? Do you farm that responsibility out to your distributors, or are you responsible The following issues have now been raised by a sales manager in the UK which we are unable to answer. 1. Is it legal to ship North American, 120VAC power cords into the UK, knowing that these cords will be thrown away upon receipt? Please provide the statutory Instrument in UK law that says 120 VAC rated cords are illegal for importation, even if they will never be used. Wrong question. You can ship whatever you want into the UK. The issue is whether you can put it on the market in the UK, or anywhere IThe only questions that you need to answer are in else. Putting on the market is making it available to a third party, for the purpose of distribution and/or use. By the way, storage is not considered placing on the market. Selling to distributors is. It is a bit US ethnocentric to expect UK law or EU law to say something about US, 120VAC, 60 Hz powercords. In any event, the issue here is not UK Statutes, but EU Directives, which are legally binding laws of the European Union that become mandatory by their transposition into national laws of the Members States. The UK has transposed the Low Voltage Directive but that is not relevant either, because you are distributing all over the map out of the UK. Boxes that go to Upper Slobovia, do not have to meet EU and EEA requirements. They probably will have to meet Upper Slobovian requirements, once they get there. 2. Please provide the UK statutory Instrument (and any other European Country National Law) that mandates products received from North America must contain a power cord appropriate to their national electric requirements, plug specific. The UK statute is not relevant. EU Directives are. The EU Member States must allow free movement of goods that meet the essential requirements of all relevant Directives. Since the plugs are different in every EU Member State, making having a specific plug an essential requirement would immediately stop all trade in electrical equipment. 3. In examining the LVD and EN 60950, no mention is made regarding the legal requirement to ship a particular power cord into Europe. The LVD para 3.2.4 mandates electrical requirements and type of cordage required. The LVD does not have a para 3.2.4, IEC-950 derivatives do, but will not specify the plug. Reason is that IEC-950 is not a catalogue of possible plugs but a safety standard. In addition, good business acumen dictates providing the equipment with a usable plug in the country where you sell (and instructions in a language the local populace can understand). 4. If the USA manufacturer cannot stock variations of European power cords, then how does your company handle this issue of multiple power cordsets for use worldwide. Any USA manufacturer who wants to, can stock any number of European power cords he wants to. However, he may find it to his advantage to let that be handled by his distributors. That has nothing to do with technical requirements, it has something to do with the economics of any given operation. 5. Are their any other statutory Instruments or requirements related to power cord usage within the EU not addressed above." YES, ANNEX I of th
European Power Cords
This question relates to the use and application of power cords provided into the EU when shipped from the USA. A company builds one version of a highly configurable product. The user chooses any combination of optional pwbs (over 20 different options) plugged anywhere into a large backplane along with a choice of several different power supply assemblies (universal auto-voltage detect, redundant, non-redundant, etc.). The product is handled by European distributors who order a large number of units for their warehouses for reshipment to any country within Europe, including non-European countries. The manufacturer, located in the USA, has no idea what country the unit will be sold to or how it is finally configured since this is up to the European distributor to configure and sell the unit. The USA manufacturer provides a North American power cord set as a default item to all shipping assemblies, since most units sold are to North America. The company, at no charge, will provide to the distributor a power cord appropriate to the end country's application. This power cord is purchased from a European power cord manufacturer, located in the UK, and dropped shipped to the distributor, also located in the UK (one of several European distributors throughout the continent). The following issues have now been raised by a sales manager in the UK which we are unable to answer. 1. Is it legal to ship North American, 120VAC power cords into the UK, knowing that these cords will be thrown away upon receipt? Please provide the statutory Instrument in UK law that says 120 VAC rated cords are illegal for importation, even if they will never be used. 2. Please provide the UK statutory Instrument (and any other European Country National Law) that mandates products received from North America must contain a power cord appropriate to their national electric requirements, plug specific. 3. In examining the LVD and EN 60950, no mention is made regarding the legal requirement to ship a particular power cord into Europe. The LVD para 3.2.4 mandates electrical requirements and type of cordage required. 4. If the USA manufacturer cannot stock variations of European power cords, then how does your company handle this issue of multiple power cordsets for use worldwide. 5. Are their any other statutory Instruments or requirements related to power cord usage within the EU not addressed above. Thank you. Mark Montrose ma...@hls.com
