Oliver The issue is that the legal bit stating that only the MD applies and not the LVD is in the MD (below) and not included in the list of exemptions in Annex II of the LVD
1.5. RISKS DUE TO OTHER HAZARDS 1.5.1. Electricity supply Where machinery has an electricity supply, it must be designed, constructed and equipped in such a way that all hazards of an electrical nature are or can be prevented. The safety objectives set out in Directive 73/23/EEC shall apply to machinery. However, the obligations concerning conformity assessment and the placing on the market and/or putting into service of machinery with regard to electrical hazards are governed solely by this Directive. (noting that 73/23/EEC was the first iteration of the LVD) My view is that Turkish customs are incorrect, but there’s little point in trying to argue with them, so I would send them a DoC that they are happy with, listing the relevant standard(s) you have applied. Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Charles Grasso <[email protected]> Sent: 17 January 2022 16:55 To: [email protected] Subject: Re: [PSES] Notice about LVD compliance in a DoC for machinery? Other that the fact that the statement is "the manufacturer’s EC Declaration of conformity shall not refer to the LVD but to the MD".? My guess is that you could invalidate the DoC if you violate that requirement. Chas On Mon, Jan 17, 2022 at 9:41 AM Oliver Betz <[email protected]<mailto:[email protected]>> wrote: This message originated outside of DISH and was sent by: [email protected]<mailto:[email protected]> Hi all, the "Guide to application of the Machinery Directive 2006/42/EC", Edition 2.2: https://ec.europa.eu/docsroom/documents/38022 states: "...Thus, whilst machinery with an electrical supply, which is not in any of the categories listed in Article 1(2) (k) of MD, shall fulfil the safety objectives of the LVD, the manufacturer’s EC Declaration of conformity shall not refer to the LVD but to the MD". Yet, EN60204-1:2018 is listed in the LVD summary of harmonised standards. Would it harm to state also the LVD conformity in a DoC for machinery? The above mentioned guide writes that the DoC "shall *not* refer to the LVD but to the MD" but I'm not sure about the intention behind. And we have problems with Turkish customs insisting that the DoC shall list also LVD compliance. I wonder whether / how I can phrase an elegant note on the LVD compliance. Any ideas? Oliver - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]<mailto:[email protected]>> 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 <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher: <[email protected]<mailto:[email protected]>> David Heald: <[email protected]<mailto:[email protected]>> -- Charles Grasso Dish Technologies (c) 303-204-2974 (h) 303-317-5530 (e ) [email protected]<mailto:[email protected]> (e2) [email protected]<mailto:[email protected]> - ---------------------------------------------------------------- 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 <[email protected]<mailto:[email protected]>> 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 <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[email protected]>> - ---------------------------------------------------------------- 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 <[email protected]> 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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
