Workshop New Approach – Sofia, Bulgaria – 19/20 April 2006 - 1 Workshop on New Approach Directives Workshop on New Approach Directives for the Engineering Industry for the Engineering Industry Focus on Directives Focus on Directives Regulating Electrical Regulating Electrical Engineering Industries Engineering Industries Haimo Huhle Haimo Huhle ORGALIME / ZVEI ORGALIME / ZVEI Technical Legislation and Technical Legislation and Standardisation Standardisation
Transcript
Workshop New Approach – Sofia, Bulgaria – 19/20 April 2006 - 1
Workshop on New Approach Directives for the Workshop on New Approach Directives for the Engineering IndustryEngineering Industry
Focus on Directives Regulating Focus on Directives Regulating Electrical Engineering Electrical Engineering
based on international Standardsbased on international Standards
permanent mandate to CENELECpermanent mandate to CENELEC
except: basic components
standard can be used after ratification
lower/upper voltage limitlower/upper voltage limit
all hazards are addressed
hierarchy EN, IEC, national
declaration of conformity does not accompany the productdeclaration of conformity does not accompany the product
not for electrical equipment for own usenot for electrical equipment for own use
Main characteristics of the LVDMain characteristics of the LVDLVD: Low Voltage Directive
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Total Safety ApproachTotal Safety Approach
For clarification:For clarification: The LVD is no „phenomenom directive“, The LVD is no „phenomenom directive“, which covers only electrical hazards. which covers only electrical hazards.
It deals with all hazards.It deals with all hazards.
Therefore, a clear borderline to other directives is important. Therefore, a clear borderline to other directives is important. Each „double use“ of directives on one product leads to higher Each „double use“ of directives on one product leads to higher costs and causes uncertainty.costs and causes uncertainty.
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SLIM-process proposed by the Internal Market CouncilSLIM-process proposed by the Internal Market Council
launched by the EU Commission in 1996launched by the EU Commission in 1996
Examination of directives in teamsExamination of directives in teams
Commission should propose amendments or revision to Commission should propose amendments or revision to the Council and the European Parliamentthe Council and the European Parliament
SLIM - simpler legislation for the internal market SLIM - simpler legislation for the internal market
Revision of the EMC-DirectiveRevision of the EMC-Directive
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„„Reasons“ for choosing the EMCD:Reasons“ for choosing the EMCD:
different interpretations in the member statesdifferent interpretations in the member states
no uniform conformity assessmentsno uniform conformity assessments
too much red tapetoo much red tape
Task was tackled in 1998 by a SLIM-Team, which made Task was tackled in 1998 by a SLIM-Team, which made suggestions in a report.suggestions in a report.
Conformity assessment:Conformity assessment:Involvement of 3rd party voluntaryInvolvement of 3rd party voluntary
Terminology:Terminology:„competent body“ renamed to „notified body“„competent body“ renamed to „notified body“
Marking and accompanying information:Marking and accompanying information:More details for the userMore details for the user
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Definition, which takes on board practical industry Definition, which takes on board practical industry experienceexperience
includes: networks and large machines as well as special includes: networks and large machines as well as special equipment for fixed installationsequipment for fixed installations
to be erected with „good engineering practice“to be erected with „good engineering practice“
without conformity assessment, without declaration of without conformity assessment, without declaration of conformity and without CE markingconformity and without CE marking
User is obliged to eliminate disturbances if they occurUser is obliged to eliminate disturbances if they occur
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3) More precise: Information 3) More precise: Information requirementsrequirements
Identification of the productIdentification of the product
Name and address ofresponsible companies
Name and address ofresponsible companies
EMC-relevant informationfor assembly, use etc.
EMC-relevant informationfor assembly, use etc.
Information on restrictionof use
Information on restrictionof use
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DatesDates
Commission proposal December 2002Commission proposal December 2002
Co-decision procedure according to article 251 with Councila and European Co-decision procedure according to article 251 with Councila and European ParliamentParliament
20 January 2005:20 January 2005:
The new directive enters into forceThe new directive enters into force (without „affecting“ the manufacturers) (without „affecting“ the manufacturers)
20 July 2007: 20 July 2007:
Transposition to national law has to be finishedTransposition to national law has to be finished (from now on the directive may be applied) (from now on the directive may be applied)
20 July 2009:20 July 2009:
End of transitional period. Products must fulfill the new requirements when End of transitional period. Products must fulfill the new requirements when they are placed on the market for the first time.they are placed on the market for the first time.(equipment on stock of a retailer is already placed on the market and can be (equipment on stock of a retailer is already placed on the market and can be distributed without modification)distributed without modification)
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GuidelinesGuidelines
Begin of work on new guidelines in summer 2004 (!)Begin of work on new guidelines in summer 2004 (!)
First draft for comments in April 2005First draft for comments in April 2005
ORGALIME concerns:ORGALIME concerns:• too long and too detailed• too long and too detailed• too many technical and physical explanations• too many technical and physical explanations• the chapter on „fixed installations”• the chapter on „fixed installations” is too much energy supply oriented is too much energy supply oriented• definitions for „end-user” and „large machines”• definitions for „end-user” and „large machines”
are missing are missing• special questions concerning high-voltage• special questions concerning high-voltage
equipment are to be clarified equipment are to be clarified
Number of comments from all stakeholders: 1000 (!)Number of comments from all stakeholders: 1000 (!)
WG redrafts the text now.WG redrafts the text now.
Workshop New Approach – Sofia, Bulgaria – 19/20 April 2006 - 14
Machinery directiveMachinery directive
Important for electroindustry: Important for electroindustry:
clear borderline to LVDclear borderline to LVD
exclusion of high-voltage equipment exclusion of high-voltage equipment
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Borderline to LVDBorderline to LVD
Exclusion list in Article 1 (2):Exclusion list in Article 1 (2):
household appliances intended for domestic use,household appliances intended for domestic use,
audio and video equipment audio and video equipment
information technology equipment information technology equipment
switchgear and controlgearswitchgear and controlgear
electrical motorselectrical motors
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High voltage equipmentHigh voltage equipment
Article 1 (2):Article 1 (2):
the following types of high-voltage electrical equipment:the following types of high-voltage electrical equipment:
— — switch gear and control gear,switch gear and control gear,
— — transformers.transformers.
-> are excluded-> are excluded
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General Product Safety Directive General Product Safety Directive 2001/95/EC2001/95/EC
Objective: only safe products shall be placed on the Objective: only safe products shall be placed on the marketmarket
in force since December 2001in force since December 2001
national transposition until January 2004national transposition until January 2004
for consumer productsfor consumer products
and „migrating“ products, which are intended for and „migrating“ products, which are intended for workers but are also used bei consumersworkers but are also used bei consumers
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GPSD: (unspecific) general safety requirement
GPSD: (unspecific) general safety requirement
LVD: more detailed technical health and safety objectives
LVD: more detailed technical health and safety objectives
GPSD: precise provisions on actions with dangerous products
GPSD: precise provisions on actions with dangerous products
LVD: no specific provisions concerning dangerous products
LVD: no specific provisions concerning dangerous products
... in so far as there are no specific ... in so far as there are no specific provisions ...provisions ...
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... in so far as there are no specific ... in so far as there are no specific provisions ...provisions ...
GPSD: (unspecific) general safety requirement
GPSD: (unspecific) general safety requirement
LVD: more detailed technical health and safety objectives
LVD: more detailed technical health and safety objectives
GPSD: precise provisions on actions with dangerous products
GPSD: precise provisions on actions with dangerous products
LVD: no specific provisions concerning dangerous products
LVD: no specific provisions concerning dangerous products
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Specific elements of the GPSDSpecific elements of the GPSD
General safety requirement and conformity General safety requirement and conformity assessment rather vagueassessment rather vague
Standardisation mandates with „arbitary“ safety Standardisation mandates with „arbitary“ safety requirements expectedrequirements expected
sample testing, register of complaintssample testing, register of complaints
manufacturer shall inform authorities on unsafe manufacturer shall inform authorities on unsafe productsproducts
precautionary principle in market surveillanceprecautionary principle in market surveillance
prohibition of export of unsafe productsprohibition of export of unsafe products
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CE everywhere ?CE everywhere ?... and no CE marking
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Thank you ... Thank you ...
… … for listening and asking questions.for listening and asking questions.
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