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Workshop on New Approach Directives for the
Engineering Industry
Focus on Directives Regulating
Electrical Engineering
Industries
Haimo Huhle
ORGALIME / ZVEI
Technical Legislation and Standardisation
Workshop New Approach – Sofia, Bulgaria – 19/20 April 2006 - 1
Low Voltage Directive – Which
products are regulated ?
„electrical equipment“
means any equipment
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Explanations on the scope
Communication of the European Commission of
1982:
„ ... Broadly the directive covers ...
Consumer and capital goods, ...
especially
 electrical appliances
 hand-held electrically driven tools
 lighting equipment
 wires and electric cables
 electrical installation equipment.“
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Main characteristics of the LVD
LVD: Low Voltage Directive
lower/upper voltage limit
„universal“ scope
except: basic components
abstract safety objectives
Total Safety Approach
all hazards are addressed
not for electrical equipment for own use
declaration of conformity does not accompany the product
no 3rd party involvement
based on international Standards
hierarchy EN, IEC, national
permanent mandate to CENELEC
standard can be used after ratification
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Total Safety Approach
 For clarification:
The LVD is no „phenomenom directive“,
which covers only electrical hazards.
 It deals with all hazards.
 Therefore, a clear borderline to other directives is important.
Each „double use“ of directives on one product leads to higher
costs and causes uncertainty.
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Revision of the EMC-Directive
SLIM - simpler legislation for the internal market
 SLIM-process proposed by the Internal Market Council
 launched by the EU Commission in 1996
 Examination of directives in teams
 Commission should propose amendments or revision to
the Council and the European Parliament
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SLIM-Projekt EMC-Directive
„Reasons“ for choosing the EMCD:
 different interpretations in the member states
 no uniform conformity assessments
 too much red tape
 Task was tackled in 1998 by a SLIM-Team, which made
suggestions in a report.
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New EMC Directive 2004/108/EC
Main points
Fixed installations:
simplified procedure introduced
Conformity assessment:
Involvement of 3rd party voluntary
Terminology:
„competent body“ renamed to „notified body“
Marking and accompanying information:
More details for the user
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1) Simplified:
Fixed Installations
 Definition, which takes on board practical industry
experience
 includes: networks and large machines as well as special
equipment for fixed installations
 to be erected with „good engineering practice“
 without conformity assessment, without declaration of
conformity and without CE marking
 User is obliged to eliminate disturbances if they occur
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2) Modified:
Conformity Assessment
apparatus
Standards used ?
no
yes
Technical
documentation
plus EMC analysis
manufacturer‘s
choice
Declaration
of conformity
Report of a competent
body
notified
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3) More precise: Information
requirements
Identification of the product
Name and address of
responsible companies
EMC-relevant information
for assembly, use etc.
Information on restriction
of use
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Dates
 Commission proposal December 2002
 Co-decision procedure according to article 251 with Councila and European
Parliament
 20 January 2005:
 The new directive enters into force
(without „affecting“ the manufacturers)
 20 July 2007:
 Transposition to national law has to be finished
(from now on the directive may be applied)
 20 July 2009:
 End of transitional period. Products must fulfill the new requirements when
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
distributed without modification)
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Guidelines
 Begin of work on new guidelines in summer 2004 (!)
 First draft for comments in April 2005
 ORGALIME concerns:
• too long and too detailed
• too many technical and physical explanations
• the chapter on „fixed installations”
is too much energy supply oriented
• definitions for „end-user” and „large machines”
are missing
• special questions concerning high-voltage
equipment are to be clarified
 Number of comments from all stakeholders: 1000 (!)
 WG redrafts the text now.
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Machinery directive
 Important for electroindustry:
 clear borderline to LVD
 exclusion of high-voltage equipment
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Borderline to LVD
 Exclusion list in Article 1 (2):
 household appliances intended for domestic use,
 audio and video equipment
 information technology equipment
 ordinary office machinery
 switchgear and controlgear
 electrical motors
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High voltage equipment
 Article 1 (2):
 the following types of high-voltage electrical equipment:
— switch gear and control gear,
— transformers.
-> are excluded
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General Product Safety Directive
2001/95/EC
 Objective: only safe products shall be placed on the
market
 in force since December 2001
 national transposition until January 2004
 for consumer products
 and „migrating“ products, which are intended for
workers but are also used bei consumers
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... in so far as there are no specific
provisions ...
 GPSD: (unspecific)
 LVD: more detailed
general safety
requirement
technical health and safety
objectives
 GPSD: precise
 LVD: no specific
provisions on actions
with dangerous
products
provisions concerning
dangerous products
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... in so far as there are no specific
provisions ...
 GPSD: (unspecific)
 LVD: more detailed
general safety
requirement
technical health and safety
objectives
 GPSD: precise
 LVD: no specific
provisions on actions
with dangerous
products
provisions concerning
dangerous products
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Specific elements of the GPSD
 General safety requirement and conformity
assessment rather vague
 Standardisation mandates with „arbitary“ safety
requirements expected
 sample testing, register of complaints
 manufacturer shall inform authorities on unsafe
products
 precautionary principle in market surveillance
 prohibition of export of unsafe products
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... and no CE marking
CE everywhere ?
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Thank you ...
… for listening and asking questions.
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