Haimo Huhle ORGALIME / ZVEI Technical Legislation and Standardisation

1. Workshop on New Approach Directives for the Engineering IndustryFocus on Directives Regulating Electrical Engineering Industries Haimo HuhleORGALIME / ZVEITechnical Legislation and Standardisation

2. Low Voltage Directive – Which products are regulated ? „electrical equipment“ means any equipment

3. 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.“

4. Main characteristics of the LVD LVD: Low Voltage Directive lower/upper voltage limit „universal“ scope except: basic components abstract safety objectives all hazards are addressed Total Safety Approach not for electrical equipment for own use declaration of conformity does not accompany the product no 3rd party involvement hierarchy EN, IEC, national based on international Standards permanent mandate to CENELEC standard can be used after ratification

5. 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.

6. 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

7. 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.

8. 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 New EMC Directive 2004/108/ECMain points

9. 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

10. 2) Modified:Conformity Assessment plus EMC analysis manufacturer‘schoice notified apparatus Standards used ? no yes Technicaldocumentation Declarationof conformity Report of a competentbody

11. Identification of the product Name and address ofresponsible companies EMC-relevant informationfor assembly, use etc. Information on restrictionof use 3) More precise: Information requirements

12. 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) Dates

13. 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.

14. Machinery directive • Important for electroindustry: • clear borderline to LVD • exclusion of high-voltage equipment

15. 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

16. High voltage equipment • Article 1 (2): • the following types of high-voltage electrical equipment: • — switch gear and control gear, • — transformers. -> are excluded

17. 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 General Product Safety Directive 2001/95/EC

18. ... in so far as there are no specific provisions ... • GPSD: (unspecific) general safety requirement • LVD: more detailed technical health and safety objectives • GPSD: precise provisions on actions with dangerous products • LVD: no specific provisions concerning dangerous products

19. ... in so far as there are no specific provisions ... • GPSD: (unspecific) general safety requirement • LVD: more detailed technical health and safety objectives • GPSD: precise provisions on actions with dangerous products • LVD: no specific provisions concerning dangerous products

20. 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 Specific elements of the GPSD

21. CE everywhere ? ... and no CE marking

22. Thank you ... … for listening and asking questions.