Workshop New Approach – Sofia, Bulgaria – 19/20 April 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 Low Voltage Directive – Which products are regulated ? „electrical equipment“ means any equipment

Workshop New Approach – Sofia, Bulgaria – 19/20 April  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.“ Explanations on the scope

Workshop New Approach – Sofia, Bulgaria – 19/20 April Total Safety Approach abstract safety objectives „universal“ scope no 3rd party involvement based on international Standards permanent mandate to CENELEC except: basic components standard can be used after ratification lower/upper voltage limit all hazards are addressed hierarchy EN, IEC, national declaration of conformity does not accompany the product not for electrical equipment for own use Main characteristics of the LVD LVD: Low Voltage Directive

Workshop New Approach – Sofia, Bulgaria – 19/20 April 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.

Workshop New Approach – Sofia, Bulgaria – 19/20 April  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 SLIM - simpler legislation for the internal market Revision of the EMC-Directive

Workshop New Approach – Sofia, Bulgaria – 19/20 April  „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. SLIM-Projekt EMC-Directive

Workshop New Approach – Sofia, Bulgaria – 19/20 April 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

Workshop New Approach – Sofia, Bulgaria – 19/20 April  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 1) Simplified: Fixed Installations

Workshop New Approach – Sofia, Bulgaria – 19/20 April apparatus Standards used ? Declaration of conformity Technical documentation Report of a competent body yes no manufacturer‘s choice plus EMC analysis notified 2) Modified: Conformity Assessment

Workshop New Approach – Sofia, Bulgaria – 19/20 April ) 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

Workshop New Approach – Sofia, Bulgaria – 19/20 April 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)

Workshop New Approach – Sofia, Bulgaria – 19/20 April 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.

Workshop New Approach – Sofia, Bulgaria – 19/20 April Machinery directive  Important for electroindustry:  clear borderline to LVD  exclusion of high-voltage equipment

Workshop New Approach – Sofia, Bulgaria – 19/20 April 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

Workshop New Approach – Sofia, Bulgaria – 19/20 April High voltage equipment  Article 1 (2):  the following types of high-voltage electrical equipment:  — switch gear and control gear,  — transformers. -> are excluded

Workshop New Approach – Sofia, Bulgaria – 19/20 April 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

Workshop New Approach – Sofia, Bulgaria – 19/20 April 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... in so far as there are no specific provisions...

Workshop New Approach – Sofia, Bulgaria – 19/20 April 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

Workshop New Approach – Sofia, Bulgaria – 19/20 April 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

Workshop New Approach – Sofia, Bulgaria – 19/20 April CE everywhere ?... and no CE marking

Workshop New Approach – Sofia, Bulgaria – 19/20 April Thank you... … for listening and asking questions. … for listening and asking questions.