How does LVD point to EN62368

Hi

I know (have been told) that for a lot of products, the EN62368 is the new harmonized standard to follow (audio/Video/information/comms)

So, for once, I tried to follow the breadcrumbs. So starting with LVD:

Low voltage (LVD) (europa.eu)

EUR-Lex - 32014L0035 - EN - EUR-Lex (europa.eu)

In this page, one can find the groups:

DocsRoom - European Commission (europa.eu)

But, where is it actually defined precisely which standard to use? (what category ones product falls under)

The low voltage directive is the overall electrical safety legislation covering the requirements for any product placed on the market in the european union. The UK and the rest of the world have similar requirements…UK equivalent is the statutory instrument - electrical equipment safety regulations.

Its a catchall document with information explaining how to provide documented evidence that a product is electrically safe by design and testing. It details the evidence and marking required.

The easiest way to meet the requirements of the low voltage directive for a product is to create and maintain a technical file. The technical file comprises all of the pertinent information relating to the products design, construction electrical safety, electromagnetic compatibility and any other pertinent directives applicable like WEEE and RoHS.

As part of making the technical file up the product being documented will need testing. The testing is detailed by an appropriate standard.

There are generic catch all standards for electrical safety like EN 60335 - household and similar electrical appliances and there are more specific ones like en60601 - medical devices or en 61010 - measurement control and laboratory equipment.

For a multimedia device like a laptop, television, paper printer etc then en 62368 would probably apply.

How one arrives at the appropriate standards to apply unfortunately comes from experience and reading the scope of the standard.

It is the same for EMC standards or any other standard for that matter…there are guidance documents from the EU that assist - official journals and the ‘blue book’ and ‘red book’ etc.

There are also online publications like In Compliance magazine which run articles from time to time.

Rather than unhelpfully point you at these links and expect you to read digest and understand everything…give me an overall picture of the product you are trying to assess:

Is the device a television, music player, picture display or something similar - does it connect to the internet and is it mains powered?

If the device is all of the above then en 62368 could be applied…perform the appropriate tests in the standard, write a report stating the tests performed and how it passed those tests. Place the report in the technical file and move on to the next annoying compliance requirement :slight_smile:

As part of this you should really have the labelling and user manual ready for assessment.

If you are still struggling with all of this message me back and i will help you.

I found this article which might also provide some assistance:

https://www.cui.com/catalog/resource/iec-62368-1-an-introduction-to-the-new-safety-standard-for-ict-and-av-equipment

I used to do this for a living at one time although i was more focused on the EMC standards. Not to worry though…i did enough of both to be confident i can assist you.

Good luck - Alex

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It’s a industrial product, mains powered and has a number of communication interfaces

I know that I need to comply to 62368, I have done products many times before

What is just annoying me, is that if anyone asked, like actually the project manager did this morning, I cannot point to the exact clear cut, no discussion path to this standard

In the old days, there were many standards, and sometimes some people did cherry picking to find an appropiate standard. Today, with the harmonized standards, it’s a lot easier

And, thanks for your valuable input :slight_smile:

Yes, the Directives never point to standards, they just say “It has to be safe”. You have to look at the scopes of various standards to find which ones could apply, as @engineer1980 mentioned.

That is still the case. I have a job right now where either EN61010 or EN61800-5 could be applied, and there are similar competing products on the market complying with one or the other of these standards. One company even makes some with 61010 and some with 618500. Same exact product and functionality. In my case, the product ends up as a component in a much larger system, so I guess the choice of standard is determined by the standard to which the end system will be tested.

“Cherry picking” is allowed, as long as you’re sure that your product falls within the scope of the standard you pick.

It should be noted that the LVD covers all safety considerations of products falling with its scope, not just electrical safety.

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I still cherry pick standards and apply more than one if I think it’s appropriate.

If the device is some sort of industrial controller with communications interfaces like ethernet or RS485 I’d apply EN 601010 - measurement control and laboratory equipment. I’ll try and find you the blue book guidance document from the Eurolex website that had some clear guidance of how to apply the appropriate standard.

It all depends on the person assessing the technical file. In the UK this rarely happens unless a complaint has been raised about the device’s compliance. Trading standards and magistrates are usually rarely able to assess this sort of thing and get a compliance lab or consulting expert to assess the technical file. When I did it for Trading standards I approached it in this way:

  1. Assess the declaration of conformity
  2. Assess the technical file
  3. Do the standards listed on the declaration match those listed in the technical file and are they reasonably relevant - a garden mower cannot be declared as compliant using the toy standards or as a medical device.
  4. If the standards declared are reasonable then are the test reports or technical rationales used for evidence of a pass valid. Check the technical content and if necessary contact the test lab for confirmation.
  5. Assess the user manual and product information.

In your case I think you would be OK using EN 62368 to provide evidence of compliance because it’s a very thorough standard and the testing required is also used in EN 61010 and others…

My only comment would be that an industrial controller with an ethernet port is not an audio visual multimedia device and it’s a stretch to say it is…the fact that it has an ethernet port or other port often used on multimedia devices is the only real link in my opinion. I would apply EN 61010 for the most part and apply EN 62368 for the communication ports. I’d find the tests which are covered by both standards, perform them and have my test report cite both standards and put both standards on the declaration. I’d also put a cover note in the technical file detailing why that has been done. The technical file and declaration of conformity are all about risk management…as long as the product has been tested for electrical safety and passed and there is documented evidence of doing so I doubt a court would be bothered. The enforcement agencies assessing declarations may comment but their comments can be fairly challenged if needed. The key part is to have the technical file and declaration done before placing the product on the market…

I found this guidance document which might keep your project manager quiet for a while:

https://ec.europa.eu/docsroom/documents/31221/attachments/1/translations/en/renditions/native

I also managed to find the blue guide again:

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52016XC0726(02)&from=EN

The critical section I found on pages 7 / 8 is:

— products manufactured in compliance with harmonised standards benefit from a presumption of conformity with the corresponding essential requirements of the applicable legislation, and, in some cases, the manufacturer may benefit from a simplified conformity assessment procedure (in many instances the manufacturer’s declaration of conformity, made more easily acceptable to public authorities by the existence of the product liability legislation (9)),

— the application of harmonised or other standards remains voluntary, and the manufacturer can always apply other technical specifications to meet the requirements (but will carry the burden of demonstrating that these technical specifications answer the needs of the essential requirements, more often than not, through a process involving a third party conformity assessment body).

Seems to back up my idea of using more than one standard to provide evidence of compliance…

Hope this helps you out.

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Blockquote
It should be noted that the LVD covers all safety considerations of products falling with its scope, not just electrical safety.

Not sure I entirely agree with your comment - The scope clearly discusses electrical safety of equipment…above and below certain voltages:

"The purpose of this Directive is to ensure that electrical
equipment on the market fulfils the requirements providing
for a high level of protection of health and safety of persons,
and of domestic animals and property, while guaranteeing the
functioning of the internal market.

This Directive shall apply to electrical equipment designed for
use with a voltage rating of between 50 and 1 000 V for alternating current and between 75 and
1500 V for direct current, other than the equipment and phenomena listed in Annex II."

For other aspects of safety there is the general product safety directive:

https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32001L0095&from=EN

…which is incredibly nebulous and could apply to just about anything. My take is if you have a device which you are looking to place on the market and it’s covered by the scope of the directive it needs to meet the directive via appropriate standards and testing or via justifiable technical rationale.

This is from “Low Voltage Directive 2014/35/EU Guidelines” Nov 2016 (not sure if it’s the latest):

Screen Shot 2022-04-09 at 11.02.36 AM

Fair enough…i sit corrected. Thank you that.

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