Germany: Streamlining CE Marking Process Under LVD
CE marking is an essential part of bringing products to the European market. It gives consumers the assurance that the product complies with European legislation and enables the free movement of those products throughout the European Economic Area (EEA).
To enable manufacturers to more quickly and easily determine which of these standards they must consider, GL Renewables Certification has for the first time undertaken a comprehensive survey of the standards within the Directive for Low Voltage Equipment (LVD) (2006/95/EC), as they apply to wind turbines.
Manufacturers of wind turbines – made up of multiple sets of technologies, often on the cutting edge of design and production – face a particularly difficult challenge when attempting to sort through the raft of legislation which might apply to them. They are responsible for ensuring that the products they bring to market comply with all the relevant legislation and if necessary have them examined by a notified conformity assessment body. At least five directives, with hundreds of harmonised standards are potentially applicable and failure to comply with any of them could result in legal liability, loss of reputation and the placement of a product on the RAPEX (Rapid Alert System for non-food dangerous products) list.
The LVD has 681 harmonised standards with potential application to wind turbines. The experts at GL Renewables Certification have identified 12 categories of electrical equipment within wind turbines which are implemented or possibly implemented in wind turbines and subject to CE marking under the LVD. Based on a comprehensive assessment of the harmonised standards, taking into account the electrical layout of modern turbine systems, these 681 harmonised standards have been split into three categories “White”, “Black” and “Grey”.
Of the 681 harmonised standards 406 are considered to not be applicable to CE marking of wind turbines – the “Black”. This list can contain superseded versions of applicable standards; however, normally these encompass a field which manufacturers or their representatives do not need to check.
There are 176 standards in the “White” category; standards judged to be fully applicable. This category includes only the most recent version of the applicable standards; a harmonised standard will be excluded even if it is fully applicable to CE marking of wind turbines when there is an updated version.
The 99 standards in the “Grey” category will apply under some circumstances, depending on the utilisation of the particular product. A questionnaire prepared by GL Renewables Certification helps manufacturers and their representatives to verify whether a harmonised standard within this category applies to their product.
Being able to concentrate only on the applicable set of standards drawn from the LVD will save manufacturers or their representatives considerable time, effort and expense in the CE marking process.
GL Renewables Certification would like to thank Zhuangzhuang Zheng for his work on the project as part of his master’s thesis at RWTH Aachen: “CE marking of Wind Turbines -Applicability of Harmonised Standards According to the EU Directive for Low Voltage Equipment 2006/95/EC)”.
Press release, October 15, 2012; Image: GL