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ari.honk...@nokia.com wrote:
>
> The second scenario is correct.
> You might consider employing a competent body and use 10.2 route to
> compliance.
> If a TCF is used instead a harmonised standard, there will be nothing that
> could be
> superseded.
> regards,
> Ari
> > -----Original Message-----
> > From: EXT Collins, Erik D [mailto:collin...@lxe.com]
> > Sent: Tuesday, March 23, 1999 6:47 PM
> > To: 'BSI'; 'CCC'; 'dbt...@mcmail.com'; 'DGIII'; 'Eddy Tosney - Nemko';
> > 'Edward Rose - Nemko'; 'EMC test lab assoc'; 'emc-pstc'; 'etsemc';
> > 'KTL'; 'Nutwood UK'; 'Olaf van den Berg'; 'UMR EMC'; 'York EMC'
> > Subject: EN 50024:1998 vs En 50082-1:1992
> >
> >
> > To whom it may concern,
> >
> > I have reviewed the EMC Directive and the Guidelines to the EMC
> > Directive yet I am somewhat confused on the applicability of new and
> > superseded standards. I am trying to decide which version of the
> > generic immunity standard (EN 50082-1) to apply to our products, the
> > present (1992) or the new (1997) version. I currently test to EN
> > 50082-1:1992 as EN50082-1:1997 will not become effective until July 1,
> > 2001.
> >
> > I work for a company who imports ITE equipment into the EU. We are
> > currently shipping a data terminal, model # xxx which is compliant to
> > EN 50082-1:1992. We plan to continue shipping this product well after
> > 2001. After July 1, 2001, will the model # xxx units we import into
> > the EU still be considered compliant even though the standard to which
> > model # xxx was tested (EN 50082-1:1992) to has been superseded by a
> > newer standard (EN 50082-1:1997 or EN 50024:1998)?
> >
> > I have been told that model # xxx will still be compliant
> > since it was
> > first placed on the market when the 1992 standard was
> > effective and will
> > remain compliant after July 1, 2001 unless it is modified in such a
> > manner that it is considered new. I have also been told that every
> > model # xxx that is imported into the EU after July 1, 2001 will be
> > considered non-compliant unless it meets the standard which are
> > effective as of that date (EN 50082-1:1997 or EN 55024:1998).
> > These two
> > scenarios are conflicting and I would like to get some
> > clarity on this
> > matter. What will my responsibilities/obligations regarding model #
> > xxx be as of July 1, 2001? Will model # xxx require
> > re-testing? Your
> > guidance and assistance is appreciated.
> >
> >
> > Erik D. Collins
> >
> > EMI/EMC Approvals Engineer
> > LXE Inc.
> > 125 Technology Parkway
> > Norcross, GA 30092
> > USA
> > Phone 770-447-4224 x3240 or 3341
> > Fax 770-447-6928
> >
> > Check out our website @:
> > http://www.lxe.com
> > Erik D. Collins
> >
> > EMI/EMC Approvals Engineer
> > LXE Inc.
> > 125 Technology Parkway
> > Norcross, GA 30092
> > USA
> > Phone 770-447-4224 x3240 or 3341
> > Fax 770-447-6928
> >
> > Check out our website @:
> > http://www.lxe.com
> >
Ari and Erik, and all at emc-pstc
The EMC Directive applies to individual pieces of apparatus, not to the
type, so Ari is correct that each piece of apparatus, sold after the date
of cessation of presumption of conformity of a superseded standard, must
meet the requirements of the new standard. That is why there is
(generally) a three year period between the listing of a new harmonised
standard in the Official Journal, and the withdrawal of the old for the
purposes of the standards route to compliance.
Ari is also correct that a certified TCF is not superseded when standards
are changed, BUT a TCF cannot be used to avoid the requirements of an
appropriate harmonised standard without good reason. An example of a
good reason might be that apparatus which is always used in a damp
environment might not need to be assessed for ESD. The Competent Body
assessing the file would decide whether the justification was valid.
Best wishes
Brian Jones
EMC Consultant and Competent Body signatory
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