Group, CTL decisions are not relevant within the EC compliance system. Whether a manufacturer chooses to declare compliance based or not based on a CTL decision is simply not relevant as long as a compliance justification falls within a harmonised standard. If a test method can be carried out two ways, well then so be it. The consensus in veryfing compliance of a certain type of equipment is to follow the test method the manufacturer carried out, and not an alternative, whether CTL exists or not. CTL are relevant within the mutual recognition schemes between CB's only, and possibly as an input towards standard improvements. CB are private organistions, and decisons taken by them need no consideration by an regulatory system, and therefore need not be denied by EC or CENELEC. The system is simple, and remains simple, in spite of any powers trying to complicate affairs.
Regards, Gert Gremmen Approvals manager ====================================================== ce-test, qualified testing Member of EMC committee CENELEC/IEC + Independent Consultancy Services + Compliance Testing and Design for CE + Improvement of product quality and reliability + Testing services according to: Electro magnetic Compatibility 89/336/EC Electrical Safety 73/23/EC Medical Devices 93/42/EC Radio & Telecommunication Terminal equipment 99/5/EC Website: www.cetest.nl (english) www.ce-test.nl (dutch) Phone : +31 10 415 24 26 Fax : +31 10 415 49 53 ====================================================== From: owner-emc-p...@majordomo.ieee.org [mailto:owner-emc-p...@majordomo.ieee.org]On Behalf Of John Allen Sent: Thursday, December 18, 2003 10:09 AM To: 'richhug...@aol.com'; emc-p...@majordomo.ieee.org Subject: RE: CTL Decisions - the situation for Europe Richard I do realise that you are probably correct in suggesting that we close the general thread at this point, but I do also want to raise one additional issue related to Europe & CENELEC which I cannot see having been addressed: There appears to be a very serious issue if a CTL decision exists and is signed up to by one or more EU test house - but is not published as a common deviation in the relevant EN version of a standard, nor published elsewhere within the "official" EU public domain ? In these circumstances, a test house could fail a product on the basis of a CTL decision, whilst the manufacturer (or another test house) could pass the product because it did not know of, or chose to ignore, that CTL decision. Therefore in the latter case, the manufacturer could prepare his DoC in "good faith" - but yet this could be challenged at a later date, based on an opinion >from the first test house (say as a result of an accident) that it did not comply with the CTL. That is a serious problem for the test house(s) and the manufacturer in question, and the EU Directives compliance system in general. Therefore, it seems to me, that CTL decisions which could affect EN versions of standards MUST either: - be officially discussed and agreed in CENELEC TC's, and then published officially in the relevant standards or some other official publication (Harmonisation Documents, or even the OJ itself?) OR - be the subject of an official Commission and/or CENELEC policy statement to the effect that they are not valid in Europe, and shall not be taken into account in deciding on the compliance status of a product. If this issue has not already been raised at Commission Level, then how can it be done (possibly via the UK DTI?) John Allen, Technical Consultant EMC and Safety Engineering ERA Technology Ltd. Cleeve Road Leatherhead Surrey KT22 7SA UK Tel: +44-1372-367025 (Direct) +44-1372-367000 (Switchboard) Fax: +44-1372-367102 ********************************************************************** Copyright ERA Technology Ltd. 2003. (www.era.co.uk). All rights reserved. The information supplied in this Commercial Communication should be treated in confidence. No liability whatsoever is accepted for any loss or damage suffered as a result of accessing this message or any attachments. ********************************************************************** _____________________________________________________________________ This e-mail has been scanned for viruses by MCI's Internet Managed Scanning Services - powered by MessageLabs. For further information visit http://www.mci.com