EMC-pstc-list, 

I have a question concerning the EMC directive. We are in a situation were an
old standard EN 60601-1-2:1993 
is superseded by a new one: EN 60601-1-2:2001. 

I have a discussion with a colleague about what should happen after the date
of withdrawel (DOW). 

Here is a small part from a text that my colleagues are referring to): 

When a harmonized standard used for presumption of conformity changes (as a
result of a new 
edition, for example), then the presumption of conformity cannot be continued
ad-infinitum by the 
manufacturer. Until the manufacturer can demonstrate conformity to the newer
version of the standard 
he cannot affix a CE marking to the product or place it on the EU market.. 

Often this is not well understood. iI fact, many manufacturers think that
their product is "grandfathered". 
The truth is, all devices placed on the market after DOW must meet the new
version of the standard 
if the manufacturer wishes to continue to legally affixing the CE mark. 


This interpretation differes from my personal view: 

A product should comply with the essential requirements of the EMC directive,
that is, (1) protection of radio-service 
and (2) immunity with respect to external disturbances. 

One should use all (applicable) standards to demonstrate the above. 

If a harmonized standard changes, for example a new edition, then it is not
necessary ilegal to affix the CE label 
and place the equipment on the EU market. We have already demonstrated that it
meets the essential requirments 
of the EMC directive. 
Of course, when there is a technical change in the standard then a (risk)
analysis should be done to assess the effect 
on the EMC performance and, possibly, action is required on behalf of the
manufacturer. 

So all devices placed on the market after the DOW do not necessarily have to
meet the new standard. And in theory it 
is possible that products are indeed "grandfathered" 

This probably an old topic. (???) 


Kind regards, 

Jan Vercammen 
EMC engineer 
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