Hi,
the European EMC ADCO group has decided that in the EC declaration of conformity the dated references of harmonized standards shall be included. The European EMC guidelines describes the “presumption of conformity” as followed (chapter 3.2.2, 3rd paragraph): “The EMC Directive refers to the moment of placing on the market for each individual apparatus. This means that for apparatus which is continuously produced over a long period, the applicable standards may change in the course of time. In this case the provisions explained at 3.2.2.3 concerning the date of cessation of Presumption of Conformity should be taken into account. The Date of Cessation ensures that a transition period (usually three years) is foreseen during which the old and new standards are both valid. After this time if the manufacturer wishes to continue to benefit from the Presumption of Conformity a new Declaration of Conformity is required to the later valid edition of the harmonised standard. This will require an EMC evaluation to the later version of the published harmonised standard and may require re-testing. However, it may be that the manufacturer wishes to continue to meet the essential requirements by continuing use of the “old” edition (that has ceased to be harmonised) plus other technical solutions if necessary. As harmonised standards are voluntary this is of course an acceptable solution but would not give the presumption of conformity that application of the later edition would confer. In addition, it will require amendment to the text of the Declaration given that the method of conformity assessment has now changed. Where new editions become available and are to be applied it does not necessarily mean that a complete EMC re-assessment of an existing product is necessary. The evaluation may be restricted to those modifications directly affecting the apparatus concerned. For example, the change may only relate to a small range in scope, or one particular clause or phenomenon.“ Therefore our German Market Surveillance Authority (Bundesnetzagentur) evaluates the “EC-DoCs” in the first step (at the second step “tests”) in regard to the applied standards. Mit freundlichen Grüßen Yours sincerely Dipl.-Ing. Michael Loerzer Managing Director Regulatory Affairs Specialist michael.loer...@globalnorm.de <mailto:michael.loer...@globalnorm.de> Fon: +49 30 3229027-50, Direct Call: -51 Mobile: +49 170 3229027 Fax: +49 30 3229027-59 www.Globalnorm.de <http://www.globalnorm.de/> Globalnorm GmbH, Sitz der Gesellschaft: Alt-Moabit 94, 10559 Berlin Geschaeftsfuehrer/Managing Director: Dipl.-Ing. Michael Loerzer Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448 Von: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Im Auftrag von Mark Gandler Gesendet: Freitag, 6. März 2009 20:09 An: tim.hay...@selexgalileo.com; j...@jmwa.demon.co.uk; emc-p...@ieee.org Betreff: RE: dated standards Tim and All, one of our products end up audited in Germany by Bundes........... They claim what our standards were outdated in DoC and they said as long as our product in on the market we must comply with new versions and it should be mentioned in DoC. The product is under RTTE. I have prepeared a letter describing what product did not change and in fact will comply with new versions of the standards by the virtue what physical requirements of the new standard did not change as well. I am not sure how it is going to end up and the product is already EOL anyway. Could you please comment and to share if anyone else had similar requests from auditors? Thanks, mark > Subject: RE: dated standards > Date: Fri, 6 Mar 2009 11:24:49 +0000 > From: tim.hay...@selexgalileo.com > To: j...@jmwa.demon.co.uk; emc-p...@ieee.org > > > Hi John, All, > > Don't forget that under the new EMC Directive you can sign off a DoC on > the basis that the equipment has been assessed against the essential > requirements. The fact that you use standard that are "out of date" is > immaterial - it is still a valid DoC. People who are getting ready to > spend money re-certifying because the standards (or indeed the > Directive) have passed their sell-by date need only satisfy themselves > that the product has not changed and then write a new DoC against the > existing evidence and declare under the full EMC assessment route. A bit > of paperwork instead of a lot of testing. > > Still I don't expect the test houses to go broke. > > Regards > Tim > > SELEX Sensors and Airborne Systems Limited > Registered Office: Sigma House, Christopher Martin Road, Basildon, Essex SS14 3EL > A company registered in England & Wales. Company no. 02426132 > ******************************************************************** > This email and any attachments are confidential to the intended > recipient and may also be privileged. If you are not the intended > recipient please delete it from your system and notify the sender. > You should not copy it or use it for any purpose nor disclose or > distribute its contents to any other person. > ******************************************************************** > > - > ---------------------------------------------------------------- > This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> > > All emc-pstc postings are archived and searchable on the web at: > http://www.ieeecommunities.org/emc-pstc > Graphics (in well-used formats), large files, etc. can be posted to that URL. > > Website: http://www.ieee-pses.org/ > Instructions: http://listserv.ieee.org/request/user-guide.html > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <emcp...@ptcnh.net> > Mike Cantwell <mcantw...@ieee.org> > > For policy questions, send mail to: > Jim Bacher: <j.bac...@ieee.org> > David Heald: <dhe...@gmail.com> ________________________________ Windows Live™: Keep your life in sync. Check it out. <http://windowslive.com/explore?ocid=TXT_TAGLM_WL_allup_1b_explore_032009> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@ptcnh.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@ptcnh.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com>
