Jim, Was this for an EMCD issue, or other? The reason I ask is I think that only the EMCD explicitly presses for keeping up with state of the art in its essential requirements (e.g., LVD and MD do not). Which might mean that an insistence on latest-and-greatest is reasonable for EMC standards. Of course it's also possible for Customs to simply ask for what they want regardless of its basis in a directive or national law.
2014/30/EU (recast EMC Directive) emphasis added: "ANNEX I ESSENTIAL REQUIREMENTS 1. General requirements Equipment shall be so designed and manufactured, having regard to the *state of the art*, as to ensure that:..." Regards, Lauren Crane KLA-Tencor -----Original Message----- From: Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: Thursday, July 31, 2014 2:18 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Definition of unsafe product A little different problem than Mr. Xe is experiencing, but we recently had a product stopped at Customs in an EU country because the Declaration of Conformity supplied with the product did not call out the latest amendment to an applicable harmonized standard. We had previously performed an assessment to the latest amendment and determined no impact on our product, so quickly drew up a new Declaration to reference the latest amendment. This was insufficient to Customs. They required us to also provide evidence that we had done that assessment. We had no choice but to comply and provide the evidence because we couldn't afford to have this shipment held up any longer. My point here is that I think Customs overstepped their authority. Jim Hulbert ________________________________ - ---------------------------------------------------------------- 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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
