Hi Gert, Glad to have leant this new process behind and congratulate your contributions to these two groups!
However I have worries about the current status that is far behind the demand of HS. With this new step, further delay may be anticipated! Is there any ID to identify the standards have been gone thru this new process? Thanks and regards, Scott On 22 June 2018 at 19:38, Gert Gremmen <g.grem...@cetest.nl> wrote: > The EC has blocked all publications of HS for the directives, because of > legal problems. > > The main problem is that part of standards were not "written in stone", > and were therefore > > not suitable as legislative text. > > To share the work and create transparency a pool of experts has been > created, to verify and if possible approve > > new corrected versions of almost all standards, currently been > (re)-written by CENELEC and ETSI. > > If judged suitable, those standards will be presented to the EC for > publication in the OJ-C. > > The pool of experts has been created last month, and will soon start > working and it is expected > > that soon after the publication of standards under RED and LVD will resume. > > I have been appointed as one of those experts, for the RED and EMCD. > > Within the scope of RED both new versions EMC and new versions of LVD > standards will be published. > > Many ETSI standards are missing tests for receivers. So there is a lot of > changes coming to the market. > > Independent Expert on CE marking > Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC > EMC Consultant > Electrical Safety Consultant > > > > > On 22-6-2018 12:54, Scott Xe wrote: > > Hi Charlie, I am not fully catching up your points. Could you please give > some insights of the points highlighted below. Thanks! > > On 22 June 2018 at 00:28, Charlie Blackham <char...@sulisconsultants.com> > wrote: > >> Scott >> >> >> >> Sound and Broadcast receivers fall under the scope of the RED (it was one >> of the changes from the R&TTE Directive), as such: >> >> - They don’t fall under the EMC Directive >> - There are no longer HS for them under the EMC Directive - Scott: >> Are we sure EU has taken out all EMC HS re receivers? RED does not >> have enough HS for EMC without referencing to EMC HS. >> - There is now a HS for them under the RED - Scott: Currently only >> have one! What is correct practice for the field to select EMC standards? >> It is not governed by the NB review! >> >> >> >> Whilst you aren’t required to apply a Harmonised Standard, please note >> the requirement of Article 34 which applies if you are using a NB: >> >> >> >> Where a notified body finds that the essential requirements set out in >> Article 3 or corresponding harmonised standards or other technical >> specifications have not been met by a manufacturer, it shall require that >> manufacturer to take appropriate corrective measures and shall not issue an >> EU-type examination certificate or a quality system approval - Scott: >> Under RED, EU-type examination cert is required for article 3.2 only. Will >> the NB also look after 3.1a and b? >> >> >> >> So if you haven’t applied a listed Harmonised Standard and are requesting >> a Type Examination Certificate that covers article 3.1(b), then you need to >> show that the product has a level of EMC performance equivalent to the >> technical levels shown in the HS - Scott: Unless EN 55035 is a relax >> version of EN 55020, how can the manufacturer/test lab to show a level of >> EMC performance equivalent to the technical levels shown in the HS? >> >> >> >> Regards >> >> Charlie >> >> >> >> >> >> *Charlie Blackham* >> >> *Sulis Consultants Ltd* >> >> *Tel: +44 (0)7946 624317* >> >> *Web: **www.sulisconsultants.com* >> <https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> >> >> Registered in England and Wales, number 05466247 >> >> >> >> *From:* Scott Xe <scott...@gmail.com> >> *Sent:* 21 June 2018 16:58 >> >> *To:* EMC-PSTC@LISTSERV.IEEE.ORG >> *Subject:* Re: [PSES] RED products in EMC compliance part >> >> >> >> Pete, >> >> >> >> Both you and Charlie share the esteemed and fair opinions that using >> other than harmonised standards is not a wise decision although it is >> allowed by the directive. I have the same perception since we have no >> control in this route due to limited knowledge. Will see how to stick to >> harmonised standards. >> >> >> >> The test lab insisted on that EN 55020 is till valid in demonstrating EMC >> compliance although RED already has a new harmonised standard and it >> disappears in EMC list. So far both the test lab and we cannot find any >> support to this claim. >> >> >> >> Regards, >> >> >> >> Scott >> >> >> >> >> >> On 21 June 2018 at 23:18, Pete Perkins <peperkin...@cs.com> wrote: >> >> Scott et al, >> >> >> >> Charlie is right; no matter what promise you get from your >> 3rd party NB they are not in ultimate control. You, as manufacturer, >> are at the mercy of the regulators. It is important for you & your company >> to keep the heat on so that there is a reasonable expectation that the work >> that has been done will be acceptable moving ahead. >> >> >> >> :>) br, Pete >> >> >> >> Peter E Perkins, PE >> >> Principal Product Safety & Regulatory Affairs Consultant >> >> PO Box 23427 >> >> Tigard, ORe 97281-3427 >> >> >> >> 503/452-1201 >> >> >> >> IEEE Life Fellow >> >> p.perk...@ieee.org >> >> >> >> *From:* Scott Xe <scott...@gmail.com> >> *Sent:* Thursday, June 21, 2018 7:25 AM >> *To:* EMC-PSTC@LISTSERV.IEEE.ORG >> >> >> *Subject:* Re: [PSES] RED products in EMC compliance part >> >> >> >> Hi Charlie, >> >> >> >> Many thanks for your kind advice!! >> >> >> >> As the conformity review of this product is required by a NB, it is quite >> difficult to challenge their result due to their status but we can require >> them to issue a confirmation of continual compliance with the latest >> essential requirements of RED on the repeat orders. >> >> >> >> Regards, >> >> >> >> Scott >> >> >> >> On 21 June 2018 at 02:46, Charlie Blackham <char...@sulisconsultants.com> >> wrote: >> >> Scott >> >> >> >> I understand the issue you describe, however it should be remembered that: >> >> - The manufacturer is always responsible , whoever advises them. If >> they are going to ask a 3rd party (lab or consultant) then they >> should satisfy themselves that the advice is correct, perhaps by asking >> what the recommendation is based on. >> - A test lab cannot issue a “Declaration of Conformity” only a >> manufacturer (or suitably contracted representative) can do that – test >> labs should (only) issue “Certificates of Conformity” as a summary of test >> results, which are not the same thing >> - Copying someone else who got it wrong isn’t much of a defence >> >> >> >> In my experience, you should be prepared for challenges from market >> surveillance if you don’t apply Harmonised Standards (but whether you >> actually get challenged may be down to luck and whether your product type >> has been selected for market surveillance activity) >> >> >> >> Regards >> >> Charlie >> >> >> >> *Charlie Blackham* >> >> *Sulis Consultants Ltd* >> >> *Tel: +44 (0)7946 624317* >> >> *Web: **www.sulisconsultants.com* >> <https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> >> >> Registered in England and Wales, number 05466247 >> >> >> >> *From:* Scott Xe <scott...@gmail.com> >> *Sent:* 20 June 2018 17:31 >> *To:* Charlie Blackham <char...@sulisconsultants.com> >> *Cc:* EMC-PSTC@LISTSERV.IEEE.ORG >> *Subject:* Re: [PSES] RED products in EMC compliance part >> >> >> >> Hi Charlie, >> >> >> >> Understand that the manufacturer is free to choose any conformity >> assessment to meet the essential requirements for EMC without using a >> Notified Body. However the manufacturer must have expert in this area to >> provide the appropriate advice. Most of oem manufacturers lack of such >> luxury resource and reply on renowned test houses to do it for them. Can >> we use the declaration of conformity from the test lab for selecting the >> right test standards for EMC part even those standards are not in RED and >> EMC harmonized lists. Would we receive extra challenges from the market >> surveillances due to the fact that we use non harmonized standards. >> >> >> >> Thanks and regards, >> >> >> >> Scott >> >> >> >> On 21 June 2018 at 00:12, Charlie Blackham <char...@sulisconsultants.com> >> wrote: >> >> Scott >> >> >> >> EN 55035 is the (only) article 3.1(b) EMC standard that is Harmonised for >> broadcast receivers under the RED. >> >> >> >> As per RED article 17, the manufacturer is free to choose any conformity >> assessment to meet the essential requirements for EMC without using a >> Notified Body, but: >> >> - Your approach to EMC needs to be considered in your Risk Assessment >> (whether or not a Harmonised Standard is applied) >> - Market enforcement and customs would “expect” to see Harmonised >> Standards such as EN 55035:2017 listed on the DoC >> >> >> >> If the DAB radio contains Bluetooth then EN 301 489-1 and -17 would also >> apply, though these won’t be in the OJ until Q4 2017 or Q1 2018 >> >> >> >> Regards >> >> Charlie >> >> >> >> *Charlie Blackham* >> >> *Sulis Consultants Ltd* >> >> *Tel: +44 (0)7946 624317* >> >> *Web: **www.sulisconsultants.com* >> <https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> >> >> Registered in England and Wales, number 05466247 >> >> >> >> *From:* Scott Xe <scott...@gmail.com> >> *Sent:* 20 June 2018 16:05 >> *To:* EMC-PSTC@LISTSERV.IEEE.ORG >> *Subject:* [PSES] RED products in EMC compliance part >> >> >> >> Dear All, >> >> >> >> We have a DAB radio with BT speaker. It held NB a cert using EN 55032 : >> 2015, EN 55020 : 2007 + A12 : 2016, …. for EMC part compliance last >> year. Currently we are reviewing the continual compliance. It is >> discovered that both EN 55032 and EN 55020 disappears in the latest list of >> EMC harmonized standard list. In RED harmonized standard list, there is a >> new harmonized standard EN 55035. Is it in need of meeting EN 55035 : 2017 >> instead of EN 55020 : 2007 to maintain the continual compliance of RED? >> >> >> >> Thanks and regards, >> >> >> >> Scott >> >> - >> ---------------------------------------------------------------- >> >> 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) <http://www.ieee-pses.org/list.html> >> List rules: http://www.ieee-pses.org/listrules.html >> >> For help, send mail to the list administrators: >> Scott Douglas <sdoug...@ieee.org> >> 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) <http://www.ieee-pses.org/list.html> >> List rules: http://www.ieee-pses.org/listrules.html >> >> For help, send mail to the list administrators: >> Scott Douglas <sdoug...@ieee.org> >> 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) <http://www.ieee-pses.org/list.html> >> List rules: http://www.ieee-pses.org/listrules.html >> >> For help, send mail to the list administrators: >> Scott Douglas <sdoug...@ieee.org> >> 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) <http://www.ieee-pses.org/list.html> > List rules: http://www.ieee-pses.org/listrules.html > > For help, send mail to the list administrators: > Scott Douglas <sdoug...@ieee.org> > Mike Cantwell <mcantw...@ieee.org> > > For policy questions, send mail to: > Jim Bacher <j.bac...@ieee.org> > David Heald <dhe...@gmail.com> > > > -- > Independent Expert on CE marking > Harmonised Standards (HAS-) Consultant @ European Commission for RED and EMC > EMC Consultant > Electrical Safety Consultant > > - ---------------------------------------------------------------- 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 <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
