Re: Philosophy for old designs with new requirements.
There have been several good comments regarding DOW's for standards. However, since you're looking for 'legal' ammunition, I'll take a shot at it ;) The comments below attempt to show a paper trail, starting with the Directive, and ending with the latest standard available. - The fact that you have to comply the EMC Directive is in Article 3, which says that apparatus placed on the market has to comply with the Directive. - 'Placed on the market' refers to individual units, not to a model series or a product type. This is clarified in the EMC Guidelines, available at http://www.emc-journal.co.uk/newguide.html - One of the methods for demonstrating compliance with the Directive is in Article 7, paragraph 1a. It says you can follow the standards listed in the Official Journal. A list of the standards published (possibly not up-to-date) is at http://europa.eu.int/comm/enterprise/newapproach/standardization/harmstds/reflist/emc.html - Notable in this reference list is the heading of the right-most column: Date of cessation of presumption of conformity of the superseded standard. This means that you can't claim compliance with the EMC Directive using the superseded standard (second column from the right) after that date. For a good display of superseded and current standards, look at EN55011 (RF emissions for ISM equipment). There's been enough activity over the years that you can see standards, what it superseded, and when you had to stop using the superseded standard (to claim compliance to the EMC Directive). Corrections from list members appreciated. Patrick Lawler plaw...@west.net -Original Message- From: don_macart...@selinc.com Sent: Monday, June 19, 2000 1:07 PM To: emc-p...@majordomo.ieee.org Subject: Philosophy for old designs with new requirements. I would appreciate some feedback on the following: Let's say I have several existing designs which meet the requirements for CE Marking today (EMC Safety). What is the requirement for these existing designs when a new standard comes out, let's say six months from now? I think the older designs must be re-designed to meet the new requirements or not be sold into the EU. Is this true? What ammunition is out there for me to prove this fact to the higher-ups? --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Philosophy for old designs with new requirements.
Dear friends, As far as the validity of European Standards ( harmonized standards) concerns, not the DOW or other dates are valid, but -with the exclusion of all other dates- the ones on the most recent list of harmonized standard as published in the European Official Journal (OJ/C) , lastly published on 7-April-2000. And yes, older designs need to comply (most often) within 2 years after publishing the reference to it in the OJ. Normally this is not such a hassle as it look like. A good quality product will almost always meet new requirements, unless they are fully new tests. In that case, most of the time a product that fails to comply will meet problems in the field too. After all, immunity requirements are there to solve performance problems as can be met in real life. Sometimes a product fails, because of some non-applicability of a test to a specific equipment, most often caused by a product accidentally falling within the scope of a standard that was not written for. Then a TCF route with a competent body may resolve your problems. Note that competent bodies are required to accept tests performed by yourself, provided they are credible. So no investment is lost. I doubt however that the citation is meant the way it was suggested. The number of tests would overwhelm the CB's capacity very quick. The procedure of self certification is one of the routes as defined in the blue guide and used in many directives that are concerned with customer risk much more then EMC. Take f.a. the LVD and MDD directive. The route chosen in the new RTTE directive is even more liberal towards this regime. Basically only frequency selection (harmonization) is left over to a notified body, the application of harmonized TTE-standards is voluntarily. Regards, Gert Gremmen, (Ing) ce-test, qualified testing P.S. this list is downloadable in .PDF format on the link below. === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === -Original Message- From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf Of geor...@lexmark.com Sent: Tuesday, June 20, 2000 6:01 PM To: emc-p...@majordomo.ieee.org Subject: RE: Philosophy for old designs with new requirements. Don asked: I would appreciate some feedback on the following: Let's say I have several existing designs which meet the requirements for CE Marking today (EMC Safety). What is the requirement for these existing designs when a new standard comes out, let's say six months from now? I think the older designs must be re-designed to meet the new requirements or not be sold into the EU. Is this true? What ammunition is out there for me to prove this fact to the higher-ups? Don, In my experience, one cannot predict whether new standards will allow existng products to be forever grandfathered under previous standards, or required to meet the new standard immediately, or some grace period after which compliance to the new standard is required. The allowances are made known by the time the standard is placed in force. This decision is often what slows the introduction of new standards as all affected parties lobby for what best suits their products. Products with relatively short market lifetimes are not usually impacted by new standards. However, products with long market lifetimes may require a re-design to meet the end of the grace period for new standards. Fortunately, our products typically fall into the first category, with market lifetimes of a year or so. George Alspaugh Lexmark International Inc. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org attachment: Gert Gremmen.vcf
RE: Philosophy for old designs with new requirements.
Don asked: I would appreciate some feedback on the following: Let's say I have several existing designs which meet the requirements for CE Marking today (EMC Safety). What is the requirement for these existing designs when a new standard comes out, let's say six months from now? I think the older designs must be re-designed to meet the new requirements or not be sold into the EU. Is this true? What ammunition is out there for me to prove this fact to the higher-ups? Don, In my experience, one cannot predict whether new standards will allow existng products to be forever grandfathered under previous standards, or required to meet the new standard immediately, or some grace period after which compliance to the new standard is required. The allowances are made known by the time the standard is placed in force. This decision is often what slows the introduction of new standards as all affected parties lobby for what best suits their products. Products with relatively short market lifetimes are not usually impacted by new standards. However, products with long market lifetimes may require a re-design to meet the end of the grace period for new standards. Fortunately, our products typically fall into the first category, with market lifetimes of a year or so. George Alspaugh Lexmark International Inc. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Philosophy for old designs with new requirements.
Don, The new standards have associated with them a date known as the Date of Withdrawal (DoW). That is the date on which the presumption of conformity to the essential requirements of the applicable directive (in this case, the EMC Directive) is withdrawn for the old standards. Any product imported or placed into service in the EC as of that date must have been tested to the new standards. If it is an older product, it must be re-tested. The DoW for EN 55022:1998 is 1 August 2001. The DoW for EN 55024:1998 is 1 July 2001. These are ITE standards. I'm not sure if there are others that apply to your products. BTW, I'll be in Pullman this weekend if you want to discuss this personally. Ghery Pettit Intel Corporation -Original Message- From: don_macart...@selinc.com [mailto:don_macart...@selinc.com] Sent: Monday, June 19, 2000 1:07 PM To: emc-p...@majordomo.ieee.org Subject: Philosophy for old designs with new requirements. I would appreciate some feedback on the following: Let's say I have several existing designs which meet the requirements for CE Marking today (EMC Safety). What is the requirement for these existing designs when a new standard comes out, let's say six months from now? I think the older designs must be re-designed to meet the new requirements or not be sold into the EU. Is this true? What ammunition is out there for me to prove this fact to the higher-ups? Thank you, Don --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Philosophy for old designs with new requirements.
Hello Don, As I understand it, once a standard has been replaced (reached it's DOW), product bearing the CE marking and intended for shipment to the EU must meet the requirements of the new standard. This almost always involves some degree of product redesign. I've found that this is also a good time to include product improvements / upgrades that may be in the works. As far as ammunition goes, if you list or certify your product with an agency (UL, TUV, etc) you should receive notification calling for a product re-evaluation. Take Care, George -Original Message- From: don_macart...@selinc.com [mailto:don_macart...@selinc.com] Sent: Monday, June 19, 2000 4:07 PM To: emc-p...@majordomo.ieee.org Subject: Philosophy for old designs with new requirements. I would appreciate some feedback on the following: Let's say I have several existing designs which meet the requirements for CE Marking today (EMC Safety). What is the requirement for these existing designs when a new standard comes out, let's say six months from now? I think the older designs must be re-designed to meet the new requirements or not be sold into the EU. Is this true? What ammunition is out there for me to prove this fact to the higher-ups? Thank you, Don --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
Re: Philosophy for old designs with new requirements.
For EMC, if you have demonstrated compliance with the EMC Directive via the technical construction file route, you probably don't need to be concerned with new standards. You should check with the competent body that assessed the file. However, if you have demonstrated compliance with the EMC Directive by testing to the harmonized standards that apply to your product, then you do have to comply with any new standards if your product falls under their scope. This also applies to revisions of existing standards. There is a transition period for each new or revised standard that can be found in the front of the standard. The date of withdrawal (DOW) of conflicting standards is the date by which your product must comply with the new or revised standards. Jim Hulbert Pitney Bowes don_macart...@selinc.com on 06/19/2000 04:06:58 PM Please respond to don_macart...@selinc.com To: emc-p...@majordomo.ieee.org cc:(bcc: Jim Hulbert/MSD/US/PBI) Subject: Philosophy for old designs with new requirements. I would appreciate some feedback on the following: Let's say I have several existing designs which meet the requirements for CE Marking today (EMC Safety). What is the requirement for these existing designs when a new standard comes out, let's say six months from now? I think the older designs must be re-designed to meet the new requirements or not be sold into the EU. Is this true? What ammunition is out there for me to prove this fact to the higher-ups? Thank you, Don --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
