In asking whether the 4 year transition period apply
to products already deemed compliant I presume our
RCIC guest means product designs. The EMC directive
does not have any grandfathering of old designs. The
directive refers to individual items of equipment. That item
must meet current requirements on the date that
it is first supplied irrespective of whether it is the
first of a new design or the latest item from a long
standing production run.
It may be sold second hand thereafter
without having to meet newer requirements.
However some of the harmonised standards have
been issued with 'certification clauses' which do
refer to new items made to old designs that were
certified to previous standards or versions of standards
and give a later date by which such items must
comply with the new standard or version. The Commission
has come down very firmly against any form of certification
clause and insists that harmonised standards, like the
directive must apply only to individual items and not
refer to to previously produced items. This is the basis
of the Commissions refusal to publish ammendment A12
to EN61000-3-2 in the OJ discussed at some length in
another thread.
In a recent agreement between CENELEC, who draw up
the standards, and the Commission the so called
'Memorandum 6' was revised in a way which would
abolish certification clauses and apply a uniform
transition period of 4 years by setting the appropriate
date of withdrawal of conflicting standards (dow).
Strictly speaking this only applies to new versions
of old standards and does not apply to new product
or product family standards that take equipment out of
the scope of the generics of to cases where, as in
EN61000-3-2 the scope of the standard has been
widened to take in equipment outside the scope of the
old version. There was some expectation that this
principal would apply more broadly but if EN55103-2 & -3
are eventually published with a dow of 1 Mar 1997 and
listed in the OJ obviously this is not so.
Nick Rouse
