Don, Two options exist for demonstrating compliance with the essential requirements of the EMC Directive. You can create a Technical Construction File with a Competent Body or you can test to the harmonized requirements applicable for the product you are selling. If you go the TCF file, you can do whatever you and the CB agree upon. If you test to the harmonized standards, then you must test to all of them and re-test when they change. The DOW is the date on which the old standard is no longer presumed to show compliance with the applicable essential requirement of the Directive. All products placed on the market in the EU must be shown to be in compliance with the current harmonized requirements.
Now, in the case that you bring up, if you can show that the standard to which the product was previously qualified was more stringent than the new one, you might have a case for not retesting. However, seldom is the new standard different from the old only in the test level. Typically test methods and technical details of how the test is run will change, making a direct comparison of the two standards difficult. For example, EN 50082-1:1992 (the old generic immunity standard for everything except heavy industrial environments) used IEC 801-3 for radiated immunity and had one test at 3 V/m. No modulation. Level on a field probe placed by the EUT (no location specified) in any facility you cared to use (bare shielded room, semi-anechoic chamber, fully anechoic chamber, your father-in-law's cow pasture). EN 55024:1998 (ITE specific immunity standard) uses IEC 61000-4-3. You still test at 3 V/m, but add modulation to the signal (80% at 1 kHz). It is now a pre-calibrated field (w/o modulation) with a certain uniformity of the field required. You must now use a fully anechoic chamber, or a semi-anechoic chamber with absorbers on the floor between the EUT and antenna. A far more repeatable test. How would you compare the two? I don't think you can reasonably do so. The addition of modulation on the signal changes things radically. Bottom line - I would test. We did for all products remaining in production past the cutoff dates for the new ITE standards this summer. Ghery Pettit Intel -----Original Message----- From: [email protected] [mailto:[email protected]] Sent: Thursday, November 29, 2001 10:14 AM To: Pettit, Ghery Cc: [email protected] Subject: RE: Revised EMC standards and CE Declarations. Ghery, Is it a absolute must to test? If you have reasonable justification that your products are compliant (the new requirement is wimpy), why not just document your reasoning and continue to sell product after the DOW? Regards, Don "Pettit, Ghery" <[email protected]> on 11/27/2001 02:09:59 PM Please respond to "Pettit, Ghery" <[email protected]> To: "'[email protected]'" <[email protected]>, [email protected] cc: (bcc: Don MacArthur/SEL) Subject: RE: Revised EMC standards and CE Declarations. Jason, You are correct. All products placed on the market in the EU must be tested to the latest standard once the magic date (DOW) for the new standard is reached. Also, keep in mind that if a product specific standard is published it takes precedence over the generic standard and the generic standard no longer applies to the product family. For example, EN 55024:1998 is the product specific immunity standard for ITE, so EN 50082-1:1997 is not used for these products. This is one more example of why I refer to the EMC Directive as The EMC Professionals Employment Act of 1989. Ghery Pettit, NCE Intel Corporation -----Original Message----- From: [email protected] [mailto:[email protected]] Sent: Tuesday, November 27, 2001 1:10 PM To: [email protected] Subject: Revised EMC standards and CE Declarations. Hi all. EN 50082-1:1992 was replaced by EN 50082-1:1997. According to the newapproach.org website, from 1/7/2001 the old version no longer allows one to presume conformity to the EMC Directive. Does this mean I need to retest all equipment to the new standard before I can declare conformance? My guess is YES. Thanks in advance for any confirmation or correction. -Jason Product Safety Consultant -- __________________________________________________________________ Your favorite stores, helpful shopping tools and great gift ideas. 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