I read in !emc-pstc that Jim Eichner <[email protected]> wrote (in <67C475A5ECE7D4118AEC0002B325CAB603510EDA@BCMAIL1>) about 'FW: EMC Prosecution in UK' on Thu, 26 Sep 2002:
>I read this article with some consternation, since in my mind it challenges >not the manufacturer or importer, but the concept of Presumption of >Conformity (I'll use PofC...). > >Quote: "If the standard in question only covers some of the EM phenomena, >or is limited in its scope, then full compliance cannot be guaranteed. The >products thus failed the essential protection requirements and were >incorrectly CE marked". > >I am in strong disagreement with that statement. If the standard in >question only covers some of the EM phenomena, then the standard in question >does NOT provide PofC and should NOT have been published in the OJ or on the >Europa site as a harmonized standard under the EMC Directive. It is not the >manufacturer's fault if the EU incorrectly publishes references in the OJ >implying PofC where there are essential requirements not covered. In my >mind, the CE Mark was correctly applied by the mfr, and the fault lies with >EN55014 (which I have always thought is flawed) and with the EU/CEN Neither EU or CEN, but CENELEC, adopting CISPR 14. This is the umpteenth edition of CISPR 14 and, AFAIK, it's never been found inadequate before. > for >issuing a standard that fails to provide PofC. > >Am I right or am I delusional, naive, misinformed, an idealist, or all of >the above?!?!? No, you are right, and I intend to expand on that point in my column in 'EMC and Compliance Journal'. > >At the very least, it seems to me that the EU has an obligation to provide >more information. If a standard is listed as applicable to the EMC >Directive and does not provide PofC, then the standard's preamble and the >Europa listing should say so, and should point out which essential >requirements are not addressed, and which standards should be used to cover >the missing requirements. I am getting extremely tired of the "let the mfr >figure it out" approach used by the EU. The obligation is the other way round, actually, on the member states, not the Commission. A national authority that doesn't think an EMC standard is adequate should take action under Article 8 of the Directive. There is a similar provision in the Low Voltage Directive, and the French government used it last year to block the notification of an EN in the Official Journal. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk Interested in professional sound reinforcement and distribution? Then go to http://www.isce.org.uk PLEASE do NOT copy news posts to me by E-MAIL! ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: [email protected] Dave Heald: [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
