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 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?!?!? 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. Ok, I'll stop whining now. Jim Eichner, P.Eng. Regulatory Compliance Manager Xantrex Technology Inc. e-mail: [email protected] web: www.xantrex.com <http://www.xantrex.com>
Any opinions expressed are those of my invisible friend, who really exists. Honest. No really. Confidentiality Notice: This email message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. -----Original Message----- From: Alan E Hutley [mailto:[email protected]] Sent: Wednesday, September 25, 2002 11:43 PM To: Emc-Pstc Discussion Group Subject: EMC Prosecution in UK EMC Prosecution, the company mentioned in the report Hot UK Ltd is owned by Helen of Troy based in El Paso Texas. For full story go click below <http://www.compliance-club.com/TS%20Prosecution.doc> http://www.compliance-club.com/TS%20Prosecution.doc Alan E Hutley EMC Compliance Journal www.compliance-club.com <http://www.compliance-club.com>
