Products that have already been placed on the market (prior to implementation
of the new directive) require no change, but this is a piece-part
consideration, not a "product line" consideration.
As with several recent directive re-writes, the new EMCD has this interesting
phrase, "References to directive 89/63/EEC shall be construed as references to
this directive [i.e., 2004/108/EC] and should be read in accordance with the
correlation table set out in Annex VII" (article 14). I *believe* this allows
declarations to the old directive to be read as declarations to the new
directive, but, of course, you must meet the criteria of the new directive.
Note: There are some significant differences in the new directive that may
warrant attention, particularly regarding marks and information (article 9).
Lauren Crane (Mr.)
Product Regulatory Analyst
Corporate Product EHS Lead
Applied Materials Inc.
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"White, Ian" <[email protected]>
Sent by: [email protected]
05/16/2008 09:39 AM To
"IEEE Forum (E-mail)" <[email protected]>
cc
Subject
The New EMC Directive and the D of C
Can l have your views on the following please.
As l understand it all new Electronic products should now have their
Declaration of Conformities to the new EMC Directive 2004/108/EC, but products
already on the market can still quote the old Directive in their D of C's
It is a common practice for company's to take anther manufactures product and
put their company logo on - badge engineer it basically.
In the past they issued a D of C in their name, based on the other
manufacturers D of C.
During this change over period if a company wishes to badge engineer a
product, but the D of C is to the old Directive what should they do :
1) Write a D of C to the old Directive under the argument that product is in
the market already anyway - if only with a different name
2) Ask the supplier manufacturer for an updated D of C. There a small
differences between the two Directives.
Thanks for your help
Ian White
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