John
 
One thing to remember for the EU is that manufacturers are required to APPLY
current harmonised standards, not TEST to them. You can, in theory, test, or
not test, to whatever you like.

"Apply" isn't really defined anywhere - one suggested definition (that I
think I saw posted here) is along the lines of "you can consider to have
fully applied a harmonised standard if your product would pass when tested
against it"

The easiest way to Apply a standard for most products is to test against it.
:)

However, Technical files can be used to:
- justify why, for example, product complies with basic standard EN61000-4-8
magnetic field immunity without need for test. 
- discuss Delta requirements in revisions of Product/Generic standards
calling up new basic standards, and what testing, if any, is needed to
demonstrate compliance with updated product/generic standard

Regards
Charlie


From: John Barnes [mailto:jrbar...@iglou.com] 
Sent: 11 December 2009 05:43
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Effective Dates for EMC Standards

EMC-PSTC'ers,
Here is a question that has been bugging me for some months--

Given an electromagnetic compatibility (EMC) or electromagnetic
interference (EMI) standard (edition & amendments) that applies to a
product:
*  When may we start testing products to the standard?
*  When must we start testing products to the standard?
*  When do we have a choice of testing products to the standard OR a
   later standard?
*  When must we stop testing products to the standard?

In short, during what period may we claim compliance to EMC requirements
by testing to the standard, and listing it in the declarations of
conformity (DoC's) for products?


I realize that various nations and market areas may have different
policies in this regard.

I was told some years ago that we usually have a two-year transition
period, from when an EMC/EMI standard or regulation comes out, until we
are required to use it.  But is this documented anywhere for:
*  United States' FCC Part 15?
*  Canada's ICES-003?
*  Australia/New Zealand AS/NZS standards?
*  Japan VCCI standards?


The question comes up because ANSI C63.4-2009 and Amendment A1:2007 to
EN 55022:2006 are seriously changing how we measure Radiated Emissions
above 1GHz.  This is akin to amendment A1:2000 to EN 55022:1998, which
required putting ferrite clamps/ferrite tubes on power cords and some
signal cables for Radiated Emissions testing of tabletop products. 
(This requirement was finally removed in EN 55022:2006, but it caused
the DOCOPOCOSS for EN 55022:1998 and its amendments to be delayed six
years.)


For the European Union (EU) we can refer to the most-recent list of
Harmonized Standards under the EMC Directive 2004/108/EC (see below):
*  If the standard (& its amendment(s)) are listed, we may test to it, 
   and list it in the product's DoC.
*  Once we reach the Date of cessation of presumption of conformity of 
   the superseded standard (DOCOPOCOSS), we *must* test to the standard.
*  We must test only to the standard until a superceding standard 
   appears on the list.
*  We must stop testing to the standard, and revise our DoC's, once we 
   reach the DOCOPOCOSS of the superceding standard.

The best way I've found to see if the EU has published a new list of
Harmonized Standards is:
1.  Go to   http://eur-lex.europa.eu/RECH_mot.do
2.  Type "2004/108/EC" in the Search for box, and hit Enter. 
3.  Look for results that start with "Commission communication in the 
    framework of the implementation of Directive 2004/108/EC ..."
4.  Click on "pdf" below the item, to see it exactly as it was 
    published.


Thanks!

John Barnes KS4GL, PE, NCE, NCT, ESDC Eng, ESDC Tech, PSE, SM IEEE
dBi Corporation
http://www.dbicorporation.com/

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