Bob - While I agree that they are product standards - if a more appropriate product standard contains overlapping requirements then (my opinion) that standard would take precedence. This is why I think that if your product falls under the scope of a product-specific standard such as EN 61326 and EN 300 386 that addresses AC current harmonics and voltage fluctuations you do not need to apply the 61000-3-2,3 standards as listed in the OJ, only the requirements of your more-specific product standard.
Mark From: [email protected] [mailto:[email protected]] On Behalf Of [email protected] Sent: Monday, October 05, 2009 1:02 AM To: [email protected] Subject: RE: Mains harmonics & flicker test equipment To make matters a bit more complicated, EN 61000-3-2 and EN 61000-3-3 are Product Family Standards in their own right (says so on page 5 of both standards). The family class being I suppose equipment with input current 16 A or less. In this case the standard in the OJ applies no matter what. Bob Heller 3M EMC Laboratory, 76-1-01 St. Paul, MN 55107-1208 Tel: 651- 778-6336 Fax: 651-778-6252 ============================================================================ ==== From: "Spencer, David H" <[email protected]> To: "Mark Briggs" <[email protected]>, <[email protected]> Date: 10/02/2009 06:48 PM Subject: RE: Mains harmonics & flicker test equipment Sent by: <[email protected]> Mark, I agree with you. Possibly I'm making a mountian out of a mole-hill. My question seems to be that if a standard is listed in the OJ that must take precedence over an older similar standard within the product specific standard. In this case the scope of EN 61000-3-2:XXXX, is products rated less than or equal to 16A. Regardless of any product specific standard that criteria takes precedence. EN61000-3-2:XXXX is not a generic standard. It is a requirement for all products that connect to low voltage distribution systems in the EU. Dave From: [email protected] on behalf of Mark Briggs Sent: Fri 10/2/2009 7:18 PM To: Spencer, David H; [email protected] Subject: RE: Mains harmonics & flicker test equipment David - This has been my take on this issue: If your product-specific standard addresses a phenomenon that is also addressed in a generic standard then you do not have to apply that generic standard. When the product specific standard uses a generic or product standard as a measurement standard you use that referenced standard just as you would any other basic standard (e.g. the EN 61000-4-x series of standards, none of which are listed in the OJ). You only concern yourself with testing to the version referenced by your product standard. In this particular case we are talking about EN 61000-3-2 and -3, but the list of product/generic standards that may be in the OJ but that are also used as basic standards includes EN 55022 and EN 55011. For example: EN 300 386 and EN 61326 both address emissions related to AC current harmonics, therefore I do not have to use EN 61000-3-2 (the "generic" standard for AC current harmonics) as listed in the OJ, or reference it on the DoC. This assumes that I have applied the requirements for AC current harmonics detailed in the product standard using the methods referenced within my product standard. EN 55022, on the other hand, does not address emissions related to AC current harmonics so I need to apply the EN 61000-3-2 standard as referenced in the OJ, and list both standards on my DoC. Mark From: [email protected] [mailto:[email protected]] On Behalf Of Spencer, David H Sent: Friday, October 02, 2009 3:11 PM To: ce-test, qualified testing bv - Gert Gremmen; John Woodgate; [email protected] Subject: RE: Mains harmonics & flicker test equipment Gert, I'm not a legal expert by any means. However, if a product is placed on the market in the EU and accompanied with a DoC, isn't it implied that the product meets the legal requirements specified by CENELEC? If CENELEC specifies that a product class must meet a given standard (EN or IEC), doesn't that make it legally binding if that product is place on the market? The standard being the de facto binding document that the DoC is based upon. I am still a bit confused as to why if in the OJ, a give standard is referenced, that an older standard may be applied if referenced by a product specific standard? I could give hypothetical examples; yet, it seems at though anything listed within the OJ takes legal precedence, regardless of additional product specific requirements. I should point out that in EN61326-1:2006, Annex ZA (NORM), Note 2 specifies EN61000-3-2:2006 as the applicable standard, though it's not in Section 2. Regards, Dave Spencer Xerox Corp. From: [email protected] on behalf of ce-test, qualified testing bv - Gert Gremmen Sent: Fri 10/2/2009 3:36 PM To: John Woodgate; [email protected] Subject: RE: Mains harmonics & flicker test equipment John Standards are private products, and there should not be a "legally" reference in your reply. Standards are binding agreements between civil parties only, and private parties may agree to use old standards. If CENELEC states that a standard has been withdrawn, so what ? If the older standard is useful as an agreement between parties, that's ok. If the European Committee agrees with that is another story; the EC might conclude that the docopocossed standard gives no presumption of conformity anymore, and that opinion is reflected legally in the OJ only, regardless dow, dopocoposs or other dates. In the case of EN 61326, being harmonized at date of application, referring to EN 61000-3-2:2000, gives presumption of compliance. At the same time EN 61000-3-2:2006 (if harmonized at the same date) gives presumption of compliance too. The fault is in EN 61326-1:2006 standard, but such Faults are not uncommon. Again, IEC nor CENELEC create legally binding documents (unless agreed upon by contract between parties). Gert Gremmen Van: [email protected] [mailto:[email protected]] Namens John Woodgate Verzonden: vrijdag 2 oktober 2009 14:59 Aan: [email protected] Onderwerp: Re: Mains harmonics & flicker test equipment In message <78eac2d97114034eb62aaa10fcc251060a8d8...@usa7061ms01.na.xerox.net>, dated Fri, 2 Oct 2009, "Spencer, David H" <[email protected]> writes: >"IF" there was a dramatic change between the two, for a proper DoC >would both versions need to be applied? No; the new version supersedes the old at the docopocoss, and legally the old EN (but not the old IEC version) ceases to exist. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk Things can always get better. But that's not the only option. John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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