You are correct Carl. The device always needs to be 'assessed' to the latest 'requirements'.
...and the easiest way to do this, is to 'test' to the latest 'standard'. If they are following the harmonised standard route, then they will need to show compliance with EN 300 328 V1.8.1 before December 2014. (Some tests will need re-testing) If they do not wish to do that, then they will need to go to a Notified Body for an opinion because they will no longer have the luxury of "presumption of conformity" because the standard listed on their DoC will no longer be the harmonised one (from December 2014). Of course, if they do go to a Notified Body with their old results (V1.7.1) and ask for an opinion to the new requirements (V1.8.1), then the Notified Body should ask for some justification. You don't need to test to harmonised standards when you go to a Notified Body, but the Notified Body should be asking for some justification for compliance, which is typically equivalent to the latest harmonised standards. Most likely, the Notified Body would ask them to demonstrate how it would meet the V1.8.1 requirements. J You're right that there's no certification for Europe on R&TTE equipment. It's all DoC, to the latest requirements. So, I think you are right. The lab and manufacturer seem like they are wrong. Michael. Michael Derby Regulatory Engineer ACB Europe From: Carl Newton [mailto:[email protected]] Sent: 15 July 2013 17:02 To: [email protected] Subject: [PSES] Grandfathered ETSI standards for CE Marking? Group, I'm in a debate with a lab and a manufacturer that insist that a R&TTE device doesn't need to be re-evaluated against a new revision standard when the previous is withdrawn. ETSI EN 300 228 V1.7.1 loses the presumption of conformity in 2014 (December I think). Customer is installing a ZigBee component within his ITE device and wishes to apply the ZigBee transceiver compliance to his device. I've argued that revision V1.8.1 which is listed in the OJ must be applied after the DoW. Both the ZigBee component manufacturer and the test lab involved argue that once a device is "certified" that retesting is not necessary. I've double-checked the Blue Guide and I believe that their interpretation is not correct and that after the DoW the current revision listed in the OJ must be stated on the DoC. Safety in numbers, looking for a sanity check here. Thanks, Carl - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
