Carl

You're correct, and there's no such thing as "certification" for the EU.

The relevant part of the Directive are:

Article 10
Conformity assessment procedures
4. Where a manufacturer has applied the harmonised standards referred to in 
Article 5(1), radio equipment not within the scope of paragraph 3 shall be 
subject to the procedures described in any one of Annexes III, IV or V at the 
choice of the manufacturer.
5. Where a manufacturer has not applied or has only applied in part the 
harmonised standards referred to in Article 5(1), radio equipment not within 
the scope of paragraph 3 of this Article shall be subject to the procedures 
described in either of Annexes IV or V at the choice of the manufacturer.

If you haven't used a Harmonised Standard (which must of course be current at 
the point in time that particular product is placed on the market), you must 
use a Notified Body. And for Annex IV, a NB should follow R&TTECA guidance, 
which says (in effect) Harmonised Standards should generally be used where 
possible. . . .

The important thing though is the word "apply". It may well be that a Zigbee 
device compliant with V1.7.1 would actually need little or no actual "testing" 
in order to be compliant with V1.8.1, but an "assessment" must be done and 
documented.

Regards
Charlie




From: Carl Newton [mailto:[email protected]]
Sent: 15 July 2013 17:02
To: [email protected]<mailto:[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previous is withdrawn.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
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