Charlie,
They are using the “test to harmonized standards” route. Read the original post. That said, as you note, EN 55022 is no good after March 5, 2017. I doubt they want to change approaches to meeting the essential requirements in the EMC Directive, so showing compliance with EN 55032 will then become necessary. Note in an earlier post I mentioned that it might not be necessary to re-test. Indeed, for many products all that will be necessary is to get the lab to amend the report, or issue some sort of documentation, showing that the previous testing to EN 55022 has shown compliance with EN 55032. No new testing and away they go. Ghery From: Charlie Blackham [mailto:char...@sulisconsultants.com] Sent: Wednesday, October 19, 2016 1:34 AM To: Ghery S. Pettit; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] Working towards compliance as per the EN 55032 Ghery Ø How do you figure that? Because there are a number of options permitted in the Directive so that route is not mandatory Ø If they are using testing to harmonized standards as the means for issuing the DoC, after 5 March 2017 EN 55022 is of no use Indeed it would be – but other options are available and the manufacturer may wish to consider them for legacy products and they don’t necessarily need to be re-tested. Regards Charlie From: Ghery S. Pettit [mailto:n6...@comcast.net] Sent: 19 October 2016 06:16 To: Charlie Blackham; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] Working towards compliance as per the EN 55032 How do you figure that? If they are using testing to harmonized standards as the means for issuing the DoC, after 5 March 2017 EN 55022 is of no use. Anything placed on the market (not just manufactured) as of that date must have been evaluated against EN 55032. To the original poster – it’s the date a product is placed on the market in the EU, not the date of manufacture. If it takes a while for a product to get from manufacturing to the market you need to start a bit earlier. Ghery From: Charlie Blackham [mailto:char...@sulisconsultants.com] Sent: Tuesday, October 18, 2016 1:56 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Working towards compliance as per the EN 55032 > What is not correct? The statement “Products leaving the factory after that must meet EN 55032” Is not correct There is no requirement for that anywhere. Regards Charlie From: John Woodgate [mailto:jmw1...@btinternet.com] Sent: 18 October 2016 21:50 To: Charlie Blackham; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] Working towards compliance as per the EN 55032 A simple, undefined assertion is of no value. What is not correct? With best wishes DESIGN IT IN! OOO – Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Charlie Blackham [mailto:char...@sulisconsultants.com] Sent: Tuesday, October 18, 2016 9:31 PM To: John Woodgate <jmw1...@btinternet.com>; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] Working towards compliance as per the EN 55032 Your previous comment….. >From: John Woodgate [mailto:jmw1...@btinternet.com] >Sent: 18 October 2016 18:24 >To: EMC-PSTC@LISTSERV.IEEE.ORG >Subject: Re: [PSES] Working towards compliance as per the EN 55032 >Yes, the docopocoss for EN 55022 is 5 March 2017. Products leaving the factory >after that must meet EN 55032. …was simple, but it wasn’t correct Regards Charlie From: John Woodgate [mailto:jmw1...@btinternet.com] Sent: 18 October 2016 20:38 To: Charlie Blackham; EMC-PSTC@LISTSERV.IEEE.ORG Subject: RE: [PSES] Working towards compliance as per the EN 55032 Mediaeval scholars used to answer any question by beginning with the Creation. I think that answers should be kept strictly simple and not explore the whole Universe. With best wishes DESIGN IT IN! OOO – Own Opinions Only <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and Associates Rayleigh England Sylvae in aeternum manent. From: Charlie Blackham [mailto:char...@sulisconsultants.com] Sent: Tuesday, October 18, 2016 8:13 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Working towards compliance as per the EN 55032 Rajneesh Please note, compliance with EN 55032 is not “required” after March 2017 any more than EN 55022 is “required” now – it might be heavily recommended, but it is not “required”. A Harmonised Standard: · Provides a presumption of Conformity with a Directive · Is what market enforcement authorities “expect to see” (and is what I would typically recommend that you apply) The legal requirement is to comply with the Directive and the Directive does provide more than one way to do that. The other thing to note, is that a presumption of conformity is obtained when a Harmonised Standard is “applied” and not “tested against”. You may find that an analysis of your test set-up and results allow you to make a technical justification that the product meets 55032, so you can “apply” the new standard without necessarily having to re-test The responsibility remains with the manufacturer and not with the test lab – they should be expert at testing, but it is the manufacturer who must demonstrate compliance with the Directive. Regards Charlie From: Rajneesh Raveendran [mailto:000008500acb6cd4-dmarc-requ...@ieee.org] Sent: 18 October 2016 17:46 To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Working towards compliance as per the EN 55032 Hi All For all our new programs, we would be testing for compliance as per the EN 55032 standard. But i have one question about some legacy products that we would continue to ship to our customers post March 2017. All these products have been tested as per the EN 55022 and if i am not wrong, there is no "grandfather clause" that provides any exemption. My question relates to whether all those products would now need to be tested as per EN 55032? Regards, Rajneesh - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> 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://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com> - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> 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://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com> - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> 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://www.ieee-pses.org/list.html (including how to unsubscribe) <http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com> - ---------------------------------------------------------------- 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 <emc-p...@ieee.org> 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://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>