Hi Nick,

You are completely correct.

Actually, this approach (NB is only needed for deviations in testing to 
Articles 3.2 and 3.3; but not needed for deviations in testing for 3.1) was 
apparently the original intention with 1999/5/EC, but it was not correctly or 
clearly written.   2014/53/EU corrects that.

Thanks,

Michael.



-----Original Message-----
From: Nick Williams [mailto:nick.willi...@conformance.co.uk] 
Sent: 04 January 2017 12:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Conformity assessment under RED

Happy New Year, EMC-PSTC listers!

2014/15/EU article 17 separates the conformity assessment procedures for 
essential requirement 3.1 (safety and EMC) from those which are applied for 
essential requirements 3.2 and 3.3 (spectrum efficiency and special 
provisions). Notified Body intervention is required for ER’s 3.2 and 3.3 if the 
manufacturer has not applied harmonised standards, but no such requirement is 
applied for ER 3.1. 

My reading of this is that the manufacturer has complete freedom of approach 
under RED for safety and EMC compliance in exactly the same way that they do 
under the LVD and EMC Directive, and can self-certifiy even if they do not 
apply harmonised standards, irrespective of whether or not they are required to 
involve a NoBo for compliance with ER’s 3.2 & 3.3. 

This is not how things worked under 1999/5/EC. 

Is my interpretation correct, and if not, why not?

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