Scott > The knowledge and experience of each manufacturer vary markedly It does, and that of test labs, and that of consultants :)
Harmonised Standards are not compulsory under EMCD or LVD - they provide for a “presumption of conformity”, and they’re very often the best option, but manufacturers can choose other options. One of the issues is that anything with a “radio” capability is now under the RED, which includes items such as an internet connected fridge, washing machine, or any other household appliance and there is no desire or intent to make the RED list of HS a combined list of the standards under RED, EMC and LV. CENELEC have just published some new EMF/SAR standards for the RED which should go in the OJ shortly, but at the moment for EMC and safety manufacturers need to decide an appropriate course of action and document the reasons why. This might be to look at lists of Harmonised Standards for other directives such as EMC or LV; or it might be to look at latest published standards that are appropriate for their product; or it might be some other option that is justified on the basic of the product and its intended use. That said: * Simplistically, the vast majority of EMC standards call up about 3 emissions limits and 3 immunity test levels * Whilst safety standards might vary between exact spacing requirements for BASIC insulation, they generally all have requirements for fundamental issues such as protection against electric shock, burn, energy, fire, sharp edges etc. * BUT….everyone is very used to Harmonised Standards, including customs and market enforcement so it will be interesting to see what issues are being faced by manufacturers and importers moving forward Regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> Registered in England and Wales, number 05466247 From: Scott Xe [mailto:[email protected]] Sent: 30 October 2017 13:53 To: Charlie Blackham <[email protected]>; [email protected] Subject: Re: [PSES] EN 301 489-1 and RED Hi Charlie, Is there any condition for that a manufacturer is free to choose any standards for demonstrating compliance with article 3(1), safety and EMC. The knowledge and experience of each manufacturer vary markedly. I am at loss on what basis, how can EU allow the manufacturer to choose a standard freely? Thanks and regards, Scott From: Charlie Blackham <[email protected]<mailto:[email protected]>> Reply-To: Charlie Blackham <[email protected]<mailto:[email protected]>> Date: Monday, 30 October 2017 at 3:15 PM To: <[email protected]<mailto:[email protected]>> Subject: Re: [PSES] EN 301 489-1 and RED Amund No, a manufacturer is free to choose any standards for demonstrating compliance with article 3(1), safety and EMC. It is only where Harmonised Standards for article 3(2) and article (3) standards have not been followed that a Notified Body must be used. This is detailed in Article 17 of the RED (As an aside, this was also the intent in the R&TTE, but not actually what the R&TTE said) Regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> Registered in England and Wales, number 05466247 From: Amund Westin [mailto:[email protected]] Sent: 30 October 2017 06:59 To: [email protected]<mailto:[email protected]> Subject: [PSES] EN 301 489-1 and RED EN 301 489-1 v2.2.0 is still not listed as a harmonized RED standard. I see a lot of DoCs with EN 301 489-1 v2.2.0 included, but none of the DoC owners have a EU-Type examination certificate in addition. I assume it is still a requirement to consult a Notified body and get a EU-Type examination certificate when using a non-harmonizes standard. Right? Mvh Amund - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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To post a message to the list, send your e-mail to <[email protected]<mailto:[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://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 <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[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://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 <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher: <[email protected]> David Heald: <[email protected]>
