Scott et al,
Charlie is right; no matter what promise you get from your 3rd
party NB they are not in ultimate control. You, as manufacturer, are at the
mercy of the regulators. It is important for you & your company to keep the
heat on so that there is a reasonable expectation that the work that has been
done will be acceptable moving ahead.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201
IEEE Life Fellow
<mailto:[email protected]> [email protected]
From: Scott Xe <[email protected]>
Sent: Thursday, June 21, 2018 7:25 AM
To: [email protected]
Subject: Re: [PSES] RED products in EMC compliance part
Hi Charlie,
Many thanks for your kind advice!!
As the conformity review of this product is required by a NB, it is quite
difficult to challenge their result due to their status but we can require them
to issue a confirmation of continual compliance with the latest essential
requirements of RED on the repeat orders.
Regards,
Scott
On 21 June 2018 at 02:46, Charlie Blackham <[email protected]
<mailto:[email protected]> > wrote:
Scott
I understand the issue you describe, however it should be remembered that:
* The manufacturer is always responsible , whoever advises them. If they
are going to ask a 3rd party (lab or consultant) then they should satisfy
themselves that the advice is correct, perhaps by asking what the
recommendation is based on.
* A test lab cannot issue a “Declaration of Conformity” only a
manufacturer (or suitably contracted representative) can do that – test labs
should (only) issue “Certificates of Conformity” as a summary of test results,
which are not the same thing
* Copying someone else who got it wrong isn’t much of a defence
In my experience, you should be prepared for challenges from market
surveillance if you don’t apply Harmonised Standards (but whether you actually
get challenged may be down to luck and whether your product type has been
selected for market surveillance activity)
Regards
Charlie
Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web:
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f>
www.sulisconsultants.com
Registered in England and Wales, number 05466247
From: Scott Xe <[email protected] <mailto:[email protected]> >
Sent: 20 June 2018 17:31
To: Charlie Blackham <[email protected]
<mailto:[email protected]> >
Cc: [email protected] <mailto:[email protected]>
Subject: Re: [PSES] RED products in EMC compliance part
Hi Charlie,
Understand that the manufacturer is free to choose any conformity assessment to
meet the essential requirements for EMC without using a Notified Body. However
the manufacturer must have expert in this area to provide the appropriate
advice. Most of oem manufacturers lack of such luxury resource and reply on
renowned test houses to do it for them. Can we use the declaration of
conformity from the test lab for selecting the right test standards for EMC
part even those standards are not in RED and EMC harmonized lists. Would we
receive extra challenges from the market surveillances due to the fact that we
use non harmonized standards.
Thanks and regards,
Scott
On 21 June 2018 at 00:12, Charlie Blackham <[email protected]
<mailto:[email protected]> > wrote:
Scott
EN 55035 is the (only) article 3.1(b) EMC standard that is Harmonised for
broadcast receivers under the RED.
As per RED article 17, the manufacturer is free to choose any conformity
assessment to meet the essential requirements for EMC without using a Notified
Body, but:
* Your approach to EMC needs to be considered in your Risk Assessment
(whether or not a Harmonised Standard is applied)
* Market enforcement and customs would “expect” to see Harmonised
Standards such as EN 55035:2017 listed on the DoC
If the DAB radio contains Bluetooth then EN 301 489-1 and -17 would also apply,
though these won’t be in the OJ until Q4 2017 or Q1 2018
Regards
Charlie
Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web:
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f>
www.sulisconsultants.com
Registered in England and Wales, number 05466247
From: Scott Xe <[email protected] <mailto:[email protected]> >
Sent: 20 June 2018 16:05
To: [email protected] <mailto:[email protected]>
Subject: [PSES] RED products in EMC compliance part
Dear All,
We have a DAB radio with BT speaker. It held NB a cert using EN 55032 : 2015,
EN 55020 : 2007 + A12 : 2016, …. for EMC part compliance last year. Currently
we are reviewing the continual compliance. It is discovered that both EN 55032
and EN 55020 disappears in the latest list of EMC harmonized standard list. In
RED harmonized standard list, there is a new harmonized standard EN 55035. Is
it in need of meeting EN 55035 : 2017 instead of EN 55020 : 2007 to maintain
the continual compliance of RED?
Thanks and regards,
Scott
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