Hi Charlie, I am not fully catching up your points. Could you please give some insights of the points highlighted below. Thanks!
On 22 June 2018 at 00:28, Charlie Blackham <[email protected]> wrote: > Scott > > > > Sound and Broadcast receivers fall under the scope of the RED (it was one > of the changes from the R&TTE Directive), as such: > > - They don’t fall under the EMC Directive > - There are no longer HS for them under the EMC Directive - Scott: Are > we sure EU has taken out all EMC HS re receivers? RED does not have > enough HS for EMC without referencing to EMC HS. > - There is now a HS for them under the RED - Scott: Currently only > have one! What is correct practice for the field to select EMC standards? > It is not governed by the NB review! > > > > Whilst you aren’t required to apply a Harmonised Standard, please note the > requirement of Article 34 which applies if you are using a NB: > > > > Where a notified body finds that the essential requirements set out in > Article 3 or corresponding harmonised standards or other technical > specifications have not been met by a manufacturer, it shall require that > manufacturer to take appropriate corrective measures and shall not issue an > EU-type examination certificate or a quality system approval - Scott: > Under RED, EU-type examination cert is required for article 3.2 only. Will > the NB also look after 3.1a and b? > > > > So if you haven’t applied a listed Harmonised Standard and are requesting > a Type Examination Certificate that covers article 3.1(b), then you need to > show that the product has a level of EMC performance equivalent to the > technical levels shown in the HS - Scott: Unless EN 55035 is a relax > version of EN 55020, how can the manufacturer/test lab to show a level of > EMC performance equivalent to the technical levels shown in the HS? > > > > 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 <[email protected]> > *Sent:* 21 June 2018 16:58 > > *To:* [email protected] > *Subject:* Re: [PSES] RED products in EMC compliance part > > > > Pete, > > > > Both you and Charlie share the esteemed and fair opinions that using other > than harmonised standards is not a wise decision although it is allowed by > the directive. I have the same perception since we have no control in this > route due to limited knowledge. Will see how to stick to harmonised > standards. > > > > The test lab insisted on that EN 55020 is till valid in demonstrating EMC > compliance although RED already has a new harmonised standard and it > disappears in EMC list. So far both the test lab and we cannot find any > support to this claim. > > > > Regards, > > > > Scott > > > > > > On 21 June 2018 at 23:18, Pete Perkins <[email protected]> wrote: > > Scott et al, > > > > Charlie is right; no matter what promise you get from your 3 > rd 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 > > [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]> > 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: **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 <[email protected]> > *Sent:* 20 June 2018 17:31 > *To:* Charlie Blackham <[email protected]> > *Cc:* [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]> > 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: **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 <[email protected]> > *Sent:* 20 June 2018 16:05 > *To:* [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 > > - > ---------------------------------------------------------------- > > 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) <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]> > Mike Cantwell <[email protected]> > > For policy questions, send mail to: > Jim Bacher <[email protected]> > David Heald <[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) <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]> > Mike Cantwell <[email protected]> > > For policy questions, send mail to: > Jim Bacher <[email protected]> > David Heald <[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) <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]> > Mike Cantwell <[email protected]> > > For policy questions, send mail to: > Jim Bacher <[email protected]> > David Heald <[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]>
