Scott, I’m not quite that hard-nosed on this issue. I have recommended that manufacturer’s choose the best available path knowing that the EU bureaucrats will move the goal posts again on us. So I would say, use harmonized standards when it is clear that they are designated to apply else use tried and true methods when there is confusion and wait for clarity from the system.
:>) 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 8:58 AM To: Pete Perkins <[email protected]> Cc: [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] <mailto:[email protected]> > wrote: 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] <mailto:[email protected]> > Sent: Thursday, June 21, 2018 7:25 AM To: [email protected] <mailto:[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 - ---------------------------------------------------------------- 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] <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] <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]>
