Maybe my explanation was a bit too brief. CENELEC specifies the dow, but
the Commission can assert a different date - the docoposs - which is
what matters for establishing conformity.
If a standard has not been notified in the OJ, and therefore does not
support regulation, the dow is just an instruction to national standards
committees to withdraw any conflicting national standard. Manufacturers
can, perhaps unwisely, continue to apply a standard beyond the dow date
in the superseding standard.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-03-04 12:51, Scott Xe wrote:
Hi John,
Thanks for your clarification! A lot of people will take the dow in
EN standard as the deadline, especially the standard has not been put
in OJEU or conflicts with OJEU. EN standard is EN Norm. What is
wrong to take this approach? Is there any official guidance to
clarify it?
Regards,
Scott
*From:*John Woodgate <[email protected]>
*Sent:* Friday, 1 March 2019 12:43 AM
*To:* [email protected]
*Subject:* Re: [PSES] RoHS standard change...
Strictly speaking, transition periods are not specified in CENELEC
standards, Instead, the mythical animal Docopocoss is specified (Date
Of Cessation Of Presumption Of Conformity Of the Superseded Standard)
is specified. Even more strictly, CENELEC specifies that, but the
Commission can overrule it.
IEC standards sometimes include a recommended transition period in the
Foreword (which no-one ever reads), but it's purely advisory.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK
On 2019-02-28 13:35, Matthew Wilson wrote:
Thank you John, that is most helpful to know that transition
periods run from the date of publication of the new standard.
Don’t know why I didn’t actually have concrete knowledge of that
but it makes sense.
Matthew Wilson,
Technical Director,
GB Electronics (UK) Ltd.
*From:*John Woodgate <[email protected]> <mailto:[email protected]>
*Sent:* 27 February 2019 17:36
*To:* Matthew Wilson <[email protected]>
<mailto:[email protected]>;
[email protected] <mailto:[email protected]>
*Subject:* Re: [PSES] RoHS standard change...
The site you mention has the answer:
/In setting the necessary technical documentation requirements, EN
IEC 63000 is *almost identical *to the text of EN 50581, even if
any wording specific to the EU RoHS Directive has been removed: it
aims at addressing different substance regulations worldwide while
ensuring the same approach from manufacturers everywhere. The
normative references of EN 50581:2012 were updated in EN IEC 63000
in order to reflect the latest international development of
analytical test methods and material declaration.
EN 50581:2012 is a harmonised standard meaning that its
application gives presumption of conformity with the requirements
of the RoHS Directive. Considering that a large number of products
on market are referring to it in their Declaration of
Conformity,*a transition period of 5 years (60 months) *has been
granted for manufacturers to adapt before EN IEC 63000:2018
supersedes EN 50581:2012. In practice this means that during this
transition period both standards will coexist, allowing the
manufacturers to smoothly migrate to EN IEC 63000:2018. /
Transition periods run from the date of publication of the new
standard, so 50581 is presumably usable until 2023. But you would
be well advised to look at the new standard well before then,
maybe in 2021, in case the first edition has acquired any
amendment or corrigendum.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK
On 2019-02-27 16:59, Matthew Wilson wrote:
I see that BSI now state that EN 50581:2012 is marked as
Status : Superseded, Withdrawn
https://shop.bsigroup.com/ProductDetail?pid=000000000030261478
and states it is replaced by: BS EN IEC 63000:2018, Technical
documentation for the assessment of electrical and electronic
products with respect to the restriction of hazardous substances
The harmonised list on the EU website still states 'EN
50581:2012 Technical documentation for the assessment of
electrical and electronic products with respect to the
restriction of hazardous substances'
https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/restriction-of-hazardous-substances_en
What one should I put in a declaration of conformity to be
issued this week? The product in question has been assessed
for RoHS compliance using the principles and our copy of EN
50581:2012.
It appears the two are probably identical according to the
link below and we've just missed there's going to be a change
(it's hard for SME like us to keep abreast of all the changes
and that before any Brexit implications! Anyone any hints on
that?) although the article talks about 60 month transition
period but not actually what the actual timescale is!
https://www.cencenelec.eu/news/brief_news/Pages/TN-2019-009.aspx
Thanks for any pointers.
Regards,
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GBE <https://gbelectronics.uk>
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