Gert
<There is no requirement to use HS for EMC requirements under the RED > Indeed, but it implies that for the RED another compliance route need to be choosen (see annexes to the RED) I’m not sure what you mean by this statement – the manufacturer can follow Annex II and self declare where HS have been applied for article 3.2 (and 3.3 if applicable) irrespective of whether HS have been applied for Article 3.1(a) and (b) – this is laid out in Article 17. Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Gert Gremmen <[email protected]> Sent: 26 March 2022 10:02 To: [email protected] Subject: Re: [PSES] RED DoC and ETSI EN 301 489-1 <The various reports issued show the ETSI EN 301 489-1 V1.9.2 as one of the standards to which they were tested.> The trend is to not harmonise the -1 version of this (and other series) in the future, the -1 instead will be normatively referenced in any of the applied subparts, that WILL be harmonised (once approved). By normatively referencing, the referenced clauses from the -1 will be part of the "text with legal effect" in the subpart. <Although non-harmonised standards will not give presumption of conformity> This implies that you will need a third party to prove your compliance status i.e. a Notified Body for 2014/53/EU (art 3.2) <There is no requirement to use HS for EMC requirements under the RED > Indeed, but it implies that for the RED another compliance route need to be choosen (see annexes to the RED) The many subparts of EN 301 489 are on their way to harmonisation. However the process of creating standards (= adapting to EU requirements) is slow, and many stakeholders are involved. Since to-be-listed standards need up to 4 HAS-assessments each followed by a round of modifications at ETSI, each taking 3-9 months, the delays can be huge. (HAS is the EU-process where candidate HS are being scrutinized for their suitability to be listed. To a great part this comes down on verifying if the presented requirements can stand up in a legal sense, are exhaustive and precise, contain no duplicates to EU legislation, and are to the state of the art. In some cases a normatively referenced standard can block harmonisation if the referenced standard has severe deficiencies.) Gert Gremmen On 26-3-2022 9:21, T.Sato wrote: Although non-harmonised standards will not give presumption of conformity, -- Independent Expert on CE marking EMC Consultant Electrical Safety Consultant - ---------------------------------------------------------------- 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]>
