Good Morning Charlie,
Indeed, there is a different regime in art 17 for conformance to article
3.1 (a) (safety) and 3.1 (b) (emc) , and 3.2 (radio) and 3.3 (others)
I overlooked the word EMC. Noted.
To resume, Art 17 describes the conformance procedures:
3.1 a) Annex I + reasonable foreseeable conditions
3.1 b) Annex I
3.2 Annex I if HS otherwise annex III or IV
3.3 Annex I if HS otherwise annex III or IV
Note that as ageneral rule when NO HS are applied for 3.1 a) or b) art
16 denies the presumption of conformity principle, which obliges the
manufacturer to obtain proof of conformity with an additional means.
In addition, Annex V requires additional : "descriptions of the
solutions applied " (under (d) ) for non HS parts.
Gert
On 26-3-2022 21:43, Charlie Blackham wrote:
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/* <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
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