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Topic Title: EMC compliance - retrospective
Topic Summary: Is EMC compliance ever retrospective for existing products
Created On: 28 February 2014 10:19 AM
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 28 February 2014 10:19 AM
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Joined: 25 July 2008

I am currently comparing BSEN61326-1:2006 and 2013 to see if my employers declaration of conformity can simply be updated to 2013. The main changes are specified in the 2013 document and can be observed in comparison - all well and good. Some of our more recent products (2012 onwards) have EMC test certificates showing testing to the 2013 levels meaning we can state compliance.

Older products (some pre 2006) are not tested to this standard but passed the tests for the standards at the time. There have been no technical changes to the products so they still comply with the old test standards. What I want to know is would the declaration of conformity listing BSEN61326-1:2013 be allowable for older products or would I have to state the old standards also?

I appreciate any comments.
 05 March 2014 06:47 PM
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If they only conform to the old standard then you need to quote the old standard, you can't quote them as conforming to the current standard unless they do conform to that standard!

BUT you do not necessarily need to retest to the new standard to show compliance to it, if you can build an argument that you are happy to defend that:

testing to the old standard + ( an assessment of the differences x an argument that the old equipment meets those differences ) = compliance to the new standard

then you can declare to the new standard quoting your Technical Construction File where you present this evidence along with your previous test results.

Good luck! And sorry for the slow reply, I very rarely look at these forums now.

Andy Millar CEng MIET CMgr MCMI

"The aim of argument, or of discussion, should not be victory, but progress." Joseph Joubert
 08 March 2014 01:10 PM
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To add to Andy's answer.

The requirement in the directive is to "apply" the standard not "test to" the standard.
I would suggest doing a requirement by requirement comparison of test levels.
The main differences to look out for in these standards are ESD test levels and Magnetic Field immunity - though only certain product types would really ever suffer a problem in a high magnetic field.

Whilst listing current Harmonised Standards on a DoC is not mandatory - it "only" gives you a presumption of conformity - it does give you a presumption of conformity.
More importantly customs officers appear to be taking a rather simplistic view of "current Harmonised Standard GOOD, old standard BAD" - so rather than risk product getting stopped and having to explain to someone who doesn't understand, why your DoC is actually OK, it is much easier to keep Technical Files and DoCs in line with current Harmonised Standards.


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