No EMC standard has been listed in the OJEU for 4 years now. The last (mini) change was on June 9, 2022, when an ETSI standard was withdrawn and a standard was replaced by a more up-to-date version.
Why is that?
Here are a few reasons:
- Alternative test methods are not desired by the EU Commission. As a result, EMC standards often fail because different measuring stations are considered equivalent in the standard.
- The description of the "performance criteria" in immunity tests must be so clear that the user/manufacturer has no room for interpretation in the evaluation. This is intended to provide a clear assessment of whether the test has been passed or not. The Commission has had this requirement for years (we reported on it in previous newsletters).
- Currently, no harmonized EMC standard has passed the HAS Assessment. This is often not the fault of the HAS consultants, but rather a mix of specifications from the EU Commission and the standards creators (IEC / CISPR).
- Almost all EMC standards (starting with 550xx or 6xxxx) are originally created by IEC and IEC-CISPR, the international standards bodies. The European Commission’s demands are not really being taken into account there. CENELEC is attempting to make corresponding changes to the IEC standards with the help of the EU annexes. This destroys international uniformity. However, it is also not possible to convince the EU Commission and the HAS consultants of the standards with the annexes.
- I don't want to go into the subject of the copyright of IEC and ISO standards in relation to the Malamud ruling of the European Court of Justice at this point. We will explain this in a more general way later.
The “performance criteria” are clearly described, making it evident that no current generic standards of the EN 61000-6-X series will be listed. The currently listed generic standards (obsolete) are to disappear from the OJEU (delisting). This has been expected for a few years now.
What are the consequences for manufacturers?
- The standards currently listed in the OJEU for the EMC Directive will no longer correspond to the state of the art once a successor standard has been published.
- A harmonized standard exists if it has been published on the basis of a mandate from the EU Commission, e.g. by CENELEC. Regardless of whether it is listed in the OJEU or not.
- Listing leads to a presumption of conformity for the product and to a reversal of evidence in the event of an inspection by the market surveillance authorities. Listing in the OJEU is worthless if the state of the art is not achieved with the standard listed in the OJEU because a successor standard has already been published.
- The manufacturer must use the risk assessment to demonstrate that the standards he uses (regardless of the listing) meet the essential requirements of the EMC Directive (emitted interference and immunity). This may make the justification in the risk assessment somewhat more detailed.
Note:
The EMC risk assessment has been mandatory for a product since the EMC Directive 2014/30/EU came into force.
Outlook:
No listing of a current EMC standard in the OJEU is expected in the next few months. Therefore, we recommend applying the current state of the art.
We will keep you up to date and will be happy to provide you with further details.
Author's note
This article has been machine translated into English.
TERMS AND ABBREVIATIONS
CEN, CENELEC and ETSI are the three EU standard organizations (ESO)
Standards = norms
