Editor’s Note: The following reply was received from Keith Armstrong, EMC consultant in the UK, to a news item we ran in the May 12th newsletter regarding complying with the new EMC Directive. We welcome reader comments to our articles.
Armstrong writes,
“I see lots of test labs publishing over-simplified guidance on complying with the new EMC Directive, including the one by [a test lab] in ITEM’s latest Newsletter.
They need to read it properly, and also widen their scope to look at the changes that will occur when the RED replaces R&TTE.
However, even people who have reviewed the RED in articles in ITEM and other trade mags have also missed an important issue:
From 12 July 2017, if your product has an embedded radio function (bluetooth module) it will have to declare its compliance to the essential requirements of the EMCD, LVD, and RED using only RED-listed harmonised standards!
Unless all the hundreds of current EMCD and LVD standards are quickly “dual-listed” in the OJEU under RED, this is going to cause huge problems.
Also there are new requirements for:
a) The Technical Documentation to include an adequate assessment of the risks of causing EMI or suffering from it;
b) Every “economic operator” in the supply chain to bear / share the responsibility for EU compliance
(This could mean sharing confidential information with importers, distributors, etc.)
c) Manufacturers name and address to be indelibly marked on the product (or that of his Authorised Rep.)
d) The names and addresses of all importers and distributors in the supply chain to be marked on the product
e) Perhaps the most important immediate change: the use of a specified format and wording in the DoC, and a single DoC covering all applicable Directives – effective from 20 April 2016. Products may well be being disallowed entry to the EU at this very moment simply because they don’t use this specified DoC!”
