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I thought I would include this in my Q&A series. I have been receiving these questions often,
“Do you expect that a new EMC directive will be coming ?”
“What impact may it have on my current test plan or program ?”
The answer to part one is yes, and it could be very soon. As part of the “Goods package”, the current EMC directive, 204/108/EC, is being amended in what is called an alignment with the New Legislative Framework of the European Union (or NLF). The EMC directive is part of what is called an “Alignment Package”. Eight other directives will also be processed in this alignment.
On the second question, the first thing to note is that the new approach directives are not technical in nature, but rather legal documents. Think of them as the “Law” of the land on the topics they cover. How you comply with the laws are another matter. The technical aspects are primarily addressed by Harmonised Standards or “EN” specifications. So, the EMC technical requirements, i.e. your testing, should not be impacted by this amendment to the EMC directive. While it is expected that the scope of the EMC directive will remain essentially the same, anytime that a directive comes up for amendment, interested parties look at it as an opportunity to address issues they may want included, see for example my post on cables being proposed: http://www.emcrules.com/2011/12/ready-made-connecting-devices-cables.html
The areas that would see significant change are;
- your documents (Declaration of Conformity) will change.
- A new directive number may require documents be modified, such as test reports, however there should be a reasonable transition period.
- Traceability requirements and product labeling, with specific identifying information on each product.
- Economic operators must keep records of supplier and distributor (already required for consumer goods)
- New supply chain duties, harmonized across the EU.
- Enforcement authority will be able to target more directly those infringing due to supply chain reporting requirements.
- Expectation is that Post market surveillance activities could increase substantially (this is one of the main points of the “Goods Package”)
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/* COM/2011/0763 final */ (Alignment of ten technical harmonisation directives to Decision No 768/2008/EC)
Proposals to Align Nine Directives with the New Legislative Framework – Published by BIS Department for Business Innovation & Skills