As per Directive 2004/108/EC, Annex III, the involvement of Notified Bodies in drafting the Declaration of Conformity (DoC) is now voluntary for all EMC assessment cases.
The tasks of the Competent Body, as introduced in the old EMC Directive 89/336/EEC, have now been merged with those of the Notified Body (NB). In the new EMC Directive 2004/108/EC, the competences of the NB have been restricted to being an advisory institution. As well, the involvement of NBs in drafting the Declaration of Conformity (DoC) is now voluntary for all EMC assessment cases, as per Annex III of the new Directive.
This measure gives more freedom to the manufacturer or to the signer of the DoC. They are now allowed to create and apply their individual method of conformity assessment without involving the NB. However, they will also have to prove that their individual conformity assessment meets the safety requirements of the EMC Directive. They must also keep the documentation available for national reviewing authorities. This entails a significant increase in paperwork for cases where harmonized standards were not previously applied.
This new freedom results in a more stringent market control by national authorities with respect to products which are not assessed against harmonized standards. A new directive aimed at harmonizing and improving market control within Europe is underway. As a result, manufacturers and DoC signers are advised to involve an NB or at least a reliable certification body to help increase the credibility of their DoCs.
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