Can I just up-issue my Declaration of Conformity to show compliance against the New Directive?

Analyse if product meets the latest harmonised EMC standards,

If standards to which product was previously tested are out of date then a comparison needs to be made for each individual test to determine if there are now more onerous requirements (for example your product may not meet all of the requirements for Radiated Immunity due to increases in frequency ranges for test and some test levels)

Depending on the results of this gap analysis it might be possible to base compliance upon technical rationale. If not then further testing may be required.

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