American Association for Laboratory Accreditation R322 – SPECIFIC REQUIREMENTS – NOTIFIED BODY ACCREDITATION REQUIREMENTS Document Issued: January 4, 2016 Page 1 of 4 On November 23, 2015, the National Institute of Standards and Technology (NIST) released requirements for United States Conformity Assessment Bodies (CABs) seeking Notified Body (NB) status for the European Union Radio Equipment Directive (RED) 2014/53/EU, Annex III (Module B: EU-Type Examination) and Electromagnetic Comparability (EMC) Directive 2014/30/EU, Annex III – Part A (Module B: EU-Type Examination). The role of the NB under Module B is to examine a manufacturer’s technical documentation and supporting evidence to verify and attest that the technical product design meets the relevant European Union (EU) legislative requirements. The NB then writes an evaluation report (that may be released only upon agreement with the manufacturer), and issues an EU-Type Examination Certificate. The manufacturer maintains the EU-Type Examination Certificate in the technical documentation that supports its Declaration of Conformity. When the manufacturer is assessing compliance of radio equipment under the essential requirements covered by the Radio Equipment Directive (RED) Articles 3.2 and 3.3, and when harmonized standards (as published in the Official Journal of the European Union) are (1) applied only in part, (2) available but not applied, or (3) are not available – per RED Article 17.4, the manufacturer is required to use an NB. In all other cases (such as when the manufacturer has used the harmonized standards in full), use of an NB is voluntary. Under the Electromagnetic Compatibility (EMC) Directive, use of an NB is voluntary. PART A INTRODUCTION NIST’s Requirements & Application for U.S. Conformity Assessment Bodies Seeking EU Radio Equipment Directive (RED) 2014/53/EU Notified Body Status and Requirements & Application of U.S. Conformity Assessment Bodies Seeking Electromagnetic Compatibility (EMC) Directive 2014/30/EU Notified Body Status, Section 4 states “The CAB shall obtain formal accreditation for its Notified Body activities.” A2LA is recognized to accredit NBs for the RED and EMC Directive. Since there is no transition period for the new EMC Directive (2014/30/EU), the notifications of all current EMC Directive (2001/108/EC) NBs expire on April 19, 2016. Therefore, it will be necessary to obtain A2LA accreditation and then re-apply to NIST to be notified to the European Commission (hereafter referred to as Commission) as an NB under the new EMC Directive. There is a one year transition period for the RED but NIST will not withdraw the NB status of the Radio and Telecommunication Terminal Equipment (R&TTE) Directive NBs until the end of the transition period. During the transition year between June 2016 and June 2017, there will be two separate lists – the NBs notified to the R&TTE Directive under the old process, and the new NBs notified under the RED. Accreditation applies for RED only, not for the R&TTE Directive. L:\Requirements\R322 – Specific Requirements – Notified Body Accreditation Requirements American Association for Laboratory Accreditation R322 – SPECIFIC REQUIREMENTS – NOTIFIED BODY ACCREDITATION REQUIREMENTS Document Issued: January 4, 2016 Page 2 of 4 PART B CONDITIONS FOR ACCREDITATION In order to attain and maintain accreditation, NBs must comply with A2LA R102 Conditions for Accreditation published by A2LA. PART C A2LA ACCREDITATION PROCESS All applicants must agree to comply with R102 - Conditions for Accreditation (see Part B of this document), pay the appropriate fees (including surcharges, where applicable), and provide detailed supporting information. For further information, refer to F309 - Application for Accreditation: ISO-IEC 17065 Product Certification Bodies (see Part D of this document Option I), F301 - Application for Accreditation: ISO-IEC 17020 Inspection Bodies (see Part D of this document - Option II), or F101 - Application for Accreditation: ISO-IEC 17025 Laboratories (see Part D of this document - Option III). PART D Specific Program Requirements NIST Requirements for CABs seeking EU NB status are publically available on the NIST website. Section 4 of NIST’s Requirements & Application for U.S. Conformity Assessment Bodies Seeking EU Radio Equipment Directive (RED) 2014/53/EU Notified Body Status and Requirements & Application for U.S. Conformity Assessment Bodies Seeking EU Electromagnetic Compatibility (EMC) Directive 2014/30/EU Notified Body Status outline the NB accreditation requirements. The Blue Guide identifies the following two basic conformity assessment standards as the most appropriate for Module B Assessments: ISO/IEC 17020 (Inspection Body Accreditation) or ISO/IEC 17065 (Product Certification Body Accreditation). EA-2/17 INF: 2014 further specifies that for Module B, supplemental (secondary basic standard requirements) apply as follows: Option I – ISO/IEC 17065:2012 Accreditation plus the following secondary basic standard requirements: o ISO/IEC 17025:2005 Section 5 o ISO/IEC 17020 Clauses 6.1.2, 6.1.3, and 6.1.6 through 6.1.10 (Ability to make professional judgements related to product requirements where required.) Option II – ISO/IEC 17020:2012 Accreditation plus the following secondary basic standard requirements: o ISO/IEC 17025:2005 Section 5. L:\Requirements\R322 – Specific Requirements – Notified Body Accreditation Requirements American Association for Laboratory Accreditation R322 – SPECIFIC REQUIREMENTS – NOTIFIED BODY ACCREDITATION REQUIREMENTS Document Issued: January 4, 2016 Page 3 of 4 Option III – ISO/IEC 17025:2005 Accreditation plus the following secondary basic standard requirements: o ISO/IEC 17065:2012 Clauses 4.1, 7.5, and 7.6 (Capability of and procedures for judging and deciding based on results of tests, if the essential requirements are fulfilled and/or the Harmonized Standards have been applied where required.) CABs accredited by A2LA to ISO/IEC 17020 or ISO/IEC 17065 that wish to seek NB Status can apply to NIST under the processes covered in RED Article 29.2 and/or EMC Directive Article 27.2. The notification process is simplified in these cases, with minimal information needing to be forwarded to the Commission. The Commission’s decisions will normally take two weeks if there are no objections from Member States. CABs accredited by A2LA to ISO/IEC 17025 (only) that wish to seek NB Status must follow alternative paths listed below for notification, since this basic conformity assessment standard is not considered sufficient on its own for Module B (per The Blue Guide). The alternative paths are described in RED Article 29.3 and EMC Directive Article 27.3. These alternative paths include the following additional steps: o Submittal of key NB application documentation by NIST to the Commission for review by Member States; o Longer Commission decision process for initial NB notification (two months if no objections are expressed by Member States after review of NB information) (RED Article 30.5 and EMC Directive Article 28.5). ISO/IEC 17025 accreditation ensures that the NB will be monitored regularly (RED Article 30.4 and EMC Directive Article 28.4). Under this option, NIST requires that the ISO/IEC 17025 Scope of Accreditation contains the NB activities and reference to EA-2/17 INF: 2014 (providing it references ISO/IEC 17025 for Module B). Refer to EA 2/17 Annex A, Description of the Accreditation Scope of NBs. 1. NIST – Radio Equipment Directive CABs seeking NB status for the RED shall meet the requirements of NIST’s Requirements & Application for U.S. Conformity Assessment Bodies Seeking EU Radio Equipment Directive (RED) 2014/53/EU Notified Body Status, in addition to the requirements of European Union Radio Equipment Directive 2014/53/EU. The NB will be evaluated against A2LA C322a - Specific Checklist: Notified Body Accreditation Requirements – Radio Equipment Directive. 2. NIST – Electromagnetic Compatibility (EMC) Directive CABs seeking NB status for the EMC Directive shall meet the requirements of NIST’s Requirements & Application for U.S. Conformity Assessment Bodies Seeking EU Electromagnetic Compatibility (EMC) Directive 2014/30/EU Notified Body Status, in addition to the requirements of European Union Electromagnetic Compatibility Directive 2014/30/EU. The NB will be evaluated against A2LA C322b - Specific Checklist: Notified Body Accreditation Requirements – Electromagnetic Compatibility Directive. L:\Requirements\R322 – Specific Requirements – Notified Body Accreditation Requirements American Association for Laboratory Accreditation R322 – SPECIFIC REQUIREMENTS – NOTIFIED BODY ACCREDITATION REQUIREMENTS Document Issued: January 4, 2016 Page 4 of 4 APPENDIX A - Document Revision History Date 01/04/2016 Description - Initial Release 2016 by A2LA All rights reserved. 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