{
  "type": "problem",
  "slug": "test-report-outdated",
  "lang": "en",
  "url": "https://www.conphora.com/solutions/problem/test-report-outdated/",
  "markdown": "https://www.conphora.com/solutions/problem/test-report-outdated.md",
  "title": "Our test report refers to a withdrawn standard",
  "description": "When the standard behind a test report is replaced or its reference withdrawn, the manufacturer must take the change into account. What to check and redo.",
  "answer": "The low voltage, EMC and radio directives require manufacturers to take changes in the harmonised standards adequately into account and to keep the declaration of conformity continuously updated. The presumption of conformity attaches to standards whose references are published in the Official Journal. Compare the old and new editions, close the gaps by assessment or re-testing, and update the technical file and the declaration.",
  "theme": {
    "id": "documentation",
    "label": "Documentation and declarations"
  },
  "roles": [
    {
      "id": "manufacturer",
      "label": "Manufacturer"
    }
  ],
  "regulations": [
    "LVD",
    "EMC",
    "RED"
  ],
  "path": [
    "regulation-library",
    "product-validation"
  ],
  "trigger": "A customer, a test lab or a notified body points out that the standard in your test report has been replaced or its reference withdrawn",
  "keep": null,
  "why": [
    {
      "text": "A test report is evidence against a specific edition of a standard. When that edition changes, the evidence ages. The Low Voltage Directive 2014/35/EU requires manufacturers to have procedures so that series production remains in conformity, and to take adequately into account changes in the harmonised standards, the international or national standards, or other technical specifications by reference to which conformity is declared (Article 6(4)). The EMC Directive 2014/30/EU says the same in Article 7(4). The Radio Equipment Directive 2014/53/EU does so in Article 10(5).",
      "sources": [
        1,
        2,
        3
      ]
    },
    {
      "text": "The legal weight of a standard comes from publication. Equipment that conforms to harmonised standards whose references have been published in the Official Journal is presumed to conform to the requirements those standards cover (Directive 2014/35/EU Article 12; Directive 2014/30/EU Article 13; Directive 2014/53/EU Article 16). Regulation (EU) No 1025/2012 governs those references. The Commission publishes a reference where a harmonised standard satisfies the requirements it aims to cover (Article 10(6)). After a formal objection it may decide to maintain, maintain with restriction or withdraw a reference (Article 11(1)(b)), and it publishes information on those decisions on its website (Article 11(2)). When a standard is revised, the Commission's implementing decision for the act withdraws the old reference, and it can defer the withdrawal. For the low voltage directive, Implementing Decision (EU) 2023/2723 kept listed references until dates of withdrawal set in its Annexes II and III, \"to give manufacturers sufficient time to adapt\" (recitals and Articles 2 and 3). The Commission's harmonised standards pages hold the current lists per act.",
      "sources": [
        1,
        2,
        3,
        4,
        7,
        6
      ]
    },
    {
      "text": "The technical file shows which standards you relied on. Annex III of the low voltage directive asks for a list of the harmonised standards applied in full or in part, and where they have not been applied, a description of the solutions adopted to meet the safety objectives (point 2(d)), plus test reports (point 2(f)). The declaration lists the standards used and is continuously updated (Article 15(2) and Annex IV item 6). When a standard changes, both documents change.",
      "sources": [
        1
      ]
    },
    {
      "text": "For radio equipment the standard can also decide the procedure. Where harmonised standards for the requirements in Article 3(2) and (3) have not been applied, have been applied only in part, or do not exist, the equipment must go through EU-type examination or full quality assurance (Directive 2014/53/EU Article 17(4)). If the product no longer meets the act, authorities require corrective action and, where the operator does not act, ensure withdrawal, recall or a prohibition (Regulation (EU) 2019/1020 Article 16(2), (3) and (5)).",
      "sources": [
        3,
        5
      ]
    }
  ],
  "steps": [
    {
      "name": "Confirm the status of the standard",
      "text": "Look up the standard in the Commission's lists of references published in the Official Journal for the act concerned. Note whether the old edition is still listed, has been replaced by a new edition, or has been withdrawn or restricted. When a standard is revised, the Commission's implementing decision can set a later date of withdrawal for the old reference; note that date.",
      "item": "regulation-library"
    },
    {
      "name": "Compare the old and the new edition",
      "text": "Ask your test lab or the standard's foreword which clauses changed. Many changes do not touch your product. Write a short gap note per clause: not relevant, already met by the existing results, or needs new evidence."
    },
    {
      "name": "Close the gaps with evidence",
      "text": "Where a changed clause applies, re-test that part or document how the product meets the requirement another way. If you no longer rely on the harmonised standard, the technical file must describe the solutions adopted to meet the essential requirements.",
      "item": "product-validation"
    },
    {
      "name": "Check the conformity procedure still fits",
      "text": "For radio equipment, the choice of procedure for some essential requirements depends on whether published harmonised standards were applied in full. A standard that is no longer listed can mean a notified body is needed for those requirements for units placed on the market after the withdrawal."
    },
    {
      "name": "Update the file and the declaration",
      "text": "Replace the standard reference and date in the technical documentation and in the declaration of conformity, sign a new version, and archive the old one with the date it stopped applying."
    }
  ],
  "documents": [
    {
      "name": "A standards gap note: old edition, new edition, affected clauses, conclusion",
      "from": "The manufacturer, with the test lab",
      "ground": "Directive 2014/35/EU Article 6(4); Directive 2014/30/EU Article 7(4); Directive 2014/53/EU Article 10(5)"
    },
    {
      "name": "New or supplementary test reports for the changed clauses",
      "from": "The test lab",
      "ground": "Directive 2014/35/EU Annex III point 2(f)"
    },
    {
      "name": "The updated EU declaration of conformity with the current standard references",
      "from": "The manufacturer",
      "ground": "Directive 2014/35/EU Article 15(2); Directive 2014/53/EU Article 18(2)"
    }
  ],
  "risks": [
    {
      "title": "Changes in standards must be taken into account",
      "text": "Manufacturers must ensure procedures are in place for series production to remain in conformity, and changes in the harmonised standards by reference to which conformity is declared shall be adequately taken into account (Directive 2014/35/EU Article 6(4); Directive 2014/30/EU Article 7(4)).",
      "source": 1
    },
    {
      "title": "The presumption depends on publication",
      "text": "Presumption of conformity applies to products that conform to harmonised standards whose references have been published in the Official Journal (Directive 2014/35/EU Article 12; Directive 2014/53/EU Article 16). After a formal objection, the Commission can decide to maintain, maintain with restriction or withdraw a reference (Regulation (EU) No 1025/2012 Article 11(1)(b)).",
      "source": 4
    },
    {
      "title": "The authority can order compliance restored",
      "text": "Authorities require corrective action to bring the product into compliance and ensure withdrawal, recall or a prohibition where the operator does not act (Regulation (EU) 2019/1020 Article 16(2), (3)(a) and (5)).",
      "source": 5
    }
  ],
  "faq": [
    {
      "q": "Does a withdrawn standard make our product non-compliant?",
      "a": "Not automatically. Compliance is with the essential requirements of the act. The standard gives a presumption of conformity only while its reference is published (Directive 2014/35/EU Article 12). Without it, you need other evidence that the requirements are met."
    },
    {
      "q": "Do we have to re-test every product?",
      "a": "No. The duty is to take the change adequately into account (Directive 2014/35/EU Article 6(4)). Re-test where a changed clause is relevant to the product, and record why the other changes do not affect it."
    },
    {
      "q": "Where do we find the current list of standards?",
      "a": "The Commission publishes the lists of references of harmonised standards per act on its harmonised standards pages, and the references are published in the Official Journal (Regulation (EU) No 1025/2012 Article 10(6))."
    },
    {
      "q": "Can we keep using an international or older standard?",
      "a": "Yes, standards are voluntary. Under the low voltage directive, where harmonised standards have not been applied, the technical file must describe the solutions adopted to meet the safety objectives (Annex III point 2(d)). Articles 13 and 14 cover IEC and national standards in specific cases."
    },
    {
      "q": "Do radio products need a notified body if the standard is gone?",
      "a": "Possibly. For the essential requirements in Article 3(2) and (3), radio equipment must go to EU-type examination or full quality assurance where harmonised standards have not been applied, have been applied only in part, or do not exist (Directive 2014/53/EU Article 17(4))."
    }
  ],
  "sources": [
    {
      "title": "Directive 2014/35/EU on electrical equipment designed for use within certain voltage limits (consolidated text of 30 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0035-20260530",
      "accessed": "2026-10-04"
    },
    {
      "title": "Directive 2014/30/EU on electromagnetic compatibility (consolidated text of 30 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0030-20260530",
      "accessed": "2026-10-04"
    },
    {
      "title": "Directive 2014/53/EU on radio equipment (consolidated text of 30 May 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02014L0053-20260530",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) No 1025/2012 on European standardisation (consolidated text of 13 December 2024)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02012R1025-20241213",
      "accessed": "2026-10-04"
    },
    {
      "title": "Regulation (EU) 2019/1020 on market surveillance and compliance of products (consolidated text of 12 August 2026)",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019R1020-20260812",
      "accessed": "2026-10-04"
    },
    {
      "title": "Harmonised standards",
      "publisher": "European Commission",
      "url": "https://single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards_en",
      "accessed": "2026-10-04"
    },
    {
      "title": "Commission Implementing Decision (EU) 2023/2723 on harmonised standards for electrical equipment drafted in support of Directive 2014/35/EU",
      "publisher": "EUR-Lex",
      "url": "https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023D2723",
      "accessed": "2026-10-04"
    }
  ],
  "related": [
    "which-standards",
    "product-change-recheck",
    "emc-test-failed",
    "first-declaration-of-conformity",
    "notified-body-needed"
  ],
  "reviewer": "Conphora compliance team",
  "reviewedAt": "2026-10-04",
  "notice": "General information, not legal advice."
}