The “Legacy Component Provision”: Clause 4.1.1 of UL/CSA/EN/IEC62368 is one of the most important clauses to be aware of when transitioning to the new standard. This clause has been referred to as the “Legacy Component Provision” because it addresses components certified to the “old standards”: UL/CSA/EN/IEC60950 & UL/CSA/EN/IEC60065.
What is Your Exposure? What is your exposure to the component legacy provision? Are you developing new products that are design locked with any 60950 or 60065 components that have not been updated to 62368 by the manufacturer? Do you have certified products with critical parts that are sole-sourced from a vendor who has not updated to 62368? Are you backed into a corner and have to use the exception? Let’s look at the wording in the standard.
Clause 4.1.1 per 62368: Unfortunately the fine print has changed with each edition. What was once very clear in the 2nd edition is now very vague in the 3rd edition. Recommendations previously made based on the 2nd edition may no longer be valid based on the new wording in the 3rd edition.
a) 2nd Edition: Here is exact wording from Clause 4.1.1 from the 2nd edition of UL/CSA/EN/IEC 62368-1 that impacts legacy components:
· “Components and subassemblies that comply with IEC60950-1 or IEC60065 are acceptable as part of equipment covered by this standard without further evaluation other than to give consideration to the appropriate use of the component or sub-assembly in the end-product.
– NOTE: The paragraph above will be deleted in edition 3 of this standard. It is added here to smooth transition from the latest editions of IEC60950-1 and IEC60065 to this document.”
b) 3rd Edition: Here is exact wording from Clause 4.1.1 from the 3rd edition of UL/CSA/EN/IEC 62368-1 that impacts legacy components. Notice that the 2nd edition specifically stated this clause would be removed in the 3rd edition = it was not removed and now indicates it will be removed in the next edition subject to a committee vote! Which means there is no clear indication if this clause will ever be removed from the standard.
· “Internal and external components and subassemblies that comply with IEC60950-1 or IEC60065 are acceptable as part of equipment covered by this document without further evaluation other than to give consideration to the appropriate use of the component or sub-assembly in the end-product.
– NOTE: The paragraph above will be deleted in the next revision of this document, subject to a vote of National Committees at the time. It is added here to smooth transition from the latest editions of IEC60950-1 and IEC60065 to this document.”
CE – A Complicating Factor: A major factor to be aware of is the European Union’s decision to formally withdraw EN60950-1 and EN60065-1 on Dec. 20, 2020 = the same day that the EU formally adopts EN62368-1. This move essentially forces manufacturers that sell in the EU to eliminate use of products and components certified to EN60950-1 and EN60065-1 by the Dec. 20, 2020 cut-off date. In which case if you are using any components that are not updated from 60950-1 or 60065 certification to 62368 certification, and your product has the CE mark, you need to address this immediately.
Potential Liability Warning: In many countries, manufacturers have ultimate liability over the products they make and sell. Which means that even with safety certification marks, a product’s manufacturer can be sued by a user who says they were injured using the product. With this in mind, if the product meets the new 62368 standard using the legacy component provision, could this create increased potential liability? Using the legacy component provision means that you have used an exception to comply with the new standard = an exception that has a lower level of safety. What is your liability if you use a 60950 or 60065 certified component and there is an accident with your product that could have been avoided by use of a 62368 certified component? Make sure you consider this if you plan to use the legacy component provision.
Summary: Unfortunately, the legacy component provision contained in clause 4.1.1 of UL/CSA/EN/IEC62368 has been allowed to stick around longer than originally intended. By now, component manufacturers should have updated their product lines to the new standard. While some countries such as the US & Canada continue to push this issue down the road, the European Union has made an official decision that will impact most manufacturers = by withdrawing 60950 and 60065 as of Dec. 20, 2020, EU officials have effectively blocked the legacy component provision in the European Union = which should have the same impact on products that are UL/CSA/CE.
If you make products that fall under 62368, you need to determine if all your components that were certified to 60950 and 60065 have been updated to 62368. And if you have any components that have not been updated, you need to get your vendor’s commitment to update to 62368 by the EU cut-off date or consider an alternative component. Do not wait, everyone should have already started this process to insure updating of all impacted certifications by Dec. 20, 2020.
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