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EMC harmonised standards: no citation since 2022

News · State of play

The list of harmonised standards under EMC Directive 2014/30/EU has gained no new content since Implementing Decision (EU) 2022/910 of 9 June 2022. Four years on, the Commission's own page still shows that date as the latest amendment. For a manufacturer the consequence is direct: presumption of conformity remains tied to the cited editions, not to the current editions CENELEC publishes.

In short:

  • No new EMC standard has been cited in the OJEU since 9 June 2022.
  • The cause is structural rather than administrative: the litigation that followed the Public.Resource.Org judgment has frozen citation of European standards derived from ISO and IEC work.
  • Testing to the latest CENELEC edition earns no presumption of conformity while that edition is not cited.
  • The fallback under discussion is common specifications, an instrument now written into the EMC Directive itself.

References to harmonised standards under the EMC Directive are published through Implementing Decision (EU) 2019/1326, amended at irregular intervals. The amendment table stops abruptly:

DecisionDateContent
(EU) 2020/66015 May 2020List amendment
(EU) 2020/16303 November 2020List amendment
(EU) 2021/45515 March 2021List amendment
(EU) 2022/6227 April 2022Added EN IEC 62053-24:2021, three successors
(EU) 2022/9109 June 2022One successor, two withdrawals

Nothing since. The consolidated version of Decision 2019/1326 still carries the date of 10 June 2022, and the Commission portal for EMC harmonised standards references no later act.

The blockage is not a translation backlog or a queue among HAS consultants. It follows the Court of Justice judgment in case C-588/21 P, Public.Resource.Org, which held that harmonised standards form part of Union law and must be accessible. The litigation that followed between the international standardisation bodies and the Commission had a mechanical effect: citation in the Official Journal of European standards reproducing ISO or IEC work effectively stopped through 2025 and 2026.

The result is a widening gap between two lists:

  • What CENELEC publishes, continuing its normal revision cycle.
  • What the Official Journal cites, unchanged since 2022.

A further signal came from the sector in September 2025: the Commission asked the EMC committees to remove superseded standards from citation, with the number of affected standards described as significant. That clean-up has produced no publication either.

The legal rule has not changed, and that is exactly the trap: only the edition cited in the OJEU confers presumption of conformity. A date of cessation published by a standardisation body carries no legal force of its own.

In practice, for an EMC campaign run in 2026:

  • A test performed to the cited edition remains fully valid, even if CENELEC has since published a newer edition.
  • A test performed only to a newer, uncited edition is technically defensible but earns no presumption: the burden of proving that essential requirements are met falls entirely on the manufacturer.
  • The pragmatic route most laboratories take is to record both editions in the test report wherever limits and methods allow it.

The cited reference standards therefore remain EN 55032 and EN 55035 in their cited editions, along with the generic series EN IEC 61000-6-1 through EN IEC 61000-6-4.

Several pages online announce an EN 55035:2026 imposing stricter radiated emission limits and new transient immunity requirements, effective May 2026. No Official Journal citation and no CENELEC publication supports that claim. Likewise, the third edition of CISPR 32 does exist, but at European draft stage (prEN IEC 55032:2025, vote closed February 2026): it applies nowhere and confers no presumption.

The way out under discussion runs through common specifications, an instrument by which the Commission sets technical requirements itself through an implementing act, without going through a standardisation body.

That instrument has just been written into the EMC Directive by Directive (EU) 2024/2749, applicable since 30 May 2026. In that text it can only be used once internal market emergency mode is active, but the simplification work under way at European level aims to turn it into a standing conformity assessment tool.

  1. Check what your EU Declaration of Conformity actually cites. A declaration referencing an edition not cited in the OJEU carries no presumption, however good the testing was.
  2. Ask the laboratory for a dual reference in the test report where the method allows, covering both the cited edition and the current one.
  3. Do not withdraw an older test report because a new edition has appeared: while the citation does not move, the report keeps its value.
  4. Watch the L series of the Official Journal rather than publication announcements from standardisation bodies.

Sources & references

  1. Implementing Decision (EU) 2019/1326, consolidated version of 10 June 2022 , EUR-Lex eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02019D1326-20220610
  2. Implementing Decision (EU) 2022/910 of 9 June 2022 , EUR-Lex eur-lex.europa.eu/eli/dec_impl/2022/910/oj
  3. Electromagnetic compatibility, harmonised standards , European Commission single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/electromagnetic-compatibility-emc_en
  4. Judgment C-588/21 P, Public.Resource.Org v Commission , Court of Justice of the European Union eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:62021CJ0588