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There is a digital output control module with a CAN interface that I will be working on. Its already certified against EMC, e-mark (UNECE 10).

As the previous contractor will no longer support the software we will step in and do a software upgrade. The product will still have the same functionality but with our codebase.

Do these type of Software changes require a recertification process of the product?

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  • \$\begingroup\$ Just to be sure, you don't mean Electromagnetic Compatibility (EMC), but the automotive E-Mark Certification? In the latter case, we can't know what software updates you will do, or if the product with new software adheres to laws and regulations about safety and emissions. \$\endgroup\$
    – Justme
    Commented Jul 11 at 8:08
  • \$\begingroup\$ "Do these type of Software changes" What software changes? Are you to change the CAN bus communication alone or the whole program? The question is too broad to answer. \$\endgroup\$
    – Lundin
    Commented Jul 11 at 8:26
  • \$\begingroup\$ In general, EMC testing isn't as intricate as to assume a certain digital signal characteristic or bus load. There just needs to be some manner of traffic on the bus during testing. Meaning there's not really a way you can affect the previously tested EMC characteristics through CAN traffic changes alone. Unless you change baudrate, slew rate and things like that. If you change other things not related to CAN, that's another story. For example if you change the bus off error handling and the CS testing would put the CAN bus in bus off, then changing the error handling might affect CS testing. \$\endgroup\$
    – Lundin
    Commented Jul 11 at 8:26

3 Answers 3

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Do these type of Software changes require a recertification process of the product?

Not for digital signaling. If you are changing any kind of frequency with a clock as far as DC DC converters, or MCU's you may have to recertify.

Mainly it's anything you have listed as an oscillator or source on your first certification.

If you do have to make a change to these, you could most likely contact your NRTL and if the changes are not huge they might just recertify it (A few hours billed) . They may require you to retest (many hours billed).

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Hardware changes usually require the certification process repeated unless the modification is not big enough to alter the emission or immunity behaviour. This covers the PCB change as well as the MCU change.

Software changes, on the other hand, usually don't (as long as the hardware is kept the same) unless there's a signalisation change e.g. crystal/oscillator frequency or transmission baud rate. For example, if the CAN baud rate is changed from, say, 125k to 250k then a re-test will be needed.

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If you're required to certify EMC (opposed to doing accredited testing and then self-declaring - regular CE), then that is something you should discuss with your assessor at the certification agency.

Even though there are a lot of software changes that would not impact EMC, there might be specific rules in your product category that warrants testing anyway. There might also be room for discussion with the assessor whether to re-test or not, and the scope of the re-test.

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