An Urgent Bulletin from CSA Group
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1 Ref No: I Appliances No. 48 (Supersedes Informs Appliances No. 21, Ref No: I12-107) Date: December 21, 2016 An Urgent Bulletin from CSA Group Existing Certification not affected Apply any time to have your products evaluated Announcing: Publication of CAN/CSA-C22.2 No :16 / UL Sixth Edition - Household and similar electrical appliances - Safety - Part 1: General requirements See Attachment 1 for affected Class Numbers. To purchase the Standard, visit us at Who is affected? Manufacturers of products that fall within the scope of the CSA-adopted and UL-adopted IEC series standards. What do you do? 1. This publication outlines certification revisions that do not affect your currently certified product designs. 2. Please contact CSA technical staff if you have questions or need information concerning this publication and how it applies to you. 3. If you would like to arrange for an evaluation of new products to the revisions, initiate a certification project by contacting our Client Services Centre at Please supply appropriate supporting documentation*. If testing is needed, we will inform you of the samples required. *which includes technical information, company name, address, factory locations and CSA file number or master contract number (if assigned), and any other relevant documentation. Introduction: In October 31, 2016, CSA Group and UL published this harmonized standard for general requirements for safety of household and similar appliances. It is the second edition of CAN/CSA C22.2 No , and the sixth edition of UL It is based on publication IEC , Edition 5.1 (Edition 5:2010 including corrigendum 1:2010, corrigendum 2:2011, and amendment 1:2013), issued April Background and Rationale: See attachment 2 Major Revisions: See attachment 3 For questions specific to your file or products contact your CSA Group technical staff associate. Go to and enter your Master Contract # and the class numbers associated with this Informs to view your certified products. For technical questions on this Informs Contact David Briere by phone , fax or david.briere@csagroup.org Visit us at click on "Contact Us" for the online phone listing of our Offices and Partners The Canadian Standards Association. All rights reserved. Page 1 of 9
2 ATTACHMENT 1 Affected Class Numbers Class No: , COMFORT CONDITIONING EQUIPMENT - Air Cleaners - Electrostatic , COMFORT CONDITIONING EQUIPMENT - Air Conditioning Apparatus , COMFORT CONDITIONING EQUIPMENT - Heat Pumps , COMFORT CONDITIONING EQUIPMENT - Air Cleaners - Electrostatic , COMFORT CONDITIONING EQUIPMENT - Air Conditioning Apparatus , COMFORT CONDITIONING EQUIPMENT - (ELECTRICAL) Heat Pumps , COMFORT CONDITIONING EQUIPMENT - Air Cleaners - Electrostatic - Certified to US Standards , COMFORT CONDITIONING EQUIPMENT - Air Conditioning Apparatus - Certified to US Standards , COMFORT CONDITIONING EQUIPMENT - Heat Pumps - Certified to US Standards , REFRIGERATION EQUIPMENT - Refrigerating Machines , REFRIGERATION EQUIPMENT - Drinking Water Coolers and Fountains , REFRIGERATION EQUIPMENT - Refrigerant Recovery/Recycling Equipment , REFRIGERATION EQUIPMENT - Refrigerating Machines , REFRIGERATION EQUIPMENT - Drinking Water Coolers and Fountains , REFRIGERATION EQUIPMENT - Refrigerating Machines - Certified to US Standards , REFRIGERATION EQUIPMENT - Drinking Water Coolers and Fountains-Certified to US Standards , REFRIGERATION EQUIPMENT - Refrigerant Recovery/Recycling Equipment - Certified to US Standards , REFRIGERATION EQUIPMENT - Refrigerating Machines - Accessories , REFRIGERATION EQUIPMENT - Refrigerating Machines - Accessories , REFRIGERATION EQUIPMENT - Refrigerating Machines - Accessories - Certified to US Standards , REFRIGERATION EQUIPMENT - Refrigerating Machines - Refrigerant Motor Compressors , REFRIGERATION EQUIPMENT - Refrigerating Machines - Condensing Units , REFRIGERATION EQUIPMENT - Refrigerating Machines - Refrigerant Motor Compressors , REFRIGERATION EQUIPMENT - Refrigerant Motor Compressors - Certified to US Standards , REFRIGERATION EQUIPMENT - Condensing Units - Certified to US Standards , CLEANING MACHINES , CLEANING MACHINES - Vacuum Cleaners - Accessories and Parts , CLEANING MACHINES - High Pressure Cleaners , CLEANING MACHINES - Vacuum Cleaners - Accessories and Parts , CLEANING MACHINES , CLEANING MACHINES - High Pressure Cleaners , CLEANING MACHINES - Certified to US Standards , CLEANING MACHINES - Washing Machines - Commercial , CLEANING MACHINES - Clothes Washing - Household , CLEANING MACHINES - Clothes Washing - Household (Ontario Government Energy , CLEANING MACHINES - Dishwashers - Household , CLEANING MACHINES - Clothes Washing Machines - Household and Commercial , CLEANING MACHINES - Dishwashers - Household and Commercial , CLEANING MACHINES - Washing Machines - Commercial - Certified to US Standards , CLEANING MACHINES - Clothes Washing - Household - Certified to US Standards , CLEANING MACHINES - Dishwashers - Household - Certified to US Standards , DRY CLEANING EQUIPMENT , DRY CLEANING EQUIPMENT - Certified to US Standards , COMMERCIAL AMUSEMENT APPARATUS - Components , COMMERCIAL AMUSEMENT APPARATUS , COMMERCIAL AMUSEMENT APPARATUS - Components - Certified to US Standards , COMMERCIAL AMUSEMENT APPARATUS - Components - Certified to US Standards , HEATERS - Air - Portable Type Page 2 of 9
3 , HEATERS - Air - Stationary Type , HEATERS - Air - Portable Type , HEATERS - Air - Stationary Type , HEATERS - Air - Portable Type - Certified to US Standards , HEATERS - Air - Stationary Type - Certified to US Standards , HEATERS - Clothes Dryers - Commercial and Industrial , HEATERS - Clothes Dryers - Household , HEATERS - Clothes Dryers - Household , HEATERS - Clothes Dryers - Household and Commercial , HEATERS - Clothes Dryers - Commercial and Industrial - Certified to US Standards , HEATERS - Clothes Dryers - Household - Certified to US Standards , HEATERS - Household Cooking Ranges and Units , HEATERS - Cooking and Liquid - Portable Type , HEATERS - Cooking and Liquid - Stationary Type , HEATERS - Household Cooking Ranges and Units , HEATERS - Cooking and Liquid - Portable Type , HEATERS - Cooking and Liquid - Stationary Type , HEATERS - Household Cooking Ranges and Units Certified to US Standards , HEATERS - Cooking and Liquid - Portable Type - Certified to US Standards , HEATERS - Cooking and Liquid - Stationary Type-Certified to US Standards , HEATERS - Industrial and Laboratory , HEATERS - Kilns , HEATERS - Industrial and Laboratory , HEATERS - Industrial and Laboratory - Certified to US Standards , HEATERS - Kilns - Certified to US Standards , HEATERS - Flat Irons and Ironing Machines , HEATERS - Flat Irons and Ironing Machine , HEATERS - Flat Irons and Ironing Machines - Certified to US Standards , HEATERS - Warming Pads , HEATERS - Warming Pads , HEATERS - Warming Pads - Certified to US Standards , HEATERS - Engine Heaters and Battery Warmers , HEATERS - Miscellaneous , HEATERS - Engine Heaters and Battery Warmers , HEATERS - Miscellaneous , HEATERS - Engine Heaters and Battery Warmers - Certified to US Standards , HEATERS - Miscellaneous - Certified to US Standards , INCUBATORS AND BROODERS , INCUBATORS AND BROODERS , INCUBATORS AND BROODERS - Certified to US Standards , AIR COMPRESSORS , AIR COMPRESSORS - Component Type , AIR COMPRESSORS , AIR COMPRESSORS - Certified to US Standards , AIR COMPRESSORS - Component Type - Certified to US Standards , FANS AND BLOWERS , FANS AND BLOWERS - Component - Hydromassage , FANS AND BLOWERS , FANS AND BLOWERS - Certified to US Standards , SPRAYERS - Paint , SPRAYERS - Paint , SPRAYERS - Paint - Certified to US Standards , PICTURE MACHINES AND APPLIANCES - Appliance , PICTURE MACHINES AND APPLIANCES - Appliances , CARBONATORS , CARBONATORS Page 3 of 9
4 , CARBONATORS - Certified to US Standards , DAIRY MACHINES , DAIRY MACHINES , FOOD-PREPARING MACHINES , FOOD-PREPARING MACHINES , FOOD-PREPARING MACHINES - Certified to US Standards , GARBAGE DISPOSAL UNITS , GARBAGE DISPOSAL UNITS , GARBAGE DISPOSAL UNITS - Certified to US Standards , KITCHEN UTENSILS , KITCHEN UTENSILS - Barbeque Motors , KITCHEN UTENSILS , KITCHEN UTENSILS - Barbecue Motors , KITCHEN UTENSILS - Certified to US Standards , KITCHEN UTENSILS - Barbecue Motors - Certified to US Standards , SEWING MACHINES , SEWING MACHINES , SEWING MACHINES - Certified to US Standards , LIQUID PUMPS , LIQUID PUMPS - Component - Hydromassage , LIQUID PUMPS - Circulating , LIQUID PUMPS , LIQUID PUMPS - Certified to US Standards , LIQUID PUMPS - Component - Certified to US Standards , HEATERS - Hair Dressing and Hand Drying , HEATERS - Hair Dressing and Hand Drying , HEATERS - Hair Dressing and Hand Drying - Certified to US Standards , HYGIENE AND COSMETIC APPLIANCES - Miscellaneous , HYGIENE AND COSMETIC APPLIANCES - Hydromassage Unit , HYGIENE AND COSMETIC APPLIANCES - Motorized , HYGIENE AND COSMETIC APPLIANCES - Electrically-heated , HYGIENE AND COSMETIC APPLIANCES - Radiant Heaters and Infrared and Ultraviolet Lamp Assemblies , HYGIENE AND COSMETIC APPLIANCES - Motorized - Components , HYGIENE AND COSMETIC APPLIANCES - Skin Care , HYGIENE AND COSMETIC APPLIANCES - Motorized , HYGIENE AND COSMETIC APPLIANCES - Radiant Heaters and Infrared and Ultraviolet Lamp Assemblies , HYGIENE AND COSMETIC APPLIANCES - Miscellaneous - Certified to US Standards , HYGIENE AND COSMETIC APPLIANCES - Hydromassage Unit - Certified to US Standards , HYGIENE AND COSMETIC APPLIANCES - Motorized - Certified to US Standards , HYGIENE AND COSMETIC APPLIANCES - Electrically-Heated - Certified to US Standards , HYGIENE AND COSMETIC APPLIANCES - Radiant Heaters and Infrared and Ultraviolet Lamp Assemblies-Certified to US Standards , TOOLS - Gardening Appliances , TOOLS - Gardening Appliances , TOOLS - Gardening Appliances - Certified to US Standards , MOTOR OPERATED EQUIPMENT - Miscellaneous , MOTOR OPERATED EQUIPMENT - Miscellaneous - Certified to CAN/CSA E60335 or C22.2 No Series Standards , MOTOR OPERATED EQUIPMENT - Miscellaneous - Certified to US Standards , TEMPERATURE-INDICATING AND REGULATING EQUIPMENT - Heaters - Air - Accessories , TEMPERATURE-INDICATING AND REGULATING EQUIPMENT - Other Than Appliance Type , TEMPERATURE-INDICATING AND REGULATING EQUIPMENT - Heaters - Air - Accessories , TEMPERATURE-INDICATING AND REGULATING EQUIPMENT - Other Than Appliance Type Page 4 of 9
5 , TEMPERATURE-INDICATING AND REGULATING EQUIPMENT - Heaters - Air - Accessories - Certified to US Standards , TEMPERATURE-INDICATING AND REGULATING EQUIPMENT - Other than Appliance Type - Certified to US Standards , POWER SUPPLIES - Battery Chargers , POWER SUPPLIES - Battery Chargers , POWER SUPPLIES - Battery Chargers - Certified to US Standards , FENCE CONTROLLERS AND ENERGIZERS - Fence Controllers - Electric , FENCE CONTROLLERS AND ENERGIZERS - Fence Energizers - Electric , FENCE CONTROLLERS AND ENERGIZERS - Fence Controllers - Electric - Certified to US Standards , DOOR OPERATING UNITS , DOOR OPERATING UNITS - Components , DOOR OPERATING UNITS - Certified to US Standards , DOOR OPERATING UNITS - Components - Certified to US Standards , AUTOMOTIVE TESTING AND REPAIRING EQUIPMENT , AUTOMOTIVE TESTING AND REPAIRING EQUIPMENT , AUTOMOTIVE TESTING AND REPAIRING EQUIPMENT - Certified to US Standards , VENDING MACHINES , VENDING MACHINES - Accessories , VENDING MACHINES - Component Accessories , VENDING MACHINES , VENDING MACHINES - Accessories , VENDING MACHINES - Certified to US Standards , VENDING MACHINES - Accessories - Certified to US Standards , PEST CONTROL EQUIPMENT , PEST CONTROL EQUIPMENT - Certified to US Standards ATTACHMENT 2 Background and Rationale CSA Standards in the series consist of one Part 1 (CAN/CSA-C22.2 No ) and several Part 2 Standards (CAN/CSA-E XX or CAN/CSA-C22.2 No XX). Similarly, UL standards in the series consist of one Part 1 (UL ) and some Part 2 standards (UL XX). In both cases, each Part 2 is for a more specific product type and works in conjunction with the Part 1 by accepting the content of the clause without change, or by adding to, amending or omitting it. This Informs does not make any immediate mandatory requirements that affect your product; however, when a Part 2 makes reference to the edition of the Part 1 announced in this Informs and an effective date is associated with that Part 2, the edition of the Part 1 announced in this Informs will become mandatory along with that that Part 2. ATTACHMENT 3 Major Revisions The following list describes the technical changes between CAN/CSA-C22.2 No and CAN/CSA- C22.2 No :16 that may have an impact on previously-evaluated products. Editorial changes and relaxations to the standard are not included. Page 5 of 9
6 CAN/CSA-C22.2 No / UL fifth edition was based on adoption with deviations of IEC edition 4.2. CAN/CSA-C22.2 No :16 / UL sixth edition is based on adoption with deviations of IEC edition 5.1. Mexico has been removed from this publication, making it a bi-national standard and no longer tri- National. Mexican deviations have been removed throughout the document so the remainder of this summary does not mention these changes further DV DR Changed an appliance is intended for use immersed in water to wet contact with the appliance is likely to occur and added a note for clarity that such appliances would be identified in the Part DV DE New normative statement for use with newly added subclause 22.55DV, to state that the new test is carried out on a new appliance Added requirement that appliances with heating elements supplied by switch mode power supplies are supplied at a voltage corresponding to the rated power input New subclause requiring testing of appliances with non-self-resetting features that are not required for compliance. 7.1 New requirement that class III appliances be marked with the class III symbol. 7.1 New requirement to mark appliances that have a functional earth. 7.1DV.3 New deviation for Canada only to require all warnings to be in both English and French. 7.4 This clause is replaced to address appliances with adjustment for different rated frequencies. 7.6 Symbols for functional earthing and class III appliance are added. 7.8 New requirement to mark terminals for functional earth New requirements for instructions are added for class III appliances and for appliances that have class III constructions supplied from a detachable power supply New requirement to include an instruction for appliances that have been evaluated for use in altitudes greater than 2000 m, and for appliances incorporating a functional earth New requirement for instructions for appliances intended to be permanently connected to the water mains and not by a hose set New installation instruction requirement for appliances requiring adjustment for voltage and/or frequency The instruction required when a non-self-resetting thermal cut-out is required in order to comply with the standard is now applicable also to appliances other than just heating appliances The note for the petroleum spirit is converted to normative text, but the specific chemical previously stated is removed: Now, any aliphatic solvent hexane may be used New requirement that functional earthing symbol must be near the class II (double insulation) or the class III symbol. 10.1, 10.2 Change to what is considered the power input (10.1) or current (10.2) when the power input or current varies throughout the operating cycle. 11.8, Table 3 Changes to the temperature rise limits for external enclosures of motor-operated appliances and for surfaces of handles, knobs, etc for various materials. Footnotes are also added to the table for application of these requirements. Table 3 Modified the temperature limits for the external enclosure of motor-operated appliances. Table 3DV DC The deviation to 11.8 (previously 11.8DV DC) becomes a deviation to Table 3 with minor changes to wording and the following: o 11.8DV.1 becomes a) (no technical change); o 11.8DV.2 becomes b) (no technical change); o 11.8DV.3 becomes d) (no technical change); o 11.8DV.4 becomes g) (no technical change); o 11.8DV.5 becomes c), but is extended to create a temperature rise limit for silicone rubber; o o 11.8DV.6 becomes e) (no technical change); A new item f) is added to provide a temperature rise limit for surfaces where adhesive is used to secure non-detachable parts used to protect against access to live parts, moisture or contact with moving parts. This temperature rise limit already existed as an absolute value (70 C) in 22.11DV.1 in the previous edition; and o New item h) is added to delete footnote f) from the IEC standard (US only). 13.1DV D1, 13.2DV.2 D2 Leakage current limits are changed. Page 6 of 9
7 14 Changes to impulse test voltages Changed reference to the humidity test to IEC rather than having the details directly in IEC IEC requires the test chamber to be five times the size of the product under test The spillage solution, which now includes rinsing agent, is used instead of water containing 1 % NaCl. 16.2DV.1 D2, 16.2DV.2 D2 Leakage current limits are changed New statement to draw attention to new clause for testing appliances with voltage selector switches New text is added to require all unattended motor-operated appliances and combined appliances that use overload protective devices relying on electronic circuits to protect the motor windings to also be subjected to this test Added requirements for appliances with rated currents higher than 16A New clause for testing appliances with voltage selector switches Updated text to include capacitors rated exactly 0.1µF. Also added requirement for when compliance with this clause relies on an electronic circuit. For Canada: 22.55DV D1 and Annex DVD; For US: 22.11DV DC From previous clause 22.11DV D2. For both countries, the temperature limit of 70 C has been converted to a temperature rise limit and moved to Table 3DV DC item f). o For Canada, new normative Annex DVD is created. The test covered by the previous edition s clause numbers 22.11DV.2 to 22.11DV.8 is relocated to DVD.2 to DVD.6 without change, except that the test is now also applied to any parts that rely on adhesive for compliance with the standard (i.e. compliance with clause 4), such as to maintain spacings (see DVD.4 item b)). o For US, 22.11DV is modified to remove the adhesive aging test and refer directly to Annex DVA, which means that adhesives used for securement of non-detachable parts must comply with the applicable parts of UL 746C DV D2 New deviation requiring the screwshell of mains-connected Edison-base lampholders to be reliably connected to neutral DV D2 New deviation requiring appliances with motors greater than 1/3 rd hp to have a manuallyoperated motor-control switch This clause and associated Annex R were completely rewritten DV D1 Rather than specifying that socket outlets are to be considered in the part 2, the part 1 now points to Annex DVA for the applicable socket outlet standards New requirement for appliances with functional earth to have double or reinforced insulation between live parts and functionally earthed parts New requirement for accessibility of button cells and R1 batteries DV New deviation for Canada only restricting the use of varistors Added to the compliance criteria that not more than 10% of the strands of the wiring, nor the moveable part may break, except for 15W or less circuits may break not more than 30% A single layer of internal wiring insulation does not provide reinforced insulation Deleted lead-tin, effectively making the requirement applicable to all solder types. Also converted note 1 to normative text but instead of making spring terminals one option, the standard now mandates use of spring terminals where stranded conductors are consolidated by solder. 24.1DV DC An error in the previous publication (previously clause 24DV DC) has been corrected which eliminated all of clause 24, when in fact the intent was to retain some of the specific subclauses. Accordingly, clause 24.1 has been replaced to refer to the standards in Annex DVA Clarification that the relevant standard for transformers in associated switch mode power supplies is Annex BB of IEC This was previously covered by 24.1 s statement Components shall comply with the safety requirements specified in the relevant IEC standards as far as they reasonably apply DV DC New deviation to specifically require transformers complying with C22.2 No and UL for creation of a limited power source Motor starting relays shall be subjected to cycles when tested according to IEC Page 7 of 9
8 New requirement for thermal cut-outs of the capillary type to comply with the requirements for type 2.K controls in IEC DV DC New deviation that modifies the necessary number of cycles for automatic controls DV DC New deviation to require telecommunication network interface circuitry responsible for remote operation to comply with information technology standards DV DC New deviation for thermal links to either comply with the standards listed in Annex DVA or be considered intentionally weak parts for the purposes of clause DV DC New deviation to ensure specific terminal type devices are not interchangeable with general use plugs and socket outlets or standardized connector styles in IEC New requirement for motor running capacitors in series with a motor winding in unattended appliances to comply with one or more from a list of options. 24.8DV DC New deviation to allow motor running capacitors to comply with the standards listed in Annex DVA instead of making use of the IEC standard, which is a new requirement in the IEC standard since the previous adoption. 25.1DV.1 DR, 25.1DV.2 DR New deviation requiring appliances provided with screwshell-type lampholders, general use socket outlets or single-pole switches to be provided with supply cords that have a polarized plug and that the neutral blade of the plug be connected to the neutral conductor. 25.3DV D2 The note that had previously stated that this would be addressed in part 2 standards is replaced with requirements that permanently connected products using supply leads in a suitable compartment for connection to the supply have leads that are of a minimum length and size and that they be completely insulated if not all installations would require use of the leads New requirement for permanently connected multi-phase appliances fitted with a supply cord. 25.7DV DC New requirements are added for supply cords: o They shall comply with the standards in Annex DVA (except for supply cords of class III appliances); o Heater cords are required for cords that can contact any surface greater than 121 C; o Supply cords of Class III appliances are required to comply with a 500V, 2 minute electric strength test; o Appliances with inlets must be provided with a cord set Sizing requirements for multi-phase appliances are added in a note in the table DV DR This clause of the IEC standard is replaced to allow for solid green insulation for earthing conductors and to require identification of the neutral conductor in accordance electrical codes Deleted lead-tin, effectively making the requirement applicable to all solder types. Also converted note 1 to normative text but instead of making spring terminals one option, the standard now mandates use of spring terminals where stranded conductors are consolidated by solder The introduction of supply cords into the enclosure are not cause damage even if the enclosure is of insulating material. For all appliances, a protective lining or bushing is required unless it is evident from the construction of the appliance that the supply cord can be introduced without risk of damage The pull force is increased to 100N for all fixed appliances DV DC New deviation to require dimensions of pins of appliances that are inserted into socket outlets (i.e. blades of direct plug-in appliances) to be in accordance with the dimensions required by the plug/socket outlet standards listed in Annex DVA Modified exemption for unattended appliances so that it is applicable for those electrical connections that carry >0.2A, rather than >0.5A. 29 Added minimum spacing requirement between conductors before type 2 protection coating is applied Requirements are introduced for appliances intended for use in altitudes great than 2000 m. This includes deletion of note Added requirements for determining required clearance for functional insulation in systems with higher frequencies and limited the ability to use the impulse voltage test in lieu of clearance distances Changed the method for determining required clearance for appliances with higher working voltages than rated voltage, acknowledging those circuits operating at higher frequencies , , , Added requirements for minimum basic, supplementary, reinforced and functional insulation creepage distances for circuits operating at greater than 30 khz and a new Page 8 of 9
9 requirement (note 4 of tables 17 and 18) that minimum values are to be determined through interpolation for working voltages up to 630 V. 29.2, Table 17 Note 1 is replaced such that it excludes creepage distances for basic insulation in double insulation constructions. 29.3, Added minimum thickness and thermal quality assessment requirements for accessible parts of reinforced solid insulation not complying with the thickness requirements in Also added requirements for supplementary and reinforced solid insulation subjected to higher frequencies The third dashed item is split into two to separately cover thermal quality assessment for single layer internal wiring Added option for pre-selection of materials with a glow wire flammability index and added exemption for small parts, but also require consequential needle flame test for parts within 3mm of some of these parts. Annex B The existing Annex B is split into Annexes B and S as follows: o Annex B is for appliances powered by rechargeable batteries that are recharged in the appliance o Annex S is for battery-operated appliances powered by batteries that are non-rechargeable or not recharged in the appliance Annex D Updated for consistency with the locked rotor/moving parts test in Annex D, DDV.1 D2 New deviation to direct to the standards listed in Annex DVA. Annex F, FDV D2 The IEC capacitor standard is replaced with the CSA and UL adopted versions. Annex G, 29 Added requirements for minimum clearance, creepage distances and solid insulation for transformers operating at greater than 30 khz. Annex R This Annex and associated clause were completely rewritten. Annex DVA Made normative since the reference from clause 24 made this informative annex normative anyway. Updated standard list. Annex DVD See changes related to 22.11DV. Page 9 of 9
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