Manufacturers should familiarize themselves with the additional requirements and the alterations found in the new EMC directive
Electronics Regional Test Laboratory (West), Indian Ministry of Information Technology, Mumbai, India
The current EMC directive 89/336/EEC, which was first published in 1989 and then succeeded by four amendments has been rewritten as 2004/108/EC. It was published in the official Journal of European Committee on December 1, 2004. This new EMC directive went into effect on July 30, 2007. The two-year transition period will end on July 20, 2009. During the transition period manufacturers have the choice of following either version of EMC Directive when placing products on the European market. After this transition period, all products placed on the European market must comply with the new EMC Directive.
Significant changes have been made in the new Directive regarding scope application, essential requirements, the use of harmonized standards, and conformity assessment procedures. This article examines some significant changes and/or additions found in the new EMC Directive.
The EMC directive 2004/108/EC applies to a vast range of equipment— essentially all electrical and electronic appliances, systems, and installations for connection to the public mains or for use with other power sources. This Directive does not apply to equipment without any electrical and/or electronic parts—i.e., equipment that is “benign” in terms of EMC, e.g., cables and cabling systems, equipment with a resistive load without any automatic switching device, batteries and calculators, headphones, and loudspeakers without amplification systems, or portable lanterns with incandescent bulbs or LEDs.
The items listed below are covered by specific directives and are thus excluded from the EMC Directive 2004/108/EC:
- Radio and telecommunication equipment (Directive 1995/5/EC)
- Aeronautical products (Regulation 1592/2002)
- Motor vehicles (Directives 72/245/EEC and 2004/104/EC)
- Medical devices (Directive 92/42/EEC)
- Active implantable medical devices (Directive 90/385/EEC)
- Marine equipment (Directive 93/42/EC)
- Agricultural and forestry tractors (Directive 2001/3/EC)
- Two- or three-wheel motor vehicles (Directive 97/24/EC)
The earlier EMC Directive refers only to “Apparatus.” In contrast, the new Directive refers to “Equipment”—a category that is divided into “Apparatus” and “Fixed Installation.”
In the new Directive “Apparatus” refers to any finished appliance, or combination thereof, made commercially available as a single functioning unit, intended for an end-user and likely to generate electromagnetic disturbances, or the performance of which might be affected by such disturbances. “Components and subassemblies” are directly addressed in the new Directive. These are categorized as apparatus if they are intended for incorporation into an apparatus by the end-user and are likely either to generate or to be affected by EM disturbances. Mobile installations are also referred to as apparatus.
Apparatus that does not comply with the new Directive may be displayed at trade fairs, exhibitions, and shows, but only with a visible sign clearly stating that it may neither be placed on the market nor put into service until it has been brought into conformity.
“Fixed installation” means a particular combination of several types of apparatus and, where applicable, other devices that are assembled, installed, or intended for permanent use at a predefined location—e.g., networks, industrial plants, power plants, airport luggage transport systems, elevators, and fire detection and prevention systems. Even transport systems on rails are included. Although the latter move, they move along the rails on predefined routes (the railway corridors).
The new Directive contains administrative provisions as well as technical requirements. In the new Directive some essential requirements apply to both apparatus and fixed installation categories while others apply only to one or the other.
In the new Directive, these requirements are the same as those in the earlier Directive, but the immunity requirements in the new Directive refer to intended use and take into account the possibility of electromagnetic disturbance and/or performance degradation.
As a specific requirement for fixed installations, the new Directive states that:
“The fixed installation shall be installed applying good engineering practices and respecting the information on the intended use of its components with a view to meeting the protection requirement. These good engineering practices shall be documented, and the documentation shall be held by the person(s) responsible for examination by the relevant national authorities for inspection purposes for as long as the fixed installation remains in operation.”
An essential requirement for EMC assessment in the new Directive is applicable solely to apparatus. This requirement mandates that a manufacturer must perform a comprehensive assessment on the apparatus. Further, the apparatus must be assessed and must be found compliant in all the possible configurations that might occur during normal use.
This requirement applies solely to apparatus—viz. apparatus shall be identified by type and designation, including its serial number or any other element of information that would allow for its identification. Also, each apparatus must have the name and address of the manufacturer and, if the company is not established within the European community, the name and address of its authorized representative or another person within the Community responsible for placing the apparatus on the Community market.
The manufacturer is also required to provide information on specific precautions to be taken for assembling, installing, maintaining, or using the apparatus to ensure conformity with the protection requirements.
Use of Harmonized Standards
The earlier EMC Directive does not explicitly require testing to harmonized standards except when a manufacturer is following the standards route, rather than the technical construction file or notification routes, for compliance. In the new EMC Directive, compliance with the harmonized standard requires both conformity with its provisions and demonstrable proof of this compliance obtained using the test methods set forth in the Directive.
Demonstration of Compliance
As noted above, in the earlier EMC Directive, there are three ways to demonstrate compliance:
- Harmonized Standards route
- Technical Construction File route
- Notification route for products requiring government approvals
These three routes for compliance are now replaced by a single route for determining compliance. In the new Directive, the manufacturer, or his representative in Europe, will draw up technical documentation that provides evidence of conformity with the essential requirements. The manufacturer can self-certify compliance without applying the harmonized standard in full. In the earlier Directive, if the manufacturer did not apply the harmonized standard in full, involvement of a third party was required. In the new Directive, such involvement is not compulsory although a manufacturer may involve a notified body if it elects to do so.
The technical documentation as per the new Directive must contain the following:
- General description of the apparatus
- Evidence of compliance with harmonized standards, if any, applied in full, or in part
- Description and explanation of the steps taken to meet essential requirements where harmonized standards have not been applied in full including, for example, electromagnetic assessments, results of testing, and design calculations;
- Statement from a notified body, if one is used by the manufacturer.
Declaration of Conformity
In the new EMC Directive, the following must be declared:
- Reference of EMC Directive
- Detailed identification of the apparatus to which it refers
- Name and address of the manufacturer, and where applicable, the name and address of the authorized representative in the European Community
- Dated references to the standards under which conformity is declared
- Date of declaration
- Identification of the person empowered to bind the manufacturer or its authorized representative and that person’s signature.
Under the new Directive, in the event of withdrawal of apparatus from the market by the enforcement authority, the authority will give precise grounds for doing so and will also provide information on available remedies under the national law. The time restrictions to which remedies are subject will also be mentioned by the enforcement authorities. The manufacturer, or its authorized representative will be given the right to put forward its point of view in advance of any enforcement action. However, this right may be disallowed in circumstances of compelling public interest.
The equipment manufacturers targeting their product toward the European market will be significantly affected by the new EMC Directive. Prudence dictates that manufacturers should familiarize themselves with the additional requirements and the alterations found in the new EMC directive before it comes into full force in July 2009.
Manjula Bhati is the Additional Director at ERTL(N), STQC Directorate, which is an Independent Test Laboratory under the Department of Information Technology, in the Indian Ministry of Communication and Information Technology. She studied Electronics and Telecommunication engineering in Delhi, India. She has 20 years of experience in testing. At present, she is responsible for the EMI/EMC related activities at the ERTL (N) laboratory. She is an assessor under the IECEE-CB Certification scheme for EMI/EMC and is also a qualified auditor for IEC17025 and ISO9001.