EMC Directive - The Sequel

By Alan McHale, Radio Frequency Investigation Ltd

Summary

Christmas 2002 saw the European Commission publish its formal proposal for an enhanced EMC Directive. With clarified text and revised procedures, the proposal offers benefits for all players in the market.

Introduction

Europe’s EMC Directive was probably the most significant milestone in the history of Electromagnetic Compatibility. It was not the first EMC law to emerge from Brussels; others had preceded it as early as 1976. However the legislators were now following a different path, the broader “New Approach”, by adopting Directive 89/336/EEC. This introduced basic essential requirements to be applied to virtually all electrical and electronic apparatus from 1st January 1992. Older piecemeal legislation, which sought specifically to limit radio interference from particular electrical household appliances, portable tools and fluorescent lighting luminaries, was repealed in its wake.

We may never know if the legislators foresaw the explosive growth that occurred in the use of apparatus covered by the Directive and the consequential risks of degradation of our electromagnetic environment. The legislators’ intentions were to remove the old technical barriers to trade within Europe, and prevent new ones, whilst ensuring that electrical and electronic products neither cause excessive electromagnetic interference nor are adversely affected by electromagnetic disturbances. With the advantage of hindsight, we see that the EMC Directive has played its part well.

Commencing in 1998 the European Commission reviewed the EMC Directive as part of the SLIM (Simpler Legislation for the Internal Market) process. Recommendations were made and there has been subsequent industry-wide consultation. The Commission published its formal proposal¹ for a revised EMC Directive at Christmas 2002; the European Parliament and Council will consider it this year.

Why the Need for Change?

The EMC Directive has not been without its problems, particularly with respect to clarity and the application of its measures. The Commission found it expedient to publish a guide, as wordy as the Directive itself, informally encouraging consistency of application. The guide proved to be indispensable, demonstrating the need for a revised legally established text. Furthermore potential enhancements had been identified through the SLIM process and the subsequent consultations.

Summary of Significant Changes

The proposal, while reducing the length of the text by at least two thirds, establishes significant changes and clarifications. Key changes are listed in the table.

Impact on Manufacturers

Under the current directive, a typical manufacturer using harmonised standards to establish compliance is obligated to retain for 10 years, at the disposal of the competent authorities, only the Declaration of Conformity. Under the proposal he must draw up, maintain and retain the full technical documentation necessary to provide evidence of conformity. This is an increased burden, largely administrative in nature. The onus will also be on the manufacturer to ensure that assessment takes into account all intended normal operating conditions and to confirm all requirements are met in all possible representative configurations.

The proposed directive provides a manufacturer with the flexibility to use the services of a Notified Body expert as and when he considers appropriate and to use reports from the Notified Body as part of his technical documentation.

Manufacturers and installers of fixed installations will find that formal conformity assessment procedures are not required. However they are obliged to use good engineering practise, including documenting the installation, with a view to meeting the basic EMC protection requirements. They must remedy any problems identified, usually through a complaint. Procedures for apparatus intended only for incorporation in fixed installations are relaxed.

Manufacturers of ready-made connection devices will find they must design and manufacture to ensure that compliance with essential protection requirements is attained when used in conjunction with types of apparatus to which they are intended to be connected. Appropriate user documentation must be supplied.

The requirement to include name and address with each product will significantly improve the effectiveness of the surveillance authorities when they police the Directive. Manufacturers can be readily traced and bona-fide manufacturers will benefit by the removal of less scrupulous players.

Can the Industry Save Money?

The cost of documentation will tend to be higher under the new proposals. This is due to the obligations to draw up, maintain and retain for 10 years after last manufacture, all compliance-related documents.

Each manufacturer’s situation will be different, however the new flexibility in selecting whether or not to involve Notified Bodies and / or test laboratories is key to the typical manufacturer optimising his costs and time to market.

Manufacturers of ready-made connection devices will face the new costs of assessment and documentation of compliance of their products.

Manufacturers and installers of fixed installations may find a reduction in costs related to conformity assessment.

How Notified Bodies and test laboratories aid compliance

Organisations such as Radio Frequency Investigation Ltd, which are accredited both as test laboratories and inspection bodies, provide services to industry to aid compliance with the EMC Directive. These services include, in addition to basic testing, the determination of worst-case configurations and operating modes, preparation of technical documentation and the independent assessment of technical files.

In view of the additional burden on manufacturers to formalise the documenting of their conformity assessment process, many may prefer to tap into the expertise and services of the accredited test laboratory to ensure testing is adequately documented.

Conclusion

Last Christmas brought the promise of a sleek new EMC Directive offering simpler, effective regulation of the EMC environment. Publication within the year will be welcomed. A previous lesson learned from the original Directive will result in a proposed transition period ending 4.5 years later. This is one aspect where the Commission may have slipped up; the take-up of the new provisions will be rapid, rendering a long transition an unnecessary luxury.

Footnotes

¹ COM (2002) 759. This can be downloaded from http://europa.eu.int/comm/enterprise/electr_equipment/emc/revision/proposal.htm

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