SLIM III Update

We will publish the next Newsletter from the DTI when issued.

1. As most of the readers of this newsletter may be aware, it is starting to look increasingly likely that the recommendations of the SLIM Panel on the EMC Directive will lead to amendments to the text of the Directive, and as a consequence the UK EMC Regulations.

2. In its response to the Panel's report, the European Commission has either endorsed the recommendations as presented, or agreed to consider the proposals in more detail. DG III were very quick to set up two groups to develop the work:
   • The first - called the SLIM Working Group - was charged with looking at the Policy issues and in particular the text of the Directive with a view to its amendment.
   • The second will undertake a strategic review of EMC Standards within the framework of the EMC Directive.

3. A meeting of the SLIM Working Group took place on the 19 & 20 May, the standards review group has yet to meet. At the Working Group most progress was made in the area of definitions, where the proposals sought to bring a number of generally agreed concepts from the EMC "Guide to the Application of Directive 89/336/EEC"2 across into the Directive. In addition, it was proposed to elaborate existing wording to allow for the separate treatment of fixed installations as against electrical and/or electronic apparatus. It was also accepted that, in further work, effort would be directed in order to bring the text of the Directive to align more closely with other, relevant Directives (e.g. RTTED, LVD).

   Definitions

4. The mood of the two days showed that there is a need to include installations in the definition of apparatus, in order to distinguish between goods involved in free trade and those which are fixed.

5. It was agreed to remove:
   • the proposal to define machines (in particular, large machines) so that their treatment would depend on whether they would fall within (or outside) the definition of fixed installations;
   • the text defining networks, as large networks would always be fixed installations; and to provide explanatory wording in the preamble of the Directive.

   The draft definitions now under consideration are at Annex A.

6. The main thrust of the discussion was to separate the treatment between apparatus and fixed installations, where all accepted that only Article 4 protection requirements should apply.

7. A particular facet of the treatment of fixed installations was the future proposed treatment of parts which are designed specifically for installation/assembly into such installations, whether from a third country or within the EEA. Given that it is proposed not to require testing of such installations until a complaint has been received and to base assessment using sound engineering practice, the question arose as to whether these parts should:
   • need to comply with the Directive at all;
   • meet both the CE marking requirements and the protection requirements;
   • only meet the protection requirements.

8. The debate was inconclusive, but it was accepted that further discussion was required. The UK position was that this apparatus should meet all of the requirements in the case of parts which are generally available for placing on the EEA market. However, where they are "one-off" for a fixed environment then it might be argued that the CE marking requirements were superfluous.

9. The treatment of installations is to be considered in more detail by a subgroup, with UK participation.

   Exclusions

10. It looks likely that the exclusion of passive equipment is to be made explicit in the text of the Directive, with examples of such equipment to continue to be provided in any revised Guidance.

11. The general wording at Art 2(2) regarding "specific" Directives is to be retained whilst mention is proposed of the new RTTE Directive (Directive no. 1999/5/EC on radio equipment and telecommunications terminal equipment), which is not a "specific" Directive under the terms of the EMC Directive. The Commission admitted that the new Directive would not now automatically lead to the deletion of Article 10(5), as Air-Traffic Management equipment (ATM), is specifically excluded from the RTTED. Those present were asked whether they could still support this amendment although it would then mean that only those procedures under Arts 10(1) and 10(2) would be available for transmitters within this area.

    EMC Environments

12. A paper was presented on this subject at the request of the Commission, which, in principle, would provide for three types of environments to be defined -general, industrial and specific. This found the some support but further work is necessary.

13. An interesting theme was the proposal to make it a requirement that the manufacturer declare the EMC environment within which the apparatus is intended for use on the EC DoC and to make this dear on the packaging.

14. A second group was set up to consider this area and provide recommendations.

    Conformity Assessment Procedures

15. No discussion, although it would evidently be affected should it be agreed to delete Article 10(5).

    EMC Study

16. The Commission presented an invitation to tender for an independent study of the EMC Directive, its impact and ways it could be improved, as a "tool" to further assist the work to amend the Directive.

    Timing

17. The next meeting of the SLIM Working Party is scheduled for the Autumn, and the Commission anticipate that this will result in a draft EMC Directive, for further discussion next year, after which it would be presented to the European Parliament and Council.

    DTI   STRD                                                         4  June 1999

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    Annex A

    Draft Definitions Now Under Consideration

    Electromagnetic compatibility means the ability of electrical or electronic equipment to function satisfactorily in its electromagnetic environment without introducing intolerable electromagnetic disturbances to anything in that environment.

    Electromagnetic disturbance means any electromagnetic phenomenon which may degrade the performance of electrical or electronic equipment. An electromagnetic disturbance may be electromagnetic noise, an unwanted signal or a change in the propagation medium itself.

    Immunity means the ability of electrical or electronic equipment to perform without degradation of quality in the presence of an electromagnetic disturbance.

    Electrical or electronic equipment: any apparatus or fixed installation.

    Apparatus:

    An electrical or electronic component or sub-assembly:
    • intended for incorporation into an apparatus by the end user;
    • which can be available without further adjustment or connections, other than simple ones that can be performed by any person not fully aware of electromagnetic compatibility implications;
    • and which is liable to generate electromagnetic disturbance, or the performance of which is liable to be affected by such disturbance;
    • is deemed to be an apparatus for the purposes of the Directive.
    A system (combination of several apparatus)
    • made commercially available as a single functional unit; is also deemed to be an apparatus for the purposes of this Directive, unless it is a fixed installation.

    Fixed installation means a combination of several types of apparatus and, where applicable, other devices:

    • assembled or erected in accordance with given specifications at its place of use;
    • in order to be used in a given environment;
    • which is liable to generate electromagnetic disturbance, or the performance of which is liable to be affected by such disturbance.

    Electromagnetic passive equipment means equipment which:

    • when used as intended
    • without internal protection measures such as filtering or shielding;
    • without user intervention;
    • does not produce any switching or oscillation of current and voltage; and,
    • is not affected by electromagnetic disturbance.

    Notified Body - means any body:

    • designated by member States; and,
    • notified to the other member States and the Commission;
    • to perform the tasks assigned to it in accordance with this Directive.