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  • Transitioning to a new European directive

    Rick Nelson, Chief Editor -- Test & Measurement World, 3/1/2005 2:00:00 AM

    Vendors targeting their products at the European community must now wrestle with a new directive regarding electromagnetic compatibility. In general, that should be good news, based on the European Commission's (EC's) stated goals in establishing Commission Directive 2004/108/EC (Ref. 1). But the implications for US manufacturers are less than clear.

    The EC developed the standard in accordance with its Simpler Legislation for the Internal Market (SLIM) program (Ref. 2). The proposal for the directive lists its key goals as "cutting 'red tape' and increasing manufacturers' choice," by simplifying conformity-assessment procedures and providing for voluntary use of conformity-assessment bodies (Ref. 3).

    Other goals include clarifying definitions and exclusions, improving market surveillance through better manufacturer traceability, and clarifying the role of international harmonized standards (Ref. 4). In addition, the new directive establishes separate regulations for mobile equipment and fixed installations. Directive 2004/108/EC, which went into effect on January 20 (Table 1), replaces 89/336/EEC, which has been operational since 1996.

    In a cost-benefit analysis conducted in accordance with SLIM (Ref. 5), the EC concluded that the EMC Directive potentially affects around 800 million products that enter the market each year having an estimated value of approximately 400 billion Euros, with EMC compliance costs ranging from 1% to 5% of a product's price.

    Tim Williams, an EMC consultant at Elmac Services, noted that the changes in the new directive are procedural: "The new directive makes no substantive changes to the essential requirements, and the referenced standards will be unchanged." He suggested, though, that the revision would not be particularly helpful to US vendors who comply with the FCC's EMC regulations (Ref. 6). "The European harmonized standards are by no means the same as the FCC rules, nor are they directly related and never have been. For instance, FCC Part 15 says nothing whatever about immunity, which is a major plank of the EC requirements."

    When asked what steps a non-European manufacturer might take to ensure compliance, he noted that engaging a European test lab "would be a recommended option, but it's not mandatory. Testing to the relevant standards is entirely possible anywhere in the world, provided that the test lab understands what the European requirements are." He added that the manufacturer's EU importer must hold the relevant documentation. Further information can be found in a presentation he gave during a January workshop (Ref. 7).

    Table 1. Timetable for EC EMC Directives

    DIRECTIVE 2004/108/EC (electronic equipment) 2004/104/EC (vehicles)
    *New vehicles must comply; existing vehicles need not comply until January 1, 2009.
    Publication date December 31, 2004 November 13, 2004
    Effective date January 20, 2005 December 3, 2004
    Member states' deadline for adoption of new directive and repeal of previous directive January 20, 2007 December 31, 2005
    Last date compliance guaranteed for products meeting previous directive January 20, 2009 July 1, 2006*


    References
    1. "Directive 2004/108/EC of the European Parliament and of the Council of 15 December 2004 on the approximation of the laws of the Member States relating to electromagnetic compatibility and repealing Directive 89/336/EEC," The European Commission. europa.eu.int/eur-lex/lex/LexUriServ/site/en/oj/2004/l_390/l_39020041231en00240037.pdf.

    2. "The revision of the EMC Directive (the SLIM process)," The European Commission. europa.eu.int/comm/enterprise/electr_equipment/emc/revision/theslimprocess.htm.

    3. "Proposal for a Directive of the European Parliament and of the Council on the approximation of the laws of the Member States relating to electromagnetic compatibility," The European Commission. europa.eu.int/comm/enterprise/electr_equipment/emc/revision/proposal.htm.

    4. "Harmonised Standards—Directive 89/336/EEC—Council Directive of 3 May 1989 on the approximation of the laws of the Member States relating to Electromagnetic Compatibility," The European Commission. europa.eu.int/comm/enterprise/newapproach/standardization/harmstds/reflist/emc.html

    5. "Cost Benefit Analysis on the Draft Amendment of the EC Directive on Electromagnetic Compatibility: Final Report—January 2002," The European Commission. europa.eu.int/comm/enterprise/electr_equipment/engin/cba.pdf.

    6. "Title 47—Telecommunication, Chapter I—Federal Communications Commission, Part 15—Radio Frequency Devices," The Federal Communications Commission. www.access.gpo.gov/nara/cfr/waisidx_03/47cfr15_03.html.

    7. Williams, Tim, "Using standards under the second edition," Elmac Services, January 19, 2005. www.elmac.co.uk/pdfs/Using_standards_under_EMCD2.pdf.

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