EMC Directive to cut red tape

Richard A Quinnell, Contributing Editor -- Test & Measurement World, 9/1/2005

One of the hot topics at the 2005 IEEE EMC Symposium (August 8–12, Chicago, IL) was the impact of a new EMC Directive from the European Parliament and Council. The directive seeks to ease the regulatory burden on manufacturers of electronic equipment by transferring responsibility for determining compliance from regulatory bodies to the manufacturers. This will have an effect on when and by whom EMC testing is performed and will change the documentation requirements for products aimed at the European market.

EMC Directive 2004/108/EC, which entered into force on January 20, 2005, and will take full effect on July 20, 2007, replaces Directive 89/336/EEC. Any national provisions that are incompatible with the old directive became inapplicable when the new one entered into force. The delay of full implementation until 2007 will give member states time to incorporate the new requirements into their own national standards.

In place of the mandatory outside testing required by the previous directive, manufacturers will now be able to document their EMC assessment and then self-declare compliance. They also have the option of having a "Notified Body" review and approve their documentation. If manufacturers follow any of the "harmonized standards" (Ref. 1) prepared by a recognized European standards body in making their EMC assessment, then their equipment will be presumed to conform.

If harmonized standards are not used, do not apply, or only partially apply, the documentation requirements become more involved. The manufacturer may need to create a technical construction file containing schematics, tests parameter rationales, and a host of additional justification. The company may also need to have testing performed by the Notified Body to assure conformity. The documentation will have to be retained and available for review for seven years following the discontinuation of product manufacturing.

The new requirements will allow compliance monitoring agencies to act effectively if noncompliance problems arise in the field. Under the terms of the new documentation requirements, a manufacturer must provide the following with each product:

• clear identification of the product, including type, batch, and serial number;
• name and address of the manufacturer, authorized representative, and person responsible for placing the equipment in the European market if manufacturing is not performed in the EU;
• information on precautions a user must take when assembling, installing, using, and maintaining the equipment;
• instructions for using the product for its intended purpose;
• any restrictions on use; and
• a declaration of conformity with the EMC Directive.

For fixed installations, such as networks and systems that may evolve over time, the new directive calls for documentation of the installation effort. Installation must follow good engineering practices and must follow the restrictions provided with each piece of equipment. Installers must document their work, and those documents must be held available for inspection as long as the installation remains in operation.

Until the new directive goes into full force in 2007, manufacturers must still follow the provisions of Directive 89/336/EEC. Once the new directive goes into full force, new equipment that follows the new directive can be introduced and a transitional period for compliance begins. Equipment that follows the old directive cannot be marketed after July 20, 2009.

More details about the new directive are available at europa.eu.int/comm/enterprise/electr_equipment/emc/revision/workshop.htm.