EMC Directive faces changes in 2007
Martin Rowe, Senior Technical Editor -- Test & Measurement World, 9/1/2006
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To find out how the new directive will really change things, I asked three prominent EMC engineers. “The new directive will put a lot of Competent Bodies and Notified Bodies out of business,” said Roland Gubisch, engineering manager for EMC and telecom at Intertek's lab in Boxborough, MA. “Technical construction files [TCFs] are no longer required to be reviewed by these bodies.”
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| The new EMC Directive gives manufacturers more freedom to self-certify products. Courtesy of DLS Electronic Systems. Also see these related articles from our September 2006 Compliance Test Report: --Stretching immunity test to 6 GHz --A year of change --Additional IEC standards for EMC that change during 2006 |
“The burden is on the manufacturer to comply,” said David Bare, CTO at Elliott Labs in Sunnyvale, CA. “Large manufacturers may write their own TCFs, but smaller ones will probably still use third parties such as test labs to write TCFs.”
“There may be less testing,” added EMC consultant Brian Jones. “Manufacturers may instead choose the more detailed technical documentation option, but customers could require third-party assessment. It's difficult to predict.”
The new directive allows for fixed installations to use equipment that is exempt from EMC compliance. So, custom equipment such as control panels or embedded systems, often designed and built by small companies and not sold on the open market, is exempt. “In the UK, the enforcement authorities would take the view that if there was an EMC problem with a fixed installation, they would ask the responsible person what good engineering practices have been employed,” said Jones.
“Good engineering practices” include shielding, grounding, and PCB layout to minimize interference. “You have to do these things anyway,” said Bare, “because without good signal integrity, your product probably won't work.”
You can still use harmonized standards that contain test procedures and limits when testing your products, but the new directive does not require this. You can, for example, claim that if you test to FCC Part 15, you don't need to test to harmonized EMI emissions standards if your test results show enough margin to give you confidence of compliance.
Furthermore, you need not repeat compliance tests for small design changes. Many manufacturers will choose to perform a comparison between a known-compliant product and a modified one. If the results let you conclude conformance in the modified product, you may place the CE Mark on your product with confidence. The reasoning for compliance should be included in the technical documentation.
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