The New EMC Directive: An Overview

OBJECTIVES:  
 Define the scope of regulation and essential requirements
 Establish a regulatory mode more adapted for fixed installations
 Clarify the role of harmonized standards
 Simplify the conformity assessment procedure (unique procedure
  for equipment)
 Improve the market survey by improving the traceability of manufacturers

SCOPE: 
The Directive 2004/108/EC applies to a vast range of equipment encompassing electrical and electronic appliances, systems, and installations, including electrical and electronic appliances; fixed installations; devices and sub-assemblies intended to be included in an apparatus by the final user and mobile installations.

It excludes:
 Equipment covered by the Radio and Telecommunications
  Terminal Equipment Directive 1999/5/EC
 Radio equipment used by radio amateurs
 Equipment where EMC is covered by other specific Directives, such
  as marine equipment if covered by Directive 96/98/EC or active
  implantable medical devices under 90/385/EEC
 Inherently benign equipment

ESSENTIAL REQUIREMENTS: 
Protection requirements for all equipment: Equipment shall be so designed and manufactured as to ensure that:
 The electromagnetic disturbance generated does not exceed the level
  above which radio and telecommunications equipment or other equipment
  cannot operate as intended
 It has a level of immunity to the electromagnetic disturbance to be expected
  in its intended use which allows it to operate without unacceptable
  degradation of its intended use

Specific requirements for fixed installations: Fixed installations shall be installed applying good engineering practices and respecting the information on the intended use of its components.

FINAL PROVISIONS: 
 20 July 2007: Directive enters into force.
 Until 20 July 2009: Transitional period where both EMC Directives
  2004/108/EC and 89/336/EEC can be used.
 20 July 2009: End of transitional period and only the new Directive
  2004/108/EC can be used to place products on the European market.

Complying with the EMC Directive

When complying with this new Directive, your products need to comply with the protection requirements according to Annex I of the EMC Directive. Compliance with these protection requirements is demonstrated by applying the conformity assessment procedure detailed in Annex II (self declaration) or Annex III (use of a Notified Body on a voluntary basis) of the Directive.

Whichever conformity assessment route is chosen, technical documentation must be prepared to demonstrate evidence of compliance with the protection requirements. You must also perform an EMC assessment of your product based on the relevant phenomena in order to demonstrate that it meets the protection requirements.

All measures necessary must be taken to show that your products are manufactured in accordance with the technical documentation. You must also complete an EC Declaration of Conformity and affix the CE Marking. You may opt on a voluntary basis to involve a Notified Body during the conformity assessment procedure to review your Technical Documentation.

Preparing for the New EMC Directive

1.  Review the new Directive to assess if you have EMC Assessment expertise within your organization. If not, consider partnering with an organization experienced in EMC and/or use the services of a Notified Body to assess your Technical Documentation and your EMC Assessment.

2.  For products in development now, you need to evaluate against the latest product standards and declare against 2004/108/EC using a Notified Body such as Curtis-Straus in USA or LCIE in Europe (Bureau Veritas companies) if you choose.

3.  For products in production that have a Declaration of Conformity against 89/336/EEC but will be obsolete by 20 July 2009, there is no need to update these products as the declaration to 89/336/EC is valid until 20 July 2009.

4.  For products in production that have been declared compliant  to the current 89/336/EEC Directive and are not likely to be obsolete by 20 July 2009, there is a need to re-declare against 2004/108/EC. However, you will need to perform a review of the standards used for your Assessment as they have been revised since your original declaration. This may involve additional testing.

5.  If in doubt, contact your local Bureau Veritas Electrical and Electronic Product Services office. We will gladly assist you starting from Step 1!  Contact us directly for details.

KEY CHANGES BETWEEN OLD AND NEW EMC DIRECTIVES  Clear responsibility for manufacturers: Clear focus that responsibility rests squarely on the shoulders of the manufacturer or authorized representative.  You must demonstrate EMC knowledge: An EMC Assessment is required for all products.  Market surveillance will be stepped up under the new Directive: There will be stiffer penalties for those that do not comply.  Notified Bodies involvement in Technical Documentation review is voluntary: The use of a Competent Body under 89/336/EEC was mandatory when there were no or partial harmonized standards

Contact Information

Bureau Veritas can assist with testing, compliance assistance regarding the EMC Assessment or we can perform the Notified Body review. To request assistance, please contact your local office.

Visit our website for contact details www.electrical.bureauveritas.com or email at electrical@uk.bureauveritas.com

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