Dear Richard The Self-Declaration Route to Conformity under the EU's EMC Directive requires the manufacturer to create and sign a Declaration of Conformity which states that the product meets the Protection Requirements of the EMC Directive, and which also lists the harmonised EMC standards that he has applied.
Now, there is NO LEGAL REQUIREMENT TO ACTUALLY HAVE PERFORMED ANY EMC TESTING to the listed standards, but there is a legal requirement to be able to show "due diligence" (as this is experessed in the UK's EMC Regulations which implement the Directive)in meeting the Directive. At a recent meeting of the UK's EMC Test Lab's Association it proved impossible to get a consensus on self-declaration (sometimes called self-certification) other than that it means the manufacturer is really saying: "if you test my products to these standards they will pass it". But even this is not quite right, as it is possible to "apply" a standard without actually passing all its tests. The EMC Enforcement in the UK make the point quite clearly: they say (based on UK Case Law) that it is possible to meet the standards and fail the Directive, or to fail the standards and meet the Directive. Obviously, a responsible manufacturer who wants to reduce the business risks of having his product barred from the entire EU will take whatever steps are needed, which will usually involve EMC testing and record-keeping, but which EMC phenonema to test for, how much testing to do, who to have do the testing and whether they should be accredited, and what reports to keep......... are all entirely up to the manufacturer, who has to make a business risk versus cost decision. Most managers can see the costs but have no inkling of the business risks, and so some are living more dangerously than they know. Some EU countries require automatic mandatory product recalls for goods found to be non-EMC-compliant! On the other hand there are alot of companies who are spending more on testing than they need to for the level of risk they want, and they could be at a competitive disadvantage compared to companies who understand the EMC Directive better. Refer to the EU's 1997 EMC Guidelines, and/or to UK Trading Standards EMC Specialists for confirmation of this, which knowledgeable test lab managers will confirm if you press them hard enough. Don't forget the EU also require manufacturers to be able to show that they are using due diligence in ensuring that products in serial production continue to comply, this usually requires some sort of sampling plan, unless the design is so good that its EMC performance cannot possibly vary (unlikely). Also, please take care not to mix FCC and EU EMC requirements, they have a different legal basis. Hope this helps! Keith Armstrong Partner, Cherry Clough Consultants Phone +44 (0)1457 871 605 Fax: +44 (0)1457 820 145 WOODS, RICHARD wrote: > > > A couple of months ago, there was a discussion in this forum about how to > > test for EU conducted emssions and immunity on a 24 Vac CCTV camera. The > > consensus was that the the manufacturer was required to perform the tests > > before he could issue a Declaration of Conformity. This problem has come > > back to haunt me. I have been asked to cite the sections of the standards > > that support this position. My citations are listed below. Your comments > > would be appreciated. > > > > CONDUCTED EMISSIONS TESTING > > > > Based upon the following citations, it is clear that the FCC rules for > > digital devices requires that an EUT operating from the AC mains via an AC > > adapter or similar power source be tested for conducted emissions. > > > > Part 15.107(f) of the FCC rules states, > > > > Measurements to demonstrate compliance with the conducted limits are > > not required for devices which only employ battery power for operation and > > which do not operate from the AC power lines or contain provisions for > > operation while connected to the AC power lines. Devices that include, or > > make provision for, the use of battery chargers which permit operating > > while charging, AC adapters or battery eliminators or that connect to the > > AC power lines indirectly, obtaining their power through another device > > which is connected to the AC power mains, shall be tested to demonstrate > > compliance with the conducted limits. > > > > Part 15.31(a)(6) of the FCC rules states, > > > > NOTE: Digital devices tested to show compliance with the provisions > > of 15.107(e) and 15.109(g) must be tested following the ANSI C63.4 > > procedure . . . > > > > ANSI C63.4-1992 Section 7 states, > > > > If the EUT normally receives power from another device that connects > > to the public untility ac powerlines, measurements shall be made on that > > device with the EUT in operation to ensure that the device continues to > > comply with the appropriate limits while providing the EUT with power. If > > the EUT is operated only from internal or dedicated batteries, with no > > provision for connection to the public utility ac powerlines (600 Vac or > > less) to operate the EUT (such as an adapter), ac powerline conducted > > measurements are not required. > > > > Based upon the following two citations, it is unclear if or how non-mains > > power ports are to be tested for CE compliance. > > > > EN55022 contains no guidance on the test setup of an EUT that is not mains > > operated except that Clause 2 makes a normative reference to CISPR 16-2: > > 1987 (methods of measurement). > > > > CISPR 16-2 contains no guidance on the test setup of an EUT that is not > > mains operated. > > > > > > CONDUCTED IMMUNITY TESTING > > > > Based upon the following two citations, it is clear that fast transient > > testing is required on AC power ports. > > > > EN 50082-1:1992 specifies in Table 4 that the "AC power ports" shall be > > subjected to the fast transients tests specified by IEC 801-4:1988. > > > > IEC 801-4:1998 specifies in clause 7.2.1 that "The EUT shall be arranged > > and connected according to its normal installation requirements." Clause > > 7.2.2 specifies that test equipment be coupled directly to the power > > supply lines of the EUT. There are no restrictions that the power ports > > must be directly connected to the AC mains. > > > > Richard Woods > > Sensormatic Electronics > > [email protected] > > Views expressed by the author do not necessarily represent those of > > Sensormatic. > > > > > >
