Concerning the application of multiple EMC standards in the EU: Another point is that an EU Declaration of Conformity under the EMC Directive - the document that you have to have signed and ready for inspection in order to apply the CE mark - requires that you state that your product meets the "protection requirements" of the EMC Directive.
Many companies are unaware of this requirement, and their declarations usually say something like: "Product XYZ meets the EMC Directive 89/336/EEC by complying with EN55022 and EN50081-2". This is strictly incorrect wording, but never mind - the statement that the product meets the EMC Directive is enough to mean that the manufacturer is declaring that he meets the essential legal EMC Protection Requirements. The Protection Requirements say little more than: apparatus must not have emissions that cause an interference problem with other apparatus, and must have adequate immunity to operate as intended in its intended environment when properly installed and maintained. Notice that the Protection Requirements make no mention of EMC phenomena, or of test limits or levels, or frequency ranges - they truly are DC to daylight. But what company would want to sell a product that was likely to cause interference, or might not be reliable enough in its intended operational environment? Enough background - the issue was whether to apply the discontinuous emissions tests of EN55014 even if the relevant emissions standard did not mention this. Our little look into the actual legal obligations of the EMC directive shows us that we need to apply all the standards that are relevant to the EMC phenomena that our product may emit, or be susceptible to, in order to be able to show legal due diligence in meeting the EMC Directive. Note that the phrase "apply all the standards" does not mean (when self-declaring to the EMC Directive) having a full test report from a 3rd party test lab, or even doing a test at all! More on the general topic - for those who have read this far: The problem is that, historically, countries have applied technical barriers to trade which required importers to meet the test requirements set by their own national test laboratories. But the EMC Directive is different, it effectively says: we leave it up to you to be an honest manufacturer using due diligence in meeting the essential requirements of the Directive, but if we find that you are not using due diligence or your products caue or suffer interference (whether they have met a harmonised standard or not) we reserve the right to suspend all sales of your product(s) from the entire EU market, including those in the distribution chain, and/or apply other legal remedies such as fines, product recalls, etc. This is known colloquially as "speak softly but carry a big stick". All the CE marking Directives include similar essential legal requirements which spell out the spirit of the Directive in terms that make it difficult for lawyers to argue about what the law is meant to achieve. All the CE marking Directives also include "routes to a presumption of conformity" - for example: self-declaration to EU harmonised standards, but it is very important to realise that IN THE EU, COMPLIANCE WITH A STANDARD IS NOT A GUARANTEE OF CONFORMITY WITH THE ESSENTIAL LEGAL REQUIREMENTS. Standards are always a compromise, and a good example is the generic immunity standards which specifically state that they do not cover situations where a mobile radio transmitter (such as a cellphone or walkie-talkie) or ISM equipment is used in proximity. Likewise the generic emissions standards, and EN55022 as well, state that they do not cover situations where sensitive apparatus is used in proximity. The words "sensitive" and "proximity" are not defined and it is up to the manufacturer to determine whether his product is likely to be used in such situations and take the necessary steps, maybe limiting the sales or use of his product, maybe giving it EMC performance that goes beyond the obvious harmonised standards, IN ORDER TO MEET THE DIRECTIVE! I hope this helps the discussion along, by explaining the reasons behind Richard's approach. EurIng Keith Armstrong Partner, Cherry Clough Consultants Member of EMC-UK phone: +44 1457 871 605 fax: +44 1457 820 145 Email: [email protected] EMC-UK may be contacted on [email protected] WOODS, RICHARD wrote: > > Let's take an example - a motor operated business machine that contains > digital logic. In my opinion, it must be judged under the generic emissions > standard because it produces both continuous and discontinuous interference. > The applicable sections of EN55022 and EN55014 must be met. The same would > apply if you had a motor operated ISM device except that EN55011 and EN55014 > would apply. > > > ---------- > > From: F.Goto[SMTP:[email protected]] > > Reply To: F.Goto > > Sent: Friday, July 17, 1998 6:11 AM > > To: [email protected] > > Subject: EN61000-3-2, EN55022 and EN55011 > > > > Dear Group, > > > > Here are a couple of questions from our EMC department. > > > > 1) EN61000-3-2 Clause 7.4. states that "The limits given in table 3 are > > valid for all applications having an active input power >75W. No limits > > apply for equipment with an active input power up to and including 75W. > > This lower limit of 75W will be reduced to 50W, four years after the > > implementation date of this standard." Does anyone know when this 4 year > > period starts? (from 1995 when the standard was issued, or from January > > 1, > > 2001 when the standard becomes mandatory? > > > > 2) Can someone make clear the discontinuous interference limits for > > EN55022,EN55011? Generic standards (EN50081-1 and EN50081-2) has limits > > for > > discontinuous interference referencing EN55014, but EN55022 nor En55011 do > > not. Another complication arises when there is a specific product > > standard, > > in which case we shouldn't use a generic one. > > > > Any help on the above will be appreciated. > > > > Sincerely, > > Frank F. Goto > > A-pex International Co., Ltd. > > 1st Engineering Department > > 248-1 Kusube-cho > > Ise-shi, Mie-ke 516-0014 > > Japan > > Tel: +81-596-24-6717 > > Fax:+81-596-27-5631 > > [email protected] > > http://a-pex.co.jp > > > >
