Hi Tin.
<< I am interested in knowing the basis of your response to items 1 and 2, as
it is contrary to my understanding of the EMC Directive.>
I carefully qualified my comments with the words, 'In the UK'. The UK view
on the EMC Directive is put into UK law in the form of The Electromagnetic
Compatibility Regulations, Statutory Instrument SI 1992/2372. In Part IV
(The Standards Route to Compliance), clause 37, it states that:
"The conformity assessment requirements are complied with pursuant to the
standards route to compliance if the manufacturer has applied an applicable
EMC standard which makes, or all applicable EMC standards which make,
complete provision in respect of the apparatus."
Clause 38 then goes on to specify applicable standards. What the UK Regs
effectively state is that you need to comply with ALL the relevant standards,
and make a formal declaration that you have done so. This is the self
certification operation - you build the equipment to all the relevant
standards (EMC, LVD, Machinery, Medical Equipment etc. etc. EMC Standards
are mutually exclusive, you need not meet both LVD AND Medical directives,
just the most relevant) and make a legal declaration that you have done so.
There is no strict requirement to provide test results to support the
Declaration, though if the equipment is EMI active it's difficult to know how
the Regulatory Authorities may be convinced that your declaration is sound
without test results. If the equipment runs at low frequencies and very low
power, it is reasonable to predict that the emissions will be very low, for
instance.
You are quite correct when you say that if all the standards are not met,
then the TCF route should be followed, the implication being that the
standards CANNOT be met rather than just the tests not carried out.
Remember that the purpose of the EMC Directive is not to reduce the EMI
'smoke' around Europe, but to ensure that no Nation State gets a commercial
advantage over another by allowing looser technical standards. If a machine
makes more interference than the Standards permit, then a TCF must be
produced that describes the equipment sufficiently that the Competent Body is
happy to take responsibility for the fact that as much has been done as
possible to reduce interference to a minimum. This is the whole point of the
Treaty of Rome and open borders, the Euro Directives are essentially a
trading tool, not a technical one.
< I am interested in learning whether UK has established an updated position
which allows manufacturer to waive testing (altogether) and still
self-declare conformity to the EMC Directive through the standards route?>
I'm not aware that the UK position has changed at all since 1996, but testing
itself is not an actual requirement in UK Law. Self declaration means making
a legal declaration which if proved deliberately wrong, means a stiff fine,
or even Jail in some circumstances.
Chris Dupres
Surrey, UK.
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