Annex II of the EMC Directive states, "The manufacturer must take all measures 
necessary to ensure that the products are manufactured in accordance with
the technical documentation referred to in point 3 and with the provisions of 
this Directive that apply to them." Now, what has to be done to insure this 
requirement is met will differ between different companies depending on the 
product, the quantity that is produced and how much control there is over its 
overall construction or makeup. Some companies do a lot, some do very little.

No matter what steps are taken by a company, a non-compliant product making it 
to market hurts us all. The failure of just a few companies will result in 
bureaucrats piling on more overburdening requirements on everyone.  So do as 
much as you can within reason.

As already mentioned, the key is having a good technical person familiar with 
EMC (and other regulatory disciplines) review all possible changes to a 
product. For our company, that responsibility falls to me. I review every 
change notice and print our documentation department processes. So if any 
constructional or component change is made I can review it and decide whether 
the change can possibly affect the EMC or product safety performance. If so, 
the change is tested by our in-house EMC/Safety lab prior to making it into 
production. To be able to make such decisions is only possible because of years 
of experience, being familiar with the products and their regulatory history, 
knowing the manufacturing abilities, strengths and weaknesses, and having a 
good relationship with the engineering departments.

We also have an production audit testing schedule (PATS), where a production 
built sample is audited from each family of product on an annual bases. This 
verifies that unknown changes has not occurred in manufacturing that could 
affect compliance. Many companies do not even do production audits while others 
may audit more often than annually. It all depends on many factors which your 
technical person must be able to determine.

Hope this was helpful.

The Other Brian

From: [email protected] [mailto:[email protected]] On Behalf Of Luke Turnbull
Sent: Thursday, July 11, 2013 5:35 AM
To: [email protected]
Subject: Production Assurance Tests for EMC

Dear Group,

I have familiarity with how the aerospace and automotive industries deal with 
testing and manufacture of systems, but am less familiar with products tested 
to commercial standards.

What is the custom and practice for demonstrating continued compliance to EMC 
requirements for products that are in production for a long time?  I assume 
that over time, the construction of e.g. capacitors may change - leading to 
different stray characteristics, even for the same manufacturer and component 
value; and that IC's may be functionally similar, but again have a different 
internal construction.  Do system suppliers generally re-test for EMC when 
components become obsolescent?  Do system suppliers generally re-test 
periodically in case components have been unknowingly changed, or in case 
production processes have been changed without considering their effect on EMC 
compliance?

Thanks for your help.


Dr Luke Turnbull
EMC Technical Manager
TRW Conekt
Stratford Road
Solihull
West Midlands B90 4GW
United Kingdom

Tel:        +44 (0)121.627.3966

email:  [email protected]<mailto:[email protected]>
web:     www.conekt.co.uk<http://www.conekt.co.uk>



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