Hi Lauren,
We once had a (deadly serious) inquiry for EMC testing of a arrange of sealed lead acid batteries. I know, about as inert as it gets. The manufacturer had been asked by an over zealous customs agent for proof of EMC compliance because of the CE mark (only present to cover RoHS). I saw the EMC test report that another lab had carried out with photos of battery-sat-on-table-in-anechoic-chamber and the rest. I did point out that this wasn't required but the manufacturer sighed and said we know, but it's the only way we can get batteries into that particular country. Maybe paying the lab was cheaper than paying the customs bribe. I mean bung. I mean tax. All the best James James Pawson Managing Director & EMC Problem Solver Unit 3 Compliance Ltd EMC : Environmental & Vibration : Electrical Safety : CE & UKCA : Consultancy From: Lauren Crane <[email protected]> Sent: 16 December 2025 15:32 To: [email protected] Subject: [PSES] EMC compliance for non-emitters? Dear Experts, I have a weird Customs challenge. I am trying to import to the US an LED indicator wrapped up in a small case etc. it is a part of a company's switch line up. It is essentially a lighted (LED) single pole switch block for a pushbutton, rated to operate at 24 V AC/DC. The OEM has declared the following compliance : * Resistance to fast transients 2 kV IEC 61000-4-4 * Resistance to electromagnetic fields 9.1 V/m (10 V/m) IEC 61000-4-3 * Resistance to electrostatic discharge 6 kV on contact (on metal parts) IEC 61000-4-2 8 kV in free air (in insulating parts) IEC 61000-4-2 * Electromagnetic emission Class B IEC 55011 This gives it the appearance as an item of EMC-interest, thus triggering (apparently) the import broker to flag it for the FDA import form 2877. My question is why would the switch OEM company do this? I can see why ESD and fast transients might be of interest to a switch, but why say it is compliant to an emission standard when the item in and of itself is not an emitter? I'm nearly certain it is compliant to the cited standard because it has no emissions of its own at all. Similarly one could declare these compliances for a length of insulated conductor, but it really makes no sense to do so. It does operate off of 24V AC and DC, but I doubt there are any active components doing power conversion internally. Thanks in advance for any insights you might have.. 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