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THE NEW EMC DIRECTIVE:
New
test requirements if you want to keep selling your equipment in Europe
EMC Directive
2004/108/EC Repealed
directive 89/336/EC on 20 July 2007. An overlap period of 2 years is now
allowed for the new requirements to be implemented. Note that some
requirements must necessarily be implemented immediately – see below
regarding DoC and Notified bodies. The New Standards being published to
replace the Standards previously referenced by manufacturers will have a
significant impact, with mandatory new tests that are more severe than
the previous tests.
Almost all existing and new products
will require testing/re-testing or further assessment.
Some products will need
remedial/redesign work to comply at the new levels if they are to
be sold in Europe after
01 June 2008.
Applicability of
the directive
Components no
longer have a blanket exclusion from the directive.
Article 1 (b) of the EMC Directive defines
"Apparatus" ("Apparatus" means any finished appliance, or combination
thereof made commercially available as a single functional unit intended
for the end user, and liable to generate electromagnetic disturbance, or
the performance of which is liable to be affected by such disturbance.).
According to article 2.2 "components/sub-assemblies" and "mobile
installations" are deemed to be an apparatus, under certain conditions.
Power supplies, PCI
cards, Disk drives, electric motors and PLC’s are considered as
apparatus and the directive must be applied.
Resistors,
capacitors, relays etc are not considered as apparatus and are excluded
Labelling &
Traceability
Apparatus must be
labelled with Type, Batch Serial Number or any other information
allowing unique identification and clearly correlating with the
Declaration of Conformity.
The name and
address of the manufacture must be provided in documentation and if
applicable, the name of the EC representative or the person responsible
for placing the product on the market.
Special conditions
for installation or use pertinent to EMC must be included in
documentation (Eg earthing requirements or connection of screened
cables).
EMC Assessment
Report.
The manufacturer is
responsible for producing an ‘EMC Assessment Report’
(Normally test
report applying harmonised standards but may include other
considerations / justifications)
There is no
requirement to use a Notified Body, but where a manufacturer chooses to
use one, their statement of opinion must be included in the EMC
assessment report.
Declarations of
Conformity must refer to the new directive from 20 July 2007, since the
old directive no longer exists, it is no longer possible to comply with
it.
Notified bodies
The Competent
bodies, appointed under directive 89/336/EC will cease to exist on 20
July, and will be replaced by the new Notified Bodies appointed in
accordance with 2004/108/EC.
The use of a
notified body is optional, but if used, their conclusions must be
included in the EMC assessment report.
Fixed
Installations
"Fixed installation" means a particular combination of
several types of Apparatus and, where applicable, other devices, which
are assembled, installed and intended to be used permanently at a
predefined location
By their nature fixed installations will not be subject to the need for
free movement within the European Community. Therefore they are not
subject to the requirements for CE marking or the need for a declaration
of conformity or for a formal EMC assessment before installation (DTI
draft guidelines)
It is necessary
to be able to demonstrate that good EMC engineering practice has
been applied in the installation. It is recommended that records of EMC
measures be maintained.
The directive
describes a ‘Responsible Person’ who is responsible for the
compliance of the installation.
Changes to
Standards
Immunity
The industrial
Immunity standard (EN61000-6-2:2005) has just changed it’s requirements
for RF Immunity Testing to cover the frequency band from 150kHz to
2.7GHz (Previously 150kHz to 1GHz).
Industrial products
must comply with these new requirements by 01 June 2008 if they
are to remain on the EU market.
The standard for
Laboratory, Process Control and Measurement Equipment (EN61326: 2006)
also extends the frequency range for radiated immunity testing to 3GHz.
The date of withdrawal of conflicting standards is 01 February 2009.
All of the other
product and generic standards are expected to follow suit, whilst the
implementation timescales may be different, the requirements will be
similar.
There are also
minor changes to the requirements for Voltage dips and interruptions,
making the industrial standard slightly more onerous than it was
previously.
Emissions
A precedent has now
been set for the long overdue change in radiated emission limits to
cover frequencies above 1GHz. The Information technology standard
EN55022: 2006, has now been published, prescribing Radiated Emissions
limits up to a maximum of 6GHz for equipment utilising high clock
frequencies. Conflicting standards have to be withdrawn, and equipment
on the market must comply by 01 October 2009.
The following table
summarises the upper test frequency based on the highest frequency
present within the apparatus.
Highest
Internal Frequency Upper Test
frequency
F < 108MHz 1GHz
108MHz < F <
500MHz 2GHz
500MHz < F <
1GHz
5GHz
F >
1GHz 6GHz or 5xF
All of the Generic
and Product Specific Emission Standards are expected to change in the
same way.
It should also be noted that the new
Standards require that all products be tested for immunity and
that the pass criteria for immunity is specified by the Standard,
not the manufacturer (some manufacturers in the past decided that it
did not matter if there equipment malfunctioned during immunity
testing and thus omitted to do any immunity testing).
Do NOT leave it to late to start the up-date process, the longer you leave
it, the more it is likely to cost and the longer it will take.
Contact Epsilon
if you wish to discuss EMC testing at our fully compliant 3Ghz EMC
Test Laboratory.
ON-LINE COMPLIANCE MANAGEMENT
The Compliance Management System has been created to assist Epsilon
customers maintain their product and quality system compliance in
line mandated regulatory requirements The
system records the Standards, Directives and 3rd party
Certification that products claim to be complaint with together with
quality criteria needed to manufacture those products (for example,
and ATEX Quality Module or lodged Technical Dossier). This
information is checked and entered by Epsilon so that on the day of
entry, you are assured that you meet the necessary criteria
to be able to put your product on the market in the EU under the
ATEX and other CE Directives on the day of entry.
The system can also generate a current template ‘Declarations of
Conformity’ for each product at the push of a button that can be
printed for use.  Epsilon
monitors all Directives and Standards on our system for changes. If
something changes that affects your product, you are notified
automatically and actions that require attention are highlighted in
your product list. When Directives or Standards are amended or
withdrawn, Epsilon will attach a guidance document informing you of
what you need to do. The system will also notify you automatically
if your Quality Assurance requires attention.
For minor actions that require no testing, Epsilon can add
‘concessions’ to your certificates or files that allow you to
demonstrate that you continue to meet the ‘state of the art’
requirements without having to update certificates or files
manually. The concession service can also be used for small changes
that you make to your products that do not require a full variation.
The concession service is free whilst subscribed to the
Compliance Management System. Each Epsilon
customer has a unique log in and password to access information on
their company and products. This can be changed under the ‘Company
Details’ menu. Initial View  The
initial view will show all current records for your company with a
search function to find what you need quickly. Use the drop downs in
the search function to select a criteria for search (a full Boolean
search feature is available to narrow the search).
Product View Clicking ‘View’ to the
left of any listed product will take you to the product details.
The main page tab will show subscription details, and any required
Quality Modules for the product.  The
Directives tab will show the Directives that are currently applied
to this product, it will also show any superseded Directives for the
product. The Standards tab will show the Standards that are
currently applied to this product, it will also show any superseded
Standards for the product. Other applied
criteria allows recording and monitoring of other mandated
regulations (such as the Noise Directive). Under ‘Certificates’, the
current Certificates used to demonstrate compliance are recorded.
Certificate details can be viewed to see the current variation level
and any concessions permitted on the certificate.
General Information The system can
be searched to find information on the current Directives and
Standards even if they are not currently used for your products. The
system is populated with the most frequently required Directives and
Standards including update histories, downloadable Directive details
and the current list of Harmonised ATEX Standards. This system is
also populated with the most frequently used CE Standards.
Technical Interpretations Under
Technical Interpretations you can search for the latest technical
guidance and Standards interpretations from Epsilon and the European
Notified Body Group. On-Line Expert
On this page you can search for answers to your technical and
general questions, Epsilon will frequently update this section to
form a true ‘expert’ system that should be your first port of call
for technical questions. If this does not answer your question you
can ask us directly using the on-line ‘contact us’ form.
Additional Information on ATEX Compliance
ATEX is a CE marking Directive, and as such, compliance is
demonstrated by a Declaration of Conformity and a Technical File or
Dossier. Within the Technical Dossier there will often be the
requirement to have a ‘Notified Body’ Certificate (for example, Zone
0 or 1 Electrical Equipment), but this alone may not meet the
requirements for the Technical Dossier and ultimately, the
manufacturer always ‘self declares’ that they meet ATEX, even with
the support of a Notified Body Certificate.
It is important to note that the declaration is made on the day the
product is placed on the market, not the day that the certificate
was issued or the technical dossier was created, and the technical
dossier must reflect the ‘state of the art’ (current practice) on
the day the item was placed on the market.
Annex II of the directive “The Essential Health and Safety
Requirements” (EHSRs) makes the
following statement: Technological
knowledge, which can change rapidly, must be taken into account as
far as possible and be utilized immediately.
‘Technological knowledge”, is generally based on the European
standards that have been given “Harmonised” status for the directive
by having their number published in the Official Journal of the
European Communities (OJEC) The Declaration
of Conformity is required to list the use of harmonized standards
(and other standards). It therefore follows that, throughout the
lifetime of a product range, the relevant declaration may have to
change to reflect withdrawn and updated Standards.
It is explicitly stated that withdrawn or superseded Standards
should not be used to ‘presume’ conformity with ATEX. With that in
mind, the ‘minimum’ requirement for changes in Standards listed in
Declarations and/or Certificates will be to check to see if the
changes affect the initial assumption of conformity (have there been
any changes that may affect the construction, assessment or testing
of the product). This assessment must be recorded in your technical
dossier and the Declaration of Conformity.
If any change affects the test or assessment required by a Notified
Body, then you should seek a variation to your certificate to
include these changes and align your certificate with the
Declaration of Conformity. Indeed, even if the changes do not affect
certification, you may find the lack of alignment between the
Declaration and the Certificate unacceptable to buyers, who are
checking new products against the ‘current’ list of Harmonised
Standards. |
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 The
codified version of the Low Voltage Directive has been published in
the OJEU L374 (27 December). This means that as from the16th
of January, the old 73/23/ECC directive is repealed and the new
Directive 2006/95/EC of 12 December 2006 on the harmonisation of the
laws of Member States relating to electrical equipment designed for
use within certain voltage limits enters into force. In practice,
this means that:
1.Member States are not obliged to transpose
this new directive, whose content does not alter the substance of
the provisions contained in the act that has been codified
2.Products placed on the market before the 16/01/2007 are of course
unaffected
3.For products placed on
the market after the 16/01/2007: all explicit references to the LVD
in the DoC, instructions for use, technical file, etc., are expected
to be replaced by references to the new Directive 2006/95/EC.
However, as there is no substantial change to the provisions of the
Directive, the European Commission and Member States representatives
confirmed at the last LVD working party of 15/11/2006 that the above
mentioned changes would be enforced in a reasonable manner, taking
into account the principle of proportionality and the need to avoid
creating unnecessary costs for manufacturers. For instance, it would
be unreasonable to require manufacturers to change all references to
the LVD in the existing documents attached to products which have
already been placed on the market under Directive 73/23/EEC and are
expected to continue to be placed on the market after the
16/01/2007, for which documents may have already been printed in
large quantities, taking into account future production as well.
Click here to download the new Directive.
Epsilon to run FREE training and update seminars for UK
ATEX Manufacturers. Epsilon will be
providing several free training sessions on how to achieve cost
effective ATEX certification and understanding CE Marking. 8 Free half
day courses will be run throughout 2007. Epsilon will
also be providing six monthly ATEX update seminars free of charge to all
ATEX manufacturers advising on the current 'state of the art'
methodologies, news from technical committees and the Notified Body
groups and other related matters. On line booking
will be available from January 2007. Contact us
if you require further information.
More free 'Compliance Update' seminars to be run starting in Houston,
Texas. Due to overwhelming demand, Epsilon
is providing another series of update seminars in Houston, Texas. The
seminars, starting from November 5th, currently have over 130 delegates
attending from some of the most prestigious (and busy!) companies
in Houston. The seminars will cover: CE Marking of
Assemblies (PED, LVD, EMC and ATEX)
ATEX and Protective Systems
An
update on the latest European and IEC Standards
An update on new or
changing European Directives
An update on the current surveillance
(checking) of products for CE and ATEX
Open Questions
The seminars are being run through Epsilon Inc., our US Incorporated
Company that is focused on providing the best support for North American
companies available from any CE, IEC and ATEX Notified Body. Epsilon has
had offices in Houston for over seven years, and even has a
company apartment for our visiting Engineers from Epsilon in the UK (who
frequently relocate to Houston for the duration of projects to work
directly with our customers). We understand the products, markets and
needs of our customers in Houston having CE Marked, IEC and ATEX
Certified most items of Oil and Gas equipment including top drives,
BOP's, pipe handling equipment, turbines and control rooms including on
site certification of equipment offshore oil rigs and FSPO's.
Additional seminars are being held in Aberdeen, New York, Calgary and
Singapore in 2007. Please
contact us if you would like to attend an open seminar or have one
in-house at your company (for example, as a lunch and learn).
Free Seminar on ATEX and CE Changes in Houston, Texas.....Download the
overheads  Epsilon
recently gave several seminars in Houston Texas on the forthcoming
changes in ATEX and other CE Marking
Directives. The 1/2 day open courses were fully booked with 50+
delegates per course. Several 'in house' courses were also run for
companies such as Schlumberger.
The overheads for the course are now being provided FREE
Click here to open the update course in PDF.
EMC Directive to be replaced...many existing products
will require re-testing EMC
Standards and Directive are changing…many existing products will require
re-testing. New EMC Standards are being produced that will require many
products to be retested to higher frequencies if you wish to continue to
sell them in Europe. The new higher frequency tests reflect the growing
use of higher frequency communication technologies, including Bluetooth
and Wi-Fi. The EMC directive is also being replaced and this may require
changes in your compliance documentation. Click the picture to see the
new EMC directive in full (PDF)
More information can be found in the free seminar update file. | 
