The EMC Directive is one of the most significant documents to impact the global electronics industry since it became mandatory on Jan. 1, 1996. After being in force these past 18 months, it is now time to clarify some of its rules.
To update you on the status of the EMC Directive, here’s what happened during a workshop held on Feb. 19, 1997, in Zurich, Switzerland. The speakers, from the European Commission, individual country governments, competent bodies (CBs), and industry, addressed the current status of the EMC Directive and offered some insight into the future.
Elenia Santiago, a spokesperson for the commission, discussed the EMC Directive guidelines being revised by the commission and expected to be published later this year. Most significant were her comments that reason and logic are being applied to the application of the EMC Directive. She introduced the EMC decision flow chart to assist you in making logical decisions about complying to the EMC Directive (Figure 1).
Following Ms. Santiago’s talk, Gerd Jeromin from the German Federal Office for Post and Telekommunikations (BAPT) spoke on present and future enforcement activities in Germany. The activities include verifying compliance by testing and keeping records on products. The BAPT procedure:
Monitors compliance with the EMC Directive requirements.
Monitors compliance with the marketing requirements.
Takes necessary steps to initiate changes the manufacturer must implement; prevent equipment from being placed on the market, if necessary; and require equipment to be withdrawn, if necessary.
The BAPT has established 54 regional offices managed by 160 people to test products. Each of the 54 offices has a spectrum analyzer for performing on-site testing for emissions. Products suspected of having immunity problems will be forwarded to the Mark Laboratory in Berlin for additional testing.
After a product is reviewed by the BAPT, information is entered into a data base describing:
The reason for the check.
The type of equipment and model number.
The year of manufacture and serial number.
The manufacturer and company marketing the product.
What markings were affixed.
What measurements were made and the corresponding results.
Mr. Jeromin explained that approximately 1,500 data sheets are generated each month. Of them, 750 are forwarded to the regional offices that regulate the company responsible for meeting the requirements or that place the equipment on the market. He stated that 10,060 products were tested in 1996, with 33% failing some portion of the review. He estimated that Germany has 30% of the European Union (EU) market, with 250 million units (electrical/electronic devices) sold each year.
He stated that Germany is taking an aggressive, proactive approach to enforcing the EMC Directive. Germany does not presume compliance simply because the CE marking is placed on the product.
Following Mr. Jeromin’s talk, members from several CBs spoke about the European Union’s Association of Competent Bodies (ACB). The ACB is similar to the U.S. Council of EMC Laboratories (USCEL). Both bodies review questions concerning the implementation of the EMC Directives.
Several manufacturers emphasized Article 10.1. It relies on harmonized standards, not technical construction files as was recommended by the CBs.
The manufacturers also discussed Amendment 12 of EN61000-3-2. This amendment, which delays the implementation of the harmonic requirements until June 1998, has been delayed itself by the commission. The amendment still is expected to be enacted; but technically, all products not complying with the harmonic requirements covered in EN61000-3-2 are considered to be out of compliance.
Manufacturers are trying to get products into compliance, but are continuing to sell them since national governments are not expected to enforce the requirement until June 1998. Ms. Santiago said Amendment 12 will be published when the certification clause is removed and a Date of Withdrawal is changed to the last date a presumption of compliance can be considered using the previous standard.
Workshop Summary
During a question-and-answer session, these topics were discussed:
Medical equipment now is covered by EN60601-1, -2, not EN50082-1 or -2.
If you have not tested your medical equipment to EN60601-1, -2 and continue to sell in the EU, you are selling illegally.
Eastern European countries (not members of the EU) will not accept the Declaration of Conformity (DoC) only, but also will want to see the test report.
The EU workshop can be summed up simply by saying the EMC Directive is in force. The authorities (namely Germany) are not just checking paperwork; they are testing products. And, if you follow a conservative, logical approach, you should have no problems.
Conclusion
All products must comply.
If you are making changes, consider retesting.
Medical products now must comply with EN60601-1, -2. If you tested to EN50082-1 or -2, you must update your testing or stop shipping products.
Ensure your DoC is in order. It must include EMC and low-voltage safety testing.
Harmonic testing will be needed on all products consuming 16-A or less as of June 1998. This may require a complete redesign.
About the Author
Donald Sweeney is the owner of D.L.S. Electronic Systems. He is a graduate of the University of Illinois Department of Electrical Engineering, and is a certified EMC engineer through NARTE. Currently, Mr. Sweeney teaches at the University of Wisconsin, serves on the Board of Directors of the IEEE EMC Society, chairs the Chicago Chapter of the EMC Society, and is founding chairman of USCEL. D.L.S. Electronic Systems, 1250 Peterson Dr., Wheeling, IL 60090-6454, (847) 537-6400.
Copyright 1997 Nelson Publishing Inc.
June 1997