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Electronic Directives FAQ |
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Electronic Directives FAQ |
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The electronic directives are applicable to several boat components and accessories. In addition, many of the questions and comments in the FAQ (frequently asked questions) apply to the Recreational Craft Directive as well.
The electronics field is much more "into" the internet than the boat builders. They have created the internet newsgroup sci.engr.electrical.compliance to deal with the issue of electrical compliance with standards. This approach would have / could be an excellent way for boat builders to address their concerns about the Recreational Craft Directive, except, many boat builders are not yet online.
A Mr. Bill Lyons at IEEE has with the assistance of several other people (listed at the bottom of this page) used the newsgroup and additional information to create a FAQ (Frequently Asked Questions) file that is posted on the sci.engr.electrical.compliance newsgroup. The FAQ is updated in the newsgroup about once a month. It is also posted on the net at http://world.std.com/~techbook/compliance_faq.html. http://world.std.com/~techbook/compliance_faq.html. We suggest you read it on the newsgroup or their web post to get the "official version". We have noticed their web site is not updated as fast as the newsgroup site. Since some of you have trouble accessing the newsgroup and their web site seems busy at times, we reproduced his 15 June 1997 edition below.
Supersedes: <863709519snz@lyons.demon.co.uk> #
Last Posted: Thu, 15 May 97 15:18:39 GMT #
URL: http://world.std.com/~techbook/compliance_faq.html
Textfile: http://www.lyons.demon.co.uk/seecfaq1.txt
FAQ: SOURCES OF EMC AND SAFETY COMPLIANCE INFORMATION - PART 1
First posted: April 17, 1996
Fifteenth issue: June 15, 1997 #
CONTENTS - PART 1 (THIS PART)
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
1.1 Introduction
1.2 Journals devoted wholly or mainly to EMC and safety compliance
1.3 Conferences and Exhibitions
1.4 Listservers
1.5 WWW Sites
1.5.1 Non-commercial
1.5.2 Commercial Web sites carrying useful EMC/safety information
1.6 Standards Organizations
1.7 Specifications for Safety and EMC Compliance
1.8 Books and Guides
1.9 CE Mark
1.10 Australia and New Zealand
1.11 Official & Quasi-official Advice
CONTENTS - PART 2
~~~~~~~~~~~~~~~~~
2.1 The sci.engr.electrical.compliance newsgroup
2.1.1 Background and History
2.1.2 Charter and Rationale
2.1.3 Guidelines
2.2 European Voltage Harmonisation
2.3 Commonly-asked Questions and Answers about the EMC Directive
2.4 The Low Voltage Directive (LVD)
Acknowledgments
1.1 INTRODUCTION
~~~~~~~~~~~~
Welcome to sci.engr.electrical.compliance (s.e.e.c).
This is the FAQ for the sci.engr.electrical.compliance newsgroup. It
supersedes the "Pre-FAQ: Sources of EMC & Safety Compliance Information"
which was posted to sci.physics.electromag monthly from January 15, 1996
until April 4, 1996 pending the establishment of the s.e.e.c newsgroup.
Since some newsreaders have difficulty with articles approaching or
exceeding approx 64k in length, this FAQ has now been divided into two
parts. This is Part 1.
This FAQ was created by, and is currently maintained by, Bill Lyons
<Bill@lyons.demon.co uk> or <w.lyons@ieee.org>, who welcomes suggestions
for additions or amendments.
It will be posted to s.e.e.c approximately monthly, with pointers in the
following related newsgroups:
sci.electronics.misc sci.electronics.design
sci.engr.electrical.sys-protection sci.physics.electromag
alt.engineering.electrical
and the following mailing lists:
emc-pstc@ieee.org treg@world.std.com
The latest issue of this FAQ is archived at:
http://world.std.com/~techbook/compliance_faq.html
PLEASE ADVISE CORRECTIONS OF ANY ERRORS YOU MAY DETECT, OR SUGGESTIONS OF
ADDITIONAL USEFUL INFORMATION, AS INDICATED AT THE END OF THIS FAQ.
N.B. A hash mark (#) in the right-hand margin indicates new or modified
information since the previous issue.
1.2 Journals devoted wholly or mainly to EMC and safety compliance
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
(Additionally many, perhaps most, electrical/electronic journals include
articles, sections or features on EMC/compliance) NB: L = UK pounds
APPROVAL - "The engineering guide to European quality, standards
and regulations"
6 issues per year - UK L39, EU L48, RoW L55 p.a.
M & M Business Communications Ltd
Lime Tree House, Lime Tree Walk, Sevenoaks, Kent TN13 1YH, UK
Adrian McLeod, Editor
Tel: +44 (0)1732 746 616
Fax: +44 (0)1732 746 617
email: approval@cix.compulink.co.uk
URL: http://www.cix.co.uk/~approval
Subscriptions/advertising: +44 (0)1732 746 616
COMPLIANCE ENGINEERING
"The magazine for international regulatory compliance"
Bimonthly, no charge to qualified persons
One Tech Drive, Suite 215, Andover, MA 01810, USA
email: ce@ultranet.com
URL: http://www.ce-mag.com
Phone: +1 (508) 681-6600
Fax: +1 (508) 681-6637
Subscriptions: on-line (see email address and URL above) or
Phone: +1 (508) 681-6627 (Kelly-Ann Riley)
Constance Brown, Publisher (email cbrowne@ultranet.com) 508-681-6642
Mark Jurgen, Assistant Editor (email mjurgen@ultranet.com)
Editorial Board, Bill Fiske, Dag Bjorklof, Roland Gubisch, Ph.D.,
Spencer Hutchens, Robert Martin, Paul Scicchitano, Don Sherratt
Production, Lisa Holovnia
Advertising Managers, Mike Costa, Mike Mintzer, Carolyn Belanger
Standards and Publications, Patricia LeBlanc
COMPLIANCE ENGINEERING, EUROPEAN EDITION
No charge to qualified persons
Unit 10, Mansfield Park, Cranleigh, Surrey GU6 8PY, UK
Phone: +44 (0)1483 488 408
Fax: +44 (0)1483 488 447
EMC ENGINEERING EUROPE
Published 6 times per year
Miller Freeman plc, Miller Freeman House
30 Calderwood Street, London SE18 6QH, UK
Phone: +44 (0)181 855 7777
Fax: +44 (0)181 854 8814
email: cz69@cityscape.co.uk
URL: http://www.dotelectronics.co.uk/
THE EUROPEAN EMC JOURNAL
Published 6 times per year (bimonthly from mid-February)
UK: no charge to qualified persons
Europe/Rest of World: L50 per year (6 issues) incl post/packing
Nutwood UK Ltd, Mansel Court, Mansel Gamage, Hereford HR4 7LE, UK
email: nutwooduk@msn.com
URL: http://www.emc-journal.co.uk/
Alan E Hutley, Publisher
Dave Fynn, News & Features Editor
Phone: +44 (0)1981 590481
Fax: +44 (0)1981 590223
Malcolm A Burchall, Technical Editor
Phone: +44 (0)1628 778446
Fax: +44 (0)1828 788294
IEEE ELECTROMAGNETIC COMPATIBILITY SOCIETY NEWSLETTER
Quarterly: no charge to IEEE EMC society members.
The Institute of Electrical and Electronics Engineers, Inc.
445 Hoes Lane, PO Box 1331, Piscataway, NJ 08855-1331, USA
Phone: +1 908 981-0060
Fax: +1 908 981-9667
Telex: 833-233
email: member.services@ieee.org
IEEE TRANSACTIONS ON ELECTROMAGNETIC COMPATIBILITY
The Institute of Electrical and Electronics Engineers, Inc.
445 Hoes Lane, PO Box 1331, Piscataway, NJ 08855-1331, USA
Phone: +1 908 981-0060
Fax: +1 908 981-9667
Telex: 833-233
email: member.services@ieee.org
Motohisa Kanda, Editor (NIST)
INTERFERENCE TECHNOLOGY ENGINEER'S MASTER (ITEM) MAGAZINE
Published twice annually as ITEM and ITEM Update
No charge to qualified persons
Robert D Goldblum, Editor
R & B Enterprises, 20 Clipper Road,
West Conshohocken, PA 19428-2721
Phone: +1 610 825-1960
Fax: +1 610 825-1684
email: rbent@pipeline.com
INTERNATIONAL PRODUCT SAFETY NEWS (ISSN 1040-7529)
"The Newsletter Devoted to Product Safety Compliance"
Published six times a year
Product Safety International (PSI)
PO Box 1561-PFAQ, Middletown, CT 06457-8061, USA
Phone: +1 860 344-1651
Fax: +1 860 346-9066
email: ipsn.pfaq@safetylink.com
URL: http://www.safetylink.com
"The Safety Link is the Internet's most comprehensive collection of
(electrical) product safety and standards links"
Arthur E Michael, Editor
SAFETY AND EMC NEWSLETTER
Published bimonthly. L120/$208 p.a.
ERA Technology Ltd
Cleeve Road, Leatherhead, Surrey KT22 7SA, UK
Phone: +44 1372 367014 (publication sales)
+44 1372 367000 (switchboard)
Fax: +44 1372 377927
Natalie Wood, Editor
1.3 Conferences and Exhibitions
~~~~~~~~~~~~~~~~~~~~~~~~~~~
N.B. CD-ROMs, formerly listed here, are now included in Paul Bennett's
"FAQ: Safety and EMC Compliance - Books and Guides" (see section 1.8)
EMC YORK '97 #
CE Marking and EMC Conference and Exhibition #
University of York Heslington York YO1 5DD UK #
Monday 14 July 1997 #
#
Chris Marshman, York EMC Services Ltd, Department of Electronics #
Tel: +44 1904 434 440 #
Fax: +44 1904 434 434 #
email: enquiries@yes.york.ac.uk #
URL: http://www.emcnet.com/uoy/ #
#
#
1997 IEEE INTERNATIONAL SYMPOSIUM ON ELECTROMAGNETIC COMPATIBILITY
Austin Convention Center Austin Texas USA
August 18-22, 1997
URL: http://www.emctest.com/ieee97
Technical Papers & Program: Edwin L Bronaugh, EdB EMC Consultants
Tel: +1 512 258 6687 Fax: +1 512 258 6982
Exhibits: Mark J Prchlik, EMC Test Systems, L.P.
Tel: +1 512 835 4684 ext 741 Fax: +1 512 835 4729
mark.prchlik@emctest.com
Registration:
All About Meetings, 1650 S Pacific Coast Highway, Ste 209
Redondo Beach, CA 90277, USA
Tel: +1 310 316 5153 (questions only - no telephone registrations)
Fax: +1 310 316 0713
10TH INTERNATIONAL CONFERENCE ON ELECTROMAGNETIC COMPATIBILITY
University of Warwick, UK
September 1-3, 1997
L Hudson, IEE, Savoy Place, London WC2R 0BL, UK
Tel: +44 171 240 1871
Fax: +44 171 497 3633
#
Further information about this event is available at: #
URL: http://www.iee.org.uk/LSboard/Conf/EMC97/ #
#
The "call-for-papers" deadline has now passed and a provisional programme #
will be added to the WWW pages shortly. #
19TH ANNUAL EOS/ESD SYMPOSIUM
Santa Clara Convention Center CA USA
September 23-25, 1997
Koen Verhaege
Tel: +1 609 734 2344
Fax: +1 609 734 2565
email: kverhaege@sarnoff.com
EURO-EMC 1997
Sandown Park Exhibition Centre UK
October 7-9, 1997
Reed Exhibition Companies
Tel: +44 181 910 7883
URL: http://www.nepcon.co.uk/euroemc/
1998 IEEE INTERNATIONAL SYMPOSIUM ON ELECTROMAGNETIC COMPATIBILITY
Denver Colorado USA
R Barry Wallen +1 303 682 6600 bwallen@intellistor.com
1.4 Listservers
~~~~~~~~~~~
EMC-PSTC EMC-PSTC Regulatory E-Mail Grapevine
Hosted by the IEEE, the EMC-PSTC is an informal group of
people interested in Product Safety regulations and
standards world-wide, networked electronically by mailing
list. Its purpose is to provide a forum for the sharing of
public, but possibly obscure Product Safety or Regulatory
Compliance information, or related information with limited
natural distribution. All mail sent to the Internet
address will be immediately echoed to everyone on the list
by an automated list server.
for subscription info send email to:
majordomo@majordomo.ieee.org
containing in the body of the message only the words:
info emc-pstc
(no subject header needed)
Information on EMC-PSTC is also available at URL
http://uc.com/compliance_engineering/pstc_db.htm
TREG: Telecom Regulatory E-Mail Grapevine (TREG)
TREG is an informal group of people interested in
telecommunications regulations and standards world-wide,
networked electronically by mailing list. Its purpose is
to provide a forum for the sharing of public, but esoteric
or possibly obscure telecom compliance information, or
related information with limited natural distribution.
Members need only send contributions to:
treg@world.std.com
All mail sent to this Internet address will be immediately
echoed to everyone on the TREG list by an automated list
server.
SUBSCRIBING OR UNSUBSCRIBING - Send an Internet e-mail
request with the phrase "subscribe treg" or "unsubscribe
treg" in it to:
majordomo@world.std.com
BILLBOARD: Billboard is a telecom newsletter published by Bill von
Alven of the FCC. Bill is head of the United States of
America's Federal Communications Commission CFR Title 47
Part 68 telecommunications registration section and
publishes an informative industry newsletter on a monthly
basis. To subscribe send:
subscribe billboard
to: majordomo@world.std.com
CONFORMITY A Monthly Newsletter for Electronic Products
Compiled by Jon Curtis, Director of Engineering of Curtis-
Straus LLC, CONFORMITY is: "A free monthly newsletter
summarizing the regulatory issues that cross my desk.
Since I also distribute treg and wish treg to remain
absolutely non-commercial, I have set up a separate
emailing list for my newsletter." If you want to get the
newsletter via email, you should send:
subscribe Conformity
to: majordomo@world.std.com
E-SAFETY Electrical Safety Email List
Rene Schmit <rene.schmit@crpht.lu> writes:
I have just installed an email list for discussions about
electrical safety (see charter below).
------- e-safety Email List Charter -------
The purpose of this email list is the discussion of topics
related to product safety in general and electrical safety
in particular. Possible discussions include standard
interpretations, product design guidelines, product
certification, product marking and legal aspects.
Typical members of this list are product design and safety
engineers, test house engineers and standardisation
commitee members. Newcomers as well as experts are welcome
to participate in the discussions. This list will
initially be unmoderated, but this could change in the
event of an unacceptably high noise/signal ratio. The
number of subscribers is unlimited, a splitting of the list
is however possible. For example, a separate list for
household appliances and information equipment might be
possible.
How to subscribe:
Send email to: majordomo@dorado.crpht.lu
Subject: None
Message: subscribe e-safety
In return, you will receive your subscription confirmation
How to write a letter to the 'list':
Send a simple email to the following address
e-safety@dorado.crpht.lu
1.5.1 WWW Sites - Non-commercial
~~~~~~~~~~~~~~~~~~~~~~~~~~
STANDARDS ORGANISATIONS: #
ANSI http://www.ansi.org/docs/home.html #
BSI http://www.bsi.org.uk #
ETSI http://www.etsi.fr #
IEC http://www.iec.ch #
ISO http://www.iso.ch #
ITU-T http://www.itu.ch #
#
AEDC - The Australian Electronics Development Centre's
EMC homepage: http://www.aedc.com.au/emc
Approval: http://www.cix.co.uk/~approval
"The engineering guide to European quality, standards and regulations"
Includes DTI (UK) guidance notes on the EMC Directive and the LVD, and
a list of EMC standards at http://www.cix.co.uk/~approval/emcstan.htm
Compliance Engineering: http://www.ce-mag.com
Defence Research Agency, UK (aerospace EMC)
http://dspace.dial.pipex.com/town/plaza/gs66/index_fr.htm
#
The European EMC Journal http://www.emc-journal.co.uk/
A draft version of the new "Commission Guidelines" for EMC can be found at
http://www.emc-journal.co.uk/newguide.html
WARNING! read with great caution: contains numerous errors
~~~~~~~
European Organisation for Testing and Certification (EOTC):
http://www.eotc.be/
email: ticqa@eotc.be
Federal Communication Commission (FCC), USA:
http://www.fcc.gov/oet/info/rules
FCC rules and regulations on-line (downloadable free)
A list of EMC test labs on file with the FCC is available at URL:
http://www.fcc.gov/oet/info/database/testsite/
IEEE Electromagnetic Compatibility Society:
http://www.emclab.umr.edu/ieee_emc/
Jet Propulsion Laboratory http://emlib.jpl.nasa.gov
Low Voltage Directive - full text:
http://www.safetylink.com/lvd.asc
National Electronics Technology Centre (NETC),
Forbairt, Dublin, Ireland
http://www.netc.ie/
National Physical Laboratory, UK (RF/MW news, incl. antenna calibration)
http://www.npl.co.uk/npl/cetm/rfmwnews
National Weights and Measures Laboratory, UK:
http://www.dti.gov.uk/nwml
Northeast Product Safety Society, Inc:
http://www.safetylink.com/npss.html
PQ-Chat (Electrotek PQ-net): http://www.electrotek.com
Regulatory Compliance Information Center (RCIC):
http://www.rcic.com/
Rudi Logghe <rlogghe@club.innet.be> maintains an interesting EMC page
covering Standards and Directives, Consultancy, Universities and
Manufacturers at: http://www.club.innet.be/~year2138/emc.htm
Safety Link: http://www.safetylink.com
"The Safety Link is the Internet's most comprehensive collection of
(electrical) product safety and standards links"
Spectrum Management Agency (Australia):
http://www.sma.gov.au/spectrum/comply/emc/index.htm
The Australian EMC Framework (downloadable free)
Test & Measurement World http://world.std.com/~techbook/emclinks.htm
"Links to info on the EMC Directive. The links are to noncommercial
sites where you can find technical info such as what are the standards
applicable to the EMC Directive. Also a link to the column 'Can You
Afford the CE Marking?'"
University of Missouri-Rolla Electromagnetic Compatibility Laboratory
http://www.emclab.umr.edu
University of Warwick ATC EMC Group (esp. automotive EMC testing)
http://www.warwick.ac.uk/~esrjo/robert.html
1.5.2 Commercial Web Sites carrying useful EMC/safety related information
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
BABT (British Approvals Board for Telecommunications:
http://www.babt.co.uk/
Claude Lyons Limited http://www.lyons.demon.co.uk/epsma.html
CE Marking on Power Supplies - Guidance from the EPSMA (see also
Section 1.11 of this FAQ, "Official & Quasi-official Advice")
Compliance Online - a monthly electronic newsletter for environmental
regulatory compliance. http://www.ieti.com/taylor/compliance.html
Conformance http://www.conformance.co.uk
Includes a full list of the 'CE Marking Directives' and the UK
legislation which enforces them.
Emcnet http://www.emcnet.com
EMC acronyms http://www.emcnet.com/emc4.htm
EPL Ltd. http://www.epl.co.uk
Telecoms/EMC/safety approvals info & telecoms test equipment
Horrocks Technology
http://ourworld.compuserve.com/homepages/Horrocks_Technology
Info on European Regulatory and Policy Documents on disk or CD ROM.
KTL - info on LVD and EMC http:/www.ktl.co.uk/ktl/cemark.htm
Patton & Associates, Inc http://www.patton-assoc.com
The CE Mark and Network Connection Mark along with instructions for
size and placement can be down loaded. Patton intend to add the
ability to down load all Approval Marks listed on this page as soon as
time permits.
List of EMC standards:
http://www.rfi.co.uk/wwwrestricted/StdBull_OJ.htm
Summary of EMC issues http://www.compulink.co.uk/~duchess/emc.htm
Technology International http://www.TechIntl.com
(CE Marking & Quality)
TUV Product Service http://www.tuvps.com
Westbay Technology http://www.emcnet.com/westbay/westbay1.htm
(demo versions of low cost pc emc packages can be downloaded)
1.6 Standards Organizations
~~~~~~~~~~~~~~~~~~~~~~~
FAQ: Safety and EMC Compliance - Organisations
Most recently posted to sci.engr.electrical.compliance on 09 Feb 1997.
Maintained by Paul E Bennett <peb@transcontech.co.uk> who will welcome
additions and amendments.
URL: http://world.std.com/~techbook/stdsorgs.htm
1.7 Specifications for Safety and EMC Compliance
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
1.7.1 FAQ: Safety and EMC Compliance - European Standards
Most recently posted to sci.engr.electrical.compliance on 09 Feb
1997.
Maintained by Paul E Bennett <peb@transcontech.co.uk> who will
welcome additions and amendments.
URL: http://world.std.com/~techbook/standard.htm
Note: AMERICAN STANDARDS : EASTERN EUROPEAN STANDARDS
Some US and Eastern European standards are mentioned in this FAQ.
Paul Bennett comments: "The few that appear here may be candidates for
an eventual separate individual FAQ for each of the global areas. It
is desirable that others should take on this task (preferably if they
live in the area of the globe concerned)."
1.7.2 FAQ: Safety and EMC Compliance - North American Standards
Volunteers to generate and maintain this FAQ are required.
1.7.3 FAQ: Safety and EMC Compliance - R-o-W Standards
Volunteers to generate and maintain this FAQ are required.
Note: A partial listing of Australian / New Zealand standards is
given in section 10 below.
1.8 Books and Guides
~~~~~~~~~~~~~~~~
FAQ: Safety and EMC Compliance - Books and Guides
Most recently posted to sci.engr.electrical.compliance on 09 Feb 1997.
Maintained by Paul E Bennett <peb@transcontech.co.uk> who will welcome
additions and amendments.
URL: http://world.std.com/~techbook/cebooks.htm
1.9 The CE Mark
~~~~~~~~~~~
A copy of the CE-MARK in PCX format is available by an email request
to Jeremy Turner <Jeremy@srscomp.demon.co.uk>.
The CE Mark logo is also available from BABT at
http://www.babt.co.uk
in their "Logos and Approval Marks" page
http://www.babt.co.uk/graphics.htm
(The logo shows the CE mark complete with Notified Body number and
"crossed hockey sticks", but you can easily edit it to suit, as the
file expands into 17 or 18 different file formats, which should suit
everybody's software!)
1.10 Australia and New Zealand
~~~~~~~~~~~~~~~~~~~~~~~~~
NOTE: Much thanks to Chris Healy <chris@jna.com.au> for the following
updated information.
New Zealand has had EMC regulation for some time, and Australia introduced
mandatory requirements for all electrical products first offered for sale
from the first of January 1997. While both countries use the C-tick as a
compliance mark, the regulations for each country are currently
independent. A recently signed MRA between Australia and New Zealand will,
at some time in the future, result in mutual acceptance of technical and
regulatory requirements, thus requiring the establishment of compliance in
one country only.
The regulations in Australia and New Zealand are both based on Declarations
of Conformity, with the party responsible for the declaration being
resident in the applicable country. This requirement is similar to the EU
requirements.
Australia
~~~~~~~~~
The Australian regulations came into force on 1 January 1997, for new
products. The regulations will apply to all products from 1 January 1999.
The Australian requirements are to:
Establish a sound technical grounds for compliance;
Make a Declaration of Conformity;
Prepare a compliance folder of technical construction file; and
Label the product.
Ref. Government Notices:
Radiocommunications Standards (Electromagnetic Compatibility) No.1 of
1996, and
Radiocommunications (Compliance Labelling - Incidental Emissions)
Notice.
Electromagnetic Compatibility Fremework, Information for Suppliers (1996)
All market sectors are covered: commercial, residential and light
industrial, installation/maintenance, automotive, heavy industry (power
transmission and large scale, manufacturing).
Applicable emission standards are:-
AS/NZS 4251 Generic
AS/NZS 1044 Household Electrical Appliances, Portable Tools &
Similar Electrical Equipment
AS/NZS 1053 Sound & Television Receivers & Associated Equipment
AS/NZS 2064.1/2 Industrial, Scientific & Medical Equipment
AS/NZS 2557 Vehicles, Motor Boats and Spark Ignition Engine Driven
Devices
AS/NZS 3548 Information Technology Equipment
AS/NZS 4051 Fluorescent Lamps & Luminaires
AS/NZS 4052 Microwave Ovens
No time frame has been set for the introduction of immunity standards.
Note: Where EMC requirements are a part of other regulators' requirements,
the SMA will accept the specific sector regulators requirements in place of
the SMA requirements. For telecommunications, EMC has been removed from the
new Telecommunications Bill currently before Parliament and due for
enforcement from 1 July 1997. The current AUSTEL requirement (AS3548 class
A) will continue until 1 January 1998, then be replaced with the SMA
requirements.
There are two marks for use on products for denoting compliance under the
EMC Framework. These are:
1) The C-Tick mark:
This mark is intended for general use on products to declare compliance
with EMC regulations. The C-tick mark is also used by AUSTEL in place of
the "AUSTEL PERMITTED" on Telecommunications Products.
2) The Regulatory Compliance Mark (RCM):
The Regulatory Compliance Mark is a general mark indicating compliance with
regulations. The RCM is accepted by the SMA as an alternative to the C-
tick. The rules for use of the mark are specified in joint Australian and
New Zealand Standard:
AS/NZS4417 Marking of Electrical products to indicate compliance with
regulations.
Currently there are three parts to the standard
Part 1 General Rules for use of the mark
Part 2 Specific requirements for electrical safety regulatory
applications
Part 3 Specific requirements for electromagnetic compatibility
applications.
There is also activities to extend the mark to use on plumbing products,
radio transmitters, telecommunications and medical products.
The RCM mark is currently accepted by the Australian electrical safety
regulators as an alternative to their certification marks. The catch is
that compliance with the requirements of the SMA, AND certification by
Electrical Safety regulator are required before the RCM can be used. In
fact, all parts of AS4417 relevant to a product must be complied with
before the RCM can be applied.
Both these marks can only be used in Australia with the permission of the
Spectrum Management Agency. Pro Formas for application to use the marks
are obtained from: Manager, Radio Communications Standards
Spectrum Management Agency,
PO Box 78 , BELCONNEN ACT 2616
Fax: +61 6 253 2424
Or down loaded from the SMA web site, URL: http://www.sma.gov.au
Details on the EMC Framework for Australia may be obtained from the SMA
website listed above, specifically
http://www.sma.gov.au/spectrum/comply/emc/index.htm
or by fax or E-mail (emc@sma.gov.au) to the SMA.
Information on Australian/NZ EMC standards and Framework is also available
at: http://www.aedc.com.au/emc
Questions and Answers #
~~~~~~~~~~~~~~~~~~~~~ #
Following are excerpts from a letter received by Douglas Scott, principal #
compliance engineer at ECRM Inc <sdouglas@ecrm.com> from David Brumfield, #
Assistant Manager of the Radiocommunications Standards section of the #
Australian Spectrum Management Agency. #
#
Question #1 #
Who is considered the Australian Importer or Australian Agent? Our dealer #
who may or may not have an office in Australia? The first customer who #
buys one of our products? Could this be one of our employees in our Hong #
Kong or United Kingdom offices? To my knowledge, we do not delegate #
authority for anyone to act as our representative except in the case of #
selling our products. #
#
Answer #1 #
"In accordance with the EMC requirement any person of company who imports a #
product whether by direct mail, sea container or air cargo and that product #
is intended for sale in Australia, that person or company is the importer #
and the product is subject to the EMC compliance requirements. #
#
On this point do you envisage individuals or companies bringing into #
Australia your product for their own use? If the product is brought into #
Australia by a single customer and is not intended for sale on the open #
market here then the product is exempt from the EMC framework." #
#
Question #2 #
What if we do not have anyone resident in Australia? Who is it that must #
"hold the Declaration"? #
#
Answer #2 #
"The agency does not insist that you have somebody resident in Australia. #
The onus for responsibility for placing a product on the market is on the #
importer. You may assist this importer by providing sufficient information #
to support a declaraion of conformity with the standard by the importer." #
#
Question #3 #
Is our Declaration issued for the CE Mark an acceptable substitute for an #
Australian version? Would it be if we added the reference to AS/NZS #
3548:1995 to our existing declaration? #
#
Answer #3 #
"The declaration of conformity must be in the Australian format and be #
signed by a responsible person resident in Australia." #
#
Question #4 #
Our existing certification label contains our name and address along with #
the CE and CSA marks as well as the appropriate safety information. Is #
that acceptable for the labeling requirements? #
#
Answer #4 #
"The existing labelling would not meet our requirements and would be #
deficient in important information such as the C-Tick mark and the identity #
of the importer. This agency requires that information for the #
traceability of the product and its importer, particulalry at the time of #
audit of an importer's compliance folder. The legal information relating #
to this requirement can be accessed on our web page." #
#
Question #5 #
Is the use of the C-TICK marking mandatory or optional? #
#
Answer #5 #
"The use of the C-Tick is mandatory for products placed on the Australian #
market." #
#
Question #6 #
How do I deal with private label products? We have arrangements with #
several other companies that sell our products under their own labels. #
Sometimes the certification label I apply has our name on it and sometimes #
the label carries the name of the private label company. In both cases we #
may ship direct to the end-user. #
#
Answer #6 #
"If the product is shipped direct to the end user and is not intended for #
sale on the open market then that product is exempt from the EMC framework. #
However, if it is sold at a later stage the product will need to be #
labelled, and the end user becomes the importer and he would be required to #
establish a compliance folder. See point 1." #
#
Question #7 #
If necessary, will you issue a "Supplier Number" to our company in the USA #
and allow the Declaration to be held here at the main office with copies #
held in the UK and/or Hong Kong? #
#
Answer #7 #
"A supplier code can not be issued directly to an overseas company. If the #
overseas company has an Australian office or Australian subsidiary #
domiciled in this country the supplier code would be issued to that company #
or independent importer in Australia. The declaration would need to be #
signed by the Australian connection and be made available when requested #
within 10 days of the request." #
#
Question #8 #
Would you please send me a complete copy of your handbook on the EMC #
Framework for Residential, Commercial and Light Industry? #
#
Answer #8 #
"Full information about the EMC framework can be found on this agency's web #
page http://www.sma.gov.au/. A hard copy of the"Information to Suppliers" #
is enclosed." #
#
#
New Zealand
~~~~~~~~~~~
In New Zealand, the regulations class equipment into levels, 0 being low-
risk products, 1 being most other products except transmitters.
Declarations for level 1 must be lodged including a fee with the Ministry.
Labelling for EMC compliance is voluntary in New Zealand, Declarations are
mandatory. Where labelling is used, the C-tick mark and the RCM mark as
listed for Australia are acceptable, however the requirements for using the
mark are slightly different.
Contact: Senior Technical Officer (Regulatory)
Communications Division, Ministry or Commerce
PO Box 2847, Wellington, NEW ZEALAND
Fax: (64)04-473 2489
Further information may be obtained from the New Zealand Government
website, and specifically from the following documents:
http://www.govt.nz/comms/rsm/pib18.html - For general information.
http://www.govt.nz/comms/rsm/rfs50.html - For Standards.
In the UK, information about Australia and New Zealand can be provided by
Ian Clasper, GAMBICA, Westminster Tower, 3 Albert Embankment London SE1 7SW
Tel: 0171 793 3050 Fax: 0171 793 7635 email: iclasper@gambica.org.uk
URL: http://www.gambica.demon.co.uk
1.11 Official & Quasi-official Advice
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
UK DTI (Department of Trade & Industry):
Business in Europe Hotline 0117 944 4888
(for EMC Information Packs, LVD Booklet etc)
DTI Guidance Notes on the EMC Regulations
http://www.cix.co.uk/~approval/dtiemc1.htm
Electrical Equipment (Implementing the LVD) Guidance Notes on the
UK Regulations July 1995
http://www.cix.co.uk/~approval/lvdgd.htm
CE/EMC CLUBS - UK
Scotland: Paisley 0141 848 3415
N. Ireland: Lisburn 01846 623 102
England/Wales: Sunderland 0191 515 2000
Salford 0161 278 2700 dmd@tscsubsl.demon.co.uk
York 01904 434 440 cpb@yes.york.ac.uk
Pontypridd 01443 482 482 101337.1147@compuserve.com
Birmingham 01527 595 066
Derby 01332 661 461 X3246
Swindon 01793 783 137 100551.2117@compuserve.com
Oxford 01865 784 888
Hemel Hemp'd 01442 230 442
Basingstoke 01256 851 193 jp@rfi.co.uk
Leatherhead 01372 367 029 conferences@era.co.uk
Canterbury 01227 763 414
Liverpool 0151 231 2052 nowrec@Livjm.ac.uk
Helpline for the South East 0990 168 186 fax 01372 374 074
Automotive 01203 348 541 beadman@mira.co.uk
CE MARKING - ADVICE FROM BEAMA
Third Edition, February 1996 L10.00 (non-members), L6.00 (members)
BEAMA, Westminster Tower, 3 Albert Embankment, London SE1 7SL, UK
Telephone: +44 (0) 171 793 3035 Fax: +44 (0) 171 793 3054
CE MARKING ON POWER SUPPLIES - Guidance from the EPSMA
Available free of charge from
Matthew Towers - EPSMA Secretariat
The European Power Supply Manufacturers Association
Belgrade Centre, Denington Road, Wellingborough, Northants NN8 2QH, UK
Telephone: +44 (0) 1933 44 22 02 Fax: +44 (0) 1933 44 22 40
email: 106262.1066@compuserve.com
This document is now also available at
http://www.lyons.demon.co.uk/epsma.html
EUROPEAN LEGISLATIVE REQUIREMENTS FOR THE MARKING OF MEASURING INSTRUMENTS
Free from The National Weights and Measures Laboratory (NWML)
Department of Trade and Industry, Stanton Avenue,
Teddington TW11 0JZ, UK.
Tel: +44 (0) 181 943 7214 Fax: +44 (0) 181 943 7270
email: 100534.2720@compuserve.com
[See also details of NWML Home Page above]
"WORLD ELECTRICITY SUPPLIES"
Available from BSI (+44 (0) 181 996 7000) under reference TH20338, for L21.
It... "Gives supply sources and household, commercial and industrial
voltage, voltage tolerance and frequency for over 200 countries worldwide.
Also available as a wall chart (TH20329).
*** CONTINUED - PART 2 ***
---------------------------------------------------------------------------
E&OE: please post corrections/additions to sci.engr.electrical.compliance
or email to Bill@lyons.demon.co.uk or w.lyons@ieee.org
---------------------------------------------------------------------------
Supersedes: <863709662snz@lyons.demon.co.uk> #
Last Posted: Thu, 15 May 97 15:21:02 GMT #
URL: http://world.std.com/~techbook/compliance_faq.html
textfile: http://www.lyons.demon.co.uk/seecfaq2.txt
FAQ: SOURCES OF EMC AND SAFETY COMPLIANCE INFORMATION - PART 2
First posted: April 17, 1996
Fifteenth issue: June 15, 1997 #
CONTENTS - PART 1
~~~~~~~~~~~~~~~~~
1.1 Introduction
1.2 Journals devoted wholly or mainly to EMC and safety compliance
1.3 Conferences and Exhibitions
1.4 Listservers
1.5 WWW Sites
1.5.1 Non-commercial
1.5.2 Commercial Web sites carrying useful EMC/safety information
1.6 Standards Organizations
1.7 Specifications for Safety and EMC Compliance
1.8 Books and Guides
1.9 CE Mark
1.10 Australia and New Zealand
1.11 Official & Quasi-official Advice
CONTENTS - PART 2 (THIS PART)
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
2.1 The sci.engr.electrical.compliance newsgroup
2.1.1 Background and History
2.1.2 Charter and Rationale
2.1.3 Guidelines
2.2 European Voltage Harmonisation
2.3 Commonly-asked Questions and Answers about the EMC Directive
2.4 The Low Voltage Directive (LVD)
Acknowledgments
2.1 The sci.engr.electrical.compliance newsgroup
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
2.1.1 Background and History
~~~~~~~~~~~~~~~~~~~~~~
The desire for a Usenet newsgroup devoted to "compliance" matters such as
EMC and safety relative to electrical and electronic equipment had been
expressed by a number of posters to various newsgroups. As part of the
reorganization of the sci.electronics.* heirarchy carried out by Mark
Zenier <mzenier@netcom.com>, he had prepared a draft Request for Discussion
(RFD), and this became the basis for the establishment of s.e.e.c
This is the FAQ for the sci.engr.electrical.compliance newsgroup. It
supersedes the "Pre-FAQ: Sources of EMC & Safety Compliance Information"
which was posted to sci.physics.electromag monthly from January 15, 1996
until April 4, 1996 pending the establishment of the s.e.e.c newsgroup.
Since some newsreaders have difficulty with articles approaching or
exceeding approx 64k in length, this FAQ has now been divided into two
parts. This is Part 2.
This FAQ was created by, and is currently maintained by, Bill Lyons
<Bill@lyons.demon.co uk> or <w.lyons@ieee.org>, who welcomes suggestions
for additions or amendments.
It will be posted to s.e.e.c approximately monthly, with pointers in the
following related newsgroups:
sci.electronics.misc sci.electronics.design
sci.engr.electrical.sys-protection sci.physics.electromag
alt.engineering.electrical
and the following mailing lists:
emc-pstc@ieee.org treg@world.std.com
The latest issue of this FAQ is archived at:
http://world.std.com/~techbook/compliance_faq.html
PLEASE ADVISE CORRECTIONS OF ANY ERRORS YOU MAY DETECT, OR SUGGESTIONS OF
ADDITIONAL USEFUL INFORMATION, AS INDICATED AT THE END OF THIS FAQ.
N.B. A hash mark (#) in the right-hand margin indicates new or modified
information since the previous issue.
2.1.2 Charter and Rationale
~~~~~~~~~~~~~~~~~~~~~
The following is extracted from the RFD (Request for Discussion) and the
successful CFV (Call for Votes) which resulted in the official creation of
s.e.e.c on 17th April 1996:-
Newsgroups line:
sci.engr.electrical.compliance -
Laws, regulations and design for EMC, safety.
CHARTER: sci.engr.electrical.compliance
Discussions on the laws, regulations, and safety approval procedures
governing the production, design and marketing of electronic and electrical
equipment, and the engineering techniques used to comply with them.
RATIONALE: sci.engr.electrical.compliance
Discussions on how to manufacture electronic equipment that has to meet the
various government regulations are occuring in several different newsgroups
(sci.electronics.misc, sci.physics.electromag, alt.engineering.electrical)
and various persons have expressed the desire to have a common location.
(There is large interest in Europe and with companies who export to there
due to recent European Union regulations.)
The name is derived from the common name of this subfield of electrical
engineering, compliance engineering.
2.1.3 Guidelines
~~~~~~~~~~
This is an unmoderated newsgroup and in the interests of participants it is
hoped that the following guidelines will be agreed by users:
1. This is a technical discussion newsgroup with subscribers using many
heterogeneous operating systems and platforms. All postings should be
in plain ASCII text, and on-topic relative to the charter and
rationale of the newsgroup. (It is helpful if you wrap text at about
70 characters/line, so that it may be moderately quoted without
exceeding 80 characters.)
2. Exceptionally, if you feel you must post short binaries, such as small
schematics, diagrams, etc, they should be in compressed format (e.g.
TIFF, JPEG or postscript) not exceeding 10k.
Long binaries/graphics and long program files must NOT be posted.
Please arrange for them to be available at an ftp or Web site. A
short announcement describing the nature of the material and giving
the URL where it may be accessed is welcome.
3. Announcements of conferences, seminars, courses, exhibitions and
meetings devoted wholly or mainly to compliance matters and related
products are welcomed and encouraged, as are short announcements of
new books and guides.
4. Commercial announcements or "plugs" for products are not appropriate,
but short announcement of the URLs of commercial Web sites carrying
details of products related to the purposes of the newsgroup are
acceptable. A specific recommendation of a particular product as a
solution to a problem is acceptable.
5. Short announcements of job vacancies in the compliance/EMC/safety area
are acceptable. Postings of CVs are NOT acceptable.
6. Normally, postings should be signed. However, it is recognised that
there may be legitimate reasons for on-topic postings via anonymous
remailers, e.g. if a matter is commercially sensitive.
2.2 European Voltage Harmonisation
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
The nominal European voltage is now 230V 50 Hz (formerly 240V in UK, 220V
in the rest of Europe) but this does not mean there has been a real change
in the supply.
Instead, the new "harmonised voltage limits" in Europe are now:
230V -10% +6% (i.e. 207.0 - 243.8V)
in most of Europe (the former 220V nominal countries), and
230V -6% +10% (i.e. 216.2 - 253.0V)
in UK (former 240V nominal).
This is really a fudge and means there is no real change of supply voltage,
only a change in the "label", with no incentive for electricity supply
companies to actually change the supply voltage.
To cope with both sets of limits an equipment will therefore need to cover
230V +/-10% i.e. 207-253V. This will actually become the official limit
for the whole of the EU in 2003.
2.3 Commonly-asked Questions and Answers about the EMC Directive
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Frequently-asked questions and answers by Brian Jones, EMC Consultant to
Nutwood UK Limited, publishers of the EMC '97 Reference Handbook &
Directory, Edition 2. http://www.emc-journal.co.uk.
The following information is believed to be correct at the time of going to
press (April 1997). It is not possible to cover individual circumstances
in general answers such as these, and caution should therefore be exercised
in the use of this information. Any changes to these answers due to
changed circumstances, legal precedents or changes to Commission or
national guidelines will appear in the updates.
Q1. Is Due Diligence tempered by cost?
A1. The DTI has published a document entitled "Minimising the cost of
meeting the EC Directive on Electromagnetic Compatibility (EMC) 89/336/EEC
as amended by EC Directive 92/31/EEC." The second edition was published
towards the end of 1995, and is available from the DTI. It is also
reproduced in the EMC Handbook. This document sets out the minimum actions
required to meet the legislation. It has also been suggested that courts
may take account of the value of the product, or size of the company, in
judging a case.
The manufacturer should satisfy himself that he has taken all reasonable
steps. It would be sensible to carry out periodic emission testing if only
one sample was tested initially.
The manufacturer takes sole responsibility for his products' performance,
and must be prepared to justify the actions he has taken (or not) to the
enforcement authorities.
Q2. How long can non-compliant goods in stock at the end of 1995 be offered
for sale? Can such goods cross borders between Member States?
A2. There is no time limit in the UK, but the majority of other Member
States will not allow non-compliant stock to be sold after the end of 1996.
The situation in other Member States is described in the section on
legislation across Europe. Whatever the stated position of the
enforcement bodies in different Member States, it will become
increasingly difficult to move non-compliant goods, and it is likely that
proof of date of manufacture will be required.
Q3. Is military equipment excluded in all Member States?
A3. Military equipment (apparatus designed for use as arms, munitions and
war material within the meaning of Article 223.1(b) of the Treaty of Rome)
is excluded from the UK Regulations provided it does not have an
alternative non-military use. The laws are not identical in all Member
States of the EEA. The EMC Handbook will identify those where compliance
with the EMC Directive is not excluded.
Military equipment which finds its way onto the open market (as surplus
goods, for example) may be caught by the UK Regulations since it would no
longer have a purely military use.
Q4. Who signs the Declaration of Conformity when the manufacturer is
outside the EEA?
A4. The manufacturer may sign the Declaration of Conformity whether he is
located inside or outside the EEA. If outside the EEA, then the
certificate must identify the person within the EEA who is responsible for
placing the apparatus on the EEA market. It is this person who must hold
the Declaration of Conformity at the disposal of the Competent Authorities.
A manufacturer outside the EEA may delegate his authorised representative
within the EEA to issue the Declaration of Conformity and affix the CE
Mark. Supply to an authorised representative does not come within the
scope of the Regulations.
Q5. Who is an authorised representative?
A5. Someone, or a company, empowered by the manufacturer to act on his
behalf. For his own due diligence, he should be satisfied that the
information provided is sufficient to enable him to issue the Declaration
of Conformity, and that he is able to bind the manufacturer to commitments.
It is unlikely that an organisation that simply imports goods would have
the contractual position to act as an authorised representative.
Q6. What constitutes an excluded installation?
A6. In the UK, excluded installation means two or more combined items of
relevant apparatus or systems put together at a given place (whether or not
in combination with any other item) to fulfil a specific objective, but not
designed by the manufacturer(s) for supply as a single functional unit. In
effect, an excluded installation is a collection of compliant apparatus.
Thus a large installation supplied as a single unit is not excluded,
whereas one supplied by a number of manufacturers is outside the scope of
the UK Regulations. An example would be a production area in a factory
comprising a number of stand-alone process stations each supplied by a
different manufacturer, for printed board populating, flow soldering,
ultrasonic welding, etc. Each process station would need a Declaration of
Conformity in its own right, but the production area as a whole would not.
Interpretations may differ in other Member States.
Q7. How can large systems be declared compliant?
A7. A large installation supplied by a single manufacturer may be
considered a system and comes within the scope of the Directive. Only one
published European standard has so far addressed this issue (ETS 300 127
for large telecommunications equipment) and this is not harmonised. Such
systems could be declared compliant via the Technical Construction File
Route. Recent draft guidance from the Commission suggests that if the
individual parts of the system are themselves compliant relevant apparatus,
and if the system is installed in accordance with the manufacturer's
instructions, this could be considered sufficient for the standards route.
It is for the manufacturer to assess the risks in deciding the most
appropriate course of action.
Q8. What constitutes a sub-assembly?
A8. Recent draft guidance from the Commission has clarified the definition,
and items which are designed, manufactured and intended to form part of an
item of apparatus do not have to comply with the Directive (only the
finished product must so do). If, however, the item would perform a direct
function for an end user, and is placed on the market, then it is covered
by the requirements of the Directive. A direct function is defined by the
Commission as any function of the component itself which fulfils the
intended use and which is available without further adjustment or
connections other than simple ones which can be performed by any person not
fully aware of the EMC implications.
Q9. With contract manufacturing, who is responsible for the Declaration of
Conformity?
A9. This should be a contractual matter to be agreed between customer and
supplier. The authorities seem to have a relaxed attitude about who issues
the Declaration of Conformity providing the declaration is produced.
Recent draft guidance from the Commission suggests that a manufacturer may
subcontract design if he produces the product, or subcontract production if
he is responsible for the design and EMC performance, without compromising
his manufacturing status.
Logically, the organisation taking responsibility for the design and
performance of the product should be responsible, but they will need to
demonstrate (via Quality Management Systems or otherwise) that they have
control over the manufacturing process as if the they were manufacturing
the product themselves.
Q10. Is a custom-made one-off item "placed on the market"?
A10. The UK Regulations make use of the concept of supply rather than
placing on the market, which makes the position clearer. Even one-off
items are covered by the Directive, when they are supplied for an end user.
Q11. Is reconditioned second-hand equipment covered?
A11. If the EMC performance of the product is unaffected, it may be
considered second-hand, and the EMC Directive does not apply. If in the
process of reconditioning, the EMC characteristics are changed to a
material degree then the reconditioner becomes a manufacturer and therefore
responsible for compliance with the Directive. If the EMC performance is
improved from the original, then no further action is necessary.
Q12. Can compliance with more than one Directive be stated on one
Declaration of Conformity?
A12. Yes, providing all the relevant information is given for each
Directive, including the year of manufacture for certificates declaring
conformity to the Low Voltage Directive.
Q13. Do software upgrades affect the validity of the CE Mark?
A13. There has been much debate on this subject, and the consensus to date
suggests that software changes should be considered in assessing whether a
re-evaluation for EMC is necessary. From an emissions perspective, the
equipment should have been exercised to a maximum extent, possibly by the
use of a special program. Analysis may show that the new software does not
exercise the equipment to a greater extent than that tested originally.
However, changes in software can affect susceptibility, particularly to
transients.
Q14. What degradation of performance is acceptable for immunity testing?
A14. The manufacturer may state this in the user documentation, providing
the degradation is acceptable and would not compromise safety. If no
statement is made, then in cases of dispute, the performance that a user
would reasonably expect will be used.
Q15. Does an assembly of CE Marked sub-assemblies make for a compliant
product?
A15. Not necessarily. There are sound technical reasons why this should be
so. The final manufacturer takes responsibility for the EMC performance of
the completed product.
Q16. What is the responsibility of an installer?
A16. If the installer is not the supplier, he should carry out the
installation in accordance with the manufacturer's instructions.
Q17. How do I decide if a printed wiring assembly should be CE Marked or
not?
A17. Boards intended for an end user should carry the CE Mark, backed by a
Declaration of Conformity. Boards which are intended only to form part of
another system, and intended to be incorporated into a finished product
need not be marked, as they are components, and outside the scope of the
Directive.
Q18. What do I have to do if I sell personal computers after fitting an
extra card to them?
A18. When this is done, the person carrying out the act performs the final
stage of manufacture of the product as supplied to the end user, and
therefore takes responsibility for the EMC performance of the whole. The
assembler should request details of the assessment carried out on the
plug-in card from the manufacturer of that product. The Directive does not
require testing to be performed, and assuming the basic computer and the
cards are CE Marked, the assembler may be satisfied with some simple
derived tests to satisfy himself that the final product remains compliant.
This may not sufficient if the assembly consists of a larger number of
modules fitted to a box containing only a power supply or power supply and
mother board.
Q19. Can a user upgrade a non-compliant product which was taken into
service before 1996?
A19. The modified product will be taken into service by the user. If the
EMC performance has been altered by the upgrade, the user will be
responsible for the product meeting the protection requirements of the
Directive (but does not need to meet the requirements for supply).
Q20. Do control panels need a CE mark?
A20. If they are sold to an end user for him to integrate into a system,
yes. If they are sold only to a machine builder who assembles the final
product, no.
Q21. How can I show due diligence when assembling products and systems from
CE marked sub-assemblies or apparatus?
A21. It is difficult to offer general guidance here as different measures
will be needed for the wide variety of possible situations. A computer
system assembled from finished products (i.e. keyboard, mouse, monitor and
completed box containing boards, disc drives and power supply) may need no
further assessment; there is only one way these can be interconnected and
they will have been assessed as completed products by their manufacturers.
A machine consisting of PLCs, motor drives, encoders, sensors, etc. may
require a full assessment.
Q22. Is all laboratory equipment covered by the educational relaxation?
A22. No. In the UK, only equipment which would not, except for the
provisions of Regulation 8, comply with the protection requirements under
normal conditions of use, and which is used in education and training
establishments for the purposes of experimentation, learning or practical
training, is covered by the modified application of that Regulation.
Test apparatus, designed or adapted to generate or be susceptible to
electromagnetic disturbance is covered by the modified application of
Regulation 9, and must not create disturbances outside the immediate
electromagnetic environment of the apparatus.
Q23. Does the signatory of the Declaration of Conformity go to jail if the
product is shown to be non-compliant?
A23. Not all offences under the UK Regulations could result in custodial
penalties. Only Regulations 83 (contravention of a prohibition or
suspension notice), 84 (giving false or misleading information) and 86(2)
(impersonating an officer of an enforcement authority, have this penalty.
To date, no-one has been sent to jail in the UK for infringement of a New
Approach Directive. It is possible that this could happen at some time in
the future for a very serious breach of regulations, but this is complex
issue of employment law, and is beyond the scope of these answers.
Regulation 89 provides further information.
Q24. What happens when the signatory leaves the company?
A24. The certificate is still valid, but signatory can no longer be held
responsible for the actions of the company he has left.
Q25. Are products which have previously been used by an end user outside
the EEA, or by the manufacturer or wholesaler, considered second-hand?
A25. No. To be considered second-hand under the EMC Directive, products
must have been previously used by an end user within the EEA.
Q26. If an end user imports a product directly from a country outside the
EEA for his own use only, does the product require a CE Mark?
A26. Latest thinking from the enforcement authorities is that the end user
takes the product into service, and is therefore ensuring that the product
complies with the protection objectives of the directive, but no
assessment, Declaration of Conformity, or CE Mark is required. The product
has not been supplied within the EEA.
Q27. Which directive applies to products intended for use on forklift
trucks?
A27. These do not come under the automotive or agricultural directives, and
the EMC Directive applies.
Q28. What is the position with loudspeakers?
A28. Passive loudspeakers consisting of moving coil units and passive
crossovers inside a cabinet are benign electromagnetically, although it is
understood that in Germany the CE Mark is required, and there may be other
countries where the products cannot be sold without the mark. The large
permanent magnet of loudspeaker units can affect TVs and monitors when in
close proximity (unless magnetically-shielded) and this should be covered
in the instructions for use.
Q29. Are quartz wristwatches covered by the regulations?
A29. No, they have been exempted by common agreement of Member State
Competent Authorities.
Q30. Are there any requirements for instructions for use to be in the
language of a Member State?
A30. The requirement for products to be supplied with instructions for use
is contained within the Directive in Annex III, but recent guidance from
the Commission has placed greater stress on the need for such instructions.
Regulation 5(6) applies in the UK. It would seem logical that if there
must be instructions for use, the user must be able to understand them.
The DTI has indicated that products supplied in the UK must have
instructions in English; it would be expected that of Member States would
insist on similar provisions.
Q31. When can a standard be used for self-certification under the standards
route?
A31. When it has been harmonised, i.e. it has been published by CENELEC or
ETSI and transposed into a national standard in at least one Member State
and it had been listed in the Official Journal of the European Communities.
Note that to use this route, the harmonised standard(s) applied must make a
complete provision, i.e. they must cover all aspects of emission and
immunity.
Q32. Where can I examine the standards?
A32. Most central reference libraries hold copies of British Standards,
which includes BS implementation of European Norms. Those with access to
university or other academic institution libraries may also find copies
there. Some libraries hold copies as microfiche which is not so easy to
read.
Members of the British Standards Institution and BSI committee members may
use the BSI library in Chiswick free of charge (prior booking necessary)
but a charge is made for non-members.
BENIGN APPARATUS
This is "apparatus" as described in Regulation 7(2), but is excepted from
the requirements by Regulation 17. Benign apparatus is therefore not
"relevant apparatus".
Regulation 36(6) prohibits the affixing of the CE Mark for EMC to any
apparatus which is not relevant apparatus. A CE Mark applied to such
apparatus would therefore be technically in breach of Regulation 85(1)(b).
It is understood that the DTI has a relaxed view of this, providing the
marking is not materially wrong.
There are, however, possible other problems with the affixing of the mark
to such apparatus, under the Trade Descriptions Act (see below).
COMPONENTS AND SUB-ASSEMBLIES INTENDED FOR FURTHER MANUFACTURING
Although many words have been written on this subject (including articles
in the EMC Journal) a closer examination of the wording of the Directive
and the UK EMC Regulations has resulted in an amendment to the advice.
Components and sub-assemblies are not "apparatus" and are not covered in
the Directive or the UK Regulations. It follows therefore, that there is
no offence in the EMC Regulations for affixing the CE Mark to these items.
However, by adding a CE Mark, a manufacturer is adding a trade description.
If the item were shown in some way to be not in conformity with the
protection requirements of the Directive, then the CE Mark could constitute
a "false and misleading statement" and therefore constitute an offence
under Section 1 of the Trade Descriptions Act 1968.
Although there would be a technical breach, it is possible that no action
would be taken unless the description was false to a material degree. If
the item was shown to be the cause of relevant apparatus causing
interference or suffering a suscepibility problem, or indeed failing an EMC
test, then a complaint could lead to a prosecution under the Trade
Descriptions Act.
By affixing the mark, therefore, the component or sub-assembly manufacturer
has possibly taken on liability for the EMC performance of his product.
As components and sub-assemblies are not required to meet the EMC
Regulations, if they were not marked, there would be no offence, even if
they were shown to be the cause of an EMC problem as described above.
The advice from the DTI and the TSOs continues to be that components and
sub-assemblies should not be CE Marked for EMC.
2.4 The Low Voltage Directive (LVD)
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
(a) A note from Alan M Hudson <hudson@msim.co.uk>
I'm not an expert on the LVD, but for what it's worth, I'll put down what I
believe to be correct (but may not be !!):
Yes - the LVD has been around since 1973, and is therefore in force now (so
you probably meet it now), but the CE marking requirement only came into
play on 1 Jan 1997.
It applies to equipment operating in the 50 - 1000 Vac or 75 - 1500Vdc.
The only route to conformity is "Self Declaration" to either Harmonised
standards (in the OJ), or if not relevant/available, then to International
standards, or if also not relevant/available, then to National standards.
There are some product-specific Harmonised standards around - EN60950 for
ITE, and EN60065 for domestic equipment.
The compilation of a "Technical File" is mandatory, I believe (as opposed
to the EMC "Technical Construction File" which is only needed for the TCF
route to compliance).
You may want to check out http://www.ktl.co.uk/ktl/cemark.htm and
http://www.safetylink.com especially http://www.safetylink.com/lvd.asc
(The last contains the full text of the Low Voltage Directive - Council
Directive 72/23/EEC of 19 February 1973).
(b) From Gerry McMahon, National Electronics Test Centre, Dublin,
Ireland <mcmahong@iol.ie>:
Subject: Are you ready for the EU Low Voltage Directive ?
The EU Low Voltage Directive (LVD) will be mandatory from 1st January 1997.
In an effort to inform manufacturers of electrical and electronic equipment
on the scope of the LVD, the National Electronics Technology Centre (NETC),
Forbairt [http://www.netc.ie/] maintains a Frequently Asked Questions (FAQ)
page on the LVD at:
http://www.netc.ie/lvdfaq.htm
Contact Person : Jackie Fitzgerald at NETC [fitzgeraldj@netc.ie]
ACKNOWLEDGMENTS
~~~~~~~~~~~~~~~
The s.e.e.c FAQs could not have been prepared without the much appreciated
help and advice of many people. If I have omitted anyone from the following
list, please accept my apologies.
Paul E Bennett peb@transcontech.co.uk
Eckard Blumschein eckard.blumschein@e-technik.uni-magdeburg.de
Ian Clasper iclasper@gambica.org.uk
Kristin Eckhardt eckhardt@techintl.com
Andy Gulliver andy.gulliver@crossprod.co.uk
Chris Healy chris@jna.com.au
Dr. Todd Hubing thubing@ee.umr.edu
Alan Hudson hudson@msim.co.uk
Alan E Hutley nutwooduk@msn.com
Mark Jurgen mjurgen@ultranet.com
Eric Lifsey Eric.Lifsey@natinst.com
Mirko Matejic mmatejic@foxboro.com
Ross McKay inspect@asiaonline.net
Adrian McLeod approval@cix.compulink.co.uk
Gerry McMahon mcmahong@iol.ie
Art Michael amichael@connix.com
David Patton patton@primenet.com
David Perlmutter Dave_Perlmutter@3mail.3Com.COM
Roger Prenger prenger@phx.sectel.mot.com
John Quinlan quinlanj@voicenet.com
Martin Rowe techbook@world.std.com
Rene Schmit rene.schmit@crpht.lu
Douglas Scott sdouglas@ecrm.com
Dr John Stockton jrs@merlyn.demon.co.uk
Jeremy Turner Jeremy@srscomp.demon.co.uk
Frank Warner fwarner@dap.csiro.au
Tim Williams elmactimw@cix.compulink.co.uk
John Woodgate jmw@jmwa.demon.co.uk
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