NMMA Tech Services Bulletin Board
The information below comes from the NMMA Tech Services Bulletin Board web site. we encourage you to read it and its updates from their site. A text only version of portions of their site is archived below.
25 April 1997 To: NMMA Members Interested in European Electromagnetic Compatibility From: Jay McBride, NMMA Director of Technical ServicesSubj: European Directive for Electromagnetic Compatibility (EMC)
The European EMC Directive requirements for electrical/electronic components, and systems comprised of these components, that would be marketed in Europe became effective 1 January 1996. That means, all electrical and electronic components falling under the guise of the EMC directive must be certified and carrying the "CE" mark if they are to be marketed in Europe. International manufacturers and a few U.S. manufacturers were aware of these requirements and had already taken actions to obtain the "CE" mark of conformance. For those remaining NMMA member manufacturers, we have researched this matter and provide the following information.
From the many inquiries we have received, your primary concerns are: how do I obtain/achieve certification to the EMC Directive; who does the certification; and where can component testing be performed? I will try to answer these and other anticipated concerns. Many of you have discussed this with Lars Granholm or me and we have been able to provide most of the verbal guidance you are seeking. Meanwhile, we have collected documents to assist you and are enclosing them with other helpful information.
Your understanding of the EMC Directive is critical to your making a choice on how to proceed to declare EMC conformance. Except for telecommunications equipment, the Directive allows for manufacturer Self-Declaration of Conformance (SDOC). However, CE conformance for telecommunications equipment requires inspection and testing by a Competent Body which exist only in Europe.
The SDOC route requires you to pursue component EMC testing, if you find it necessary, and maintain the Technical Documentation File to support your SDOC. You then issue a copy of your SDOC certificate/document with the component/component family to your customer. You also apply the CE mark to the component, packaging, instruction manual, or whatever is appropriate, and this is typically determined by the size of the component (The CE mark is described in the Directive). On that SDOC you specify the applicable elements of the Directive, if not the entire Directive, and the reference standards/specifications that the component meets for compliance. Also declare limitations of the component for installation, etc., to ensure the integrity and truth in marketing of your declaration. The Directive only describes the type of information to be on the SDOC, and not the format. Samples of SDOC's for two electrical devices are available.
With the above information, I will now try to answer other typical questions regarding this program.
- What is the SDOC procedure? You know your product best. If the Directive applies, meaning when your electrical/electronic component is energized and used as intended, and it will interfere with transmitting and receiving radio equipment, transponders, transducers, radars, G.P.S., etc., then you should have it tested for emissions, or immunity if itís operation will be affected by emissions. The Directive explains the difference. When you have received test results that say you meet the Directive requirements which are qualified by your intended product use, you prepare the SDOC with the proper conformance limits, etc. If from your manufacturing experience with similar products that were tested elsewhere to meet other EMC requirements, such as, you sold the product to the U.S. Navy for their aircraft, you can elect to not repeat tests and make your SDOC. It's your decision, remembering it is self-declaration as long as you have the technical file to support your declaration.
- Where can I go to test my products? We have located testing labs who have the necessary qualifications to perform EMC testing for electrical/electronic components and system installations such as engines with their components. They have agreed to testing costs as low as $2500 and no waiting. They will do generic testing and provide you with a report on the qualifications of your component(s) and what you need to do to correct deficiencies if the component does not pass. You can decide to make those corrections and issue your SDOC or return the component for more testing after you correct the deficiencies. Your discussions with the test lab will help you make that decision.
- What about products already in the pipeline to Europe? The product must be declared in conformance with the EMC Directive when it is presented to the European market for sale. For products already on the way to Europe, establish your SDOC and provide the documentation and CE mark labels to your distributors so they can be prepared for customs, or find a means for putting the product in a holding pattern until the SDOC is prepared.
- My product complies with the Directive, now how do I get the CE mark? The Directive describes the design of the CE mark, and it has to 5 mm in height or larger. So, any size above that can be applied to the component, packaging, etc. At this point, you may go to a local designer/printer and have them made. Just make sure the packaging, instructions, manuals describe the applicable Directives represented by the mark. Application can be by similar methods for other labels. It's your choice, just as long as it makes it through the European border and to the consumer.
- What do I do when other Directives apply to my product such as the ignition protection requirements under the Recreational Craft Directive? Depending on your market customer, you can use the same SDOC to address both or more Directives, or use separate documents, just as long as your technical files support your declarations. However, you need only apply one CE mark.
- If I need a Competent Body for the EMC Directive, where do I go? You have to go to Europe. Some of you may already know some of the Body's . We are working on putting together a list. We will get this to you as soon as practicable. Meanwhile, you should know that IMCI and NMMA do not have that authority.
IMCI provides a listing of components certified to the Recreational Craft Directive for its IMCI certified members. This list will be expanded to include components declared in conformance to the EMC Directive. Send a copy of your SDOC to IMCI for consideration. A nominal fee will be required.
I have also listed three other documents which will give a further explanation of what the EMC Directive requires, subject to the interpretation of the drafters of these documents. These are not the letter of the law, but very helpful guidelines and hints to steer you through this process that is not very complicated. Once you get use to it, it's pretty simple. We do not have all the answers yet. And I'm sure some of you have superior knowledge and experience on related matters to EMC conformance. Share that information with your fellow NMMA members and make it available to me so I can distribute it.
Thank you. Happy CE marking.
(1) EMC Directive
(2) Sample SDOC's
(3) List of EMC Testing Laboratories
(4) Related EMC documents (BMIF Guidelines, dti EMC law brief, EC Tech File Guide)
8 March 1997
Please pass to all engineers, designers, and purchasing agents.
The Electromagnetic Compatibility (EMC) Directive for the European Community, which has been effective since 1 January 1996, applies to all electrical/electronic equipment that either emits electrical interference, or is susceptible to electrical emissions.
The purpose of the EMC Directive is to ensure that the safety of life and property are in no way jeopardized due to electrical or electronic interference by equipment that either emits stray electrical signals, or is affected by stray electrical signals (not immune). Basically, the Directive is protecting telecommunications equipment, one and two way radios, radar, sonar, GPS, and other systems that are critical to ensuring safe navigation, propulsion and generator systems, and the integrity of emergency notification systems.
Electrical/electronic equipment that will cause interference (emitters) with other equipment must be tested for conformance with the EMC Directive. Equipments that typically fill this description are motors, chattering switches, florescent lighting, and engine ignition systems. Let your imagine run and you will be able to identify many other electrical/electronic devices that fit this brief description. When youíre at a stop light and a diesel truck pulls up next to you and your favorite radio AM station gets static, thatís emission interference. But, itís two issues, the diesel engine has not been designed to limit emissions (or its emissions shields have broken down; also applies to gasoline engines), and/or your radio is not properly shielded/immunized to protect it from these stray emissions.
Boat manufacturers should keep this in mind when designing a particular boat equipment portfolio. Also, ask your equipment suppliers if their equipment has been designed for conformance with the EMC Directive.
Boat manufacturers should consider the following factors in deciding if the supplied equipment needs to be EMC tested and/or otherwise declared immune from the scope of the EMC Directive:
- Does the boat where the equipment is to be installed have any electronic navigation or other systems that may be affected by outside emissions that would threaten life or the safety of the boat?
- Has the boat manufacturer checked with the supplier of the potentially affected equipment to make sure the equipment is immunity protected as per the EMC Directive (you should not take the full responsibility)?
- Where is the equipment to be installed, that is, its proximity to emitter and those equipments needing protection? You are allowed to specify installation constraints to ensure your non EMC compliant equipment does not affect other potentially sensitive equipments. This goes hand in hand with the above consideration.
- Is the electrical/electronic equipment passive or otherwise manually controlled by the boat user? This means that a simple device like an AM/FM/tape/disc receiver/radio/player which is a one way or local entertainment system on the boat is most likely not a candidate for conformance with the EMC Directive. An on board entertainment system, and itís malfunction, is not considered a threat to lives or boats (unless its operation would prevent identification of an incoming distress signal on the tele-communication equipment). A special consideration is that the boat user can turn off the equipment when it is found to be interfering with critical operations. Another example, which further explains the simplicity and common sense in consideration of the EMC Directive, is the typical boat horn. The activating button, controlled by the user, causes the typical horn to be a noisy emitter. If the boat user finds that a critical emergency message needs to be tele-communicated (if they have that equipment), stop pushing the horn button will allow a noise free communication.
There really isnít any magic to understanding the EMC Directive, or the ways of taking advantage of its provisions for self declaration, or making the determination as to whether the EMC Directive applies to your product. Itís a common sense approach to analyzing the circumstances of use and installation of the equipment.
Jay McBride Director, Technical Services
The Union allowed a two year transition period for the member States, terminating 16 June 1998, to effect national legislation for enforcement of the boat Directive in their respective States. During this period a State may continue, as well as a manufacturer, to use its national rules for boat construction in their State. This is basically the same as done now with the homologation process. However, if a boat has the CE mark, the national regulations cannot be applied and the State must honor the CE mark, whether the boat is manufactured within or without the State. After 16 June 1998, States will no longer be able to implement their national regulations and they must follow the Directive in its entirety.
It's apparent that the simplest route for a U.S. manufacturer is to obtain the CE mark so the boats can be marketed freely throughout the Union. If a manufacturer markets only in one or several States, then the option of compliance with just those States' regulations and paying the fees is still available, but only until 16 June 1998. Why go through the hassle and costs when the CE mark opens the whole market, at much less cost?
The US boating industry is now preparing for the 1998 model year!
Suddenly, 16 June 1998, is staring you in the face. If you want to take advantage of the European market, and perhaps other international markets who are considering acceptance of the "CE" mark, it's show time! You will no longer be able to market your craft without the CE mark after June 1998. Homologation is out the window. What does this mean to you in February 1997?
In first upfront simple context, if the boat does not have a CE mark on it at the 1977 Shows, the dealers are not going to buy. If a boat does not have a CE, mark on it on 16 June 1998, no matter date of construction, the dealer will not be allowed to sell. Dealer sucks up the inventory,
You are designing your '98 models. You are planning your component and assembly purchases so they'll be ready to assemble this summer, You are preparing for the fall '97 European boat shows and IMTEC. If those components and systems are not CE certified in the next few months, before you even build the boats, you will be hard pressed to get the boats certified in time for the BIG SHOW,
Many of you have been through the CE process, but if you are changing components, models, etc., you have to rethink this process. For manufacturers taking the first plunge, you better get to your suppliers now.
For more information, contact Jay McBride at 312-946-6200, FAX 312-946-0388, or Lars Granholm at IMCI, 011,32-2238-7892, Fax 011,32-2238-7700
Copyright ©1997 by Westlawn Institute Of Marine Technology, Inc. - ALL RIGHTS RESERVED
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