| The EMC Directive Frequently Asked Questions |
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| The EMC Directive Frequently Asked Questions |
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| Please note that the following give only brief answers to what can be complex issues.
It is essential to consult the latest Commission guidelines on the EMC Directive for more
definitive answers and also the Directive itself. Note that the Directive itself takes
legal precedence over the guidelines. |
| Can I make an agreement with a manufacturer/supplier to purchase non-compliant equipment if I am prepared to accept its shortcomings? |
| No; this would constitute an offence.
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| If I build out of CE Marked constituent parts, can I be sure that the finished product can comply with the Directive? |
| No; for various technical reasons this may not be the case. For example, the emissions
of the various parts may add together and exceed the allowable limit.
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| Is it necessary to use the Technical Construction File (TCF) route for certifying product variants? |
| Not necessarily; if the manufacturer is confident that he can make a judgement as to
which variants are the worst case then he can use the Standards Route and test only a
limited number of variants.
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| Can one Declaration of Conformity be used to certify compliance with more than one Directive? |
| Yes.
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| How are installations covered by the Directive? |
| Provided it is an excluded installation not designed by the manufacturer for supply as a single functional unit then no conformity assessment or CE Marking is required for the installation as a whole. However, each of the individual elements must comply with the Directive and be CE Marked and they must be installed to the manufacturers specifications. |
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| How are components and sub-assemblies covered by the Directive? |
| If they do not have an intrinsic function to the end user, then they are outside the
scope. It is the finished apparatus which must comply. However, see latest European
Commission guidelines since it is not always clear what is a Component and what is Apparatus. Plug-in PC cards are normally
considered to be apparatus and have to comply.
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| Is re-conditioned equipment covered by the Directive even if the apparatus was originally built before the Directive was enforced? |
| If the re-conditioning changes significantly the EMC performance, then this is
regarded as manufacture and certification and CE Marking are required.
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| Can apparatus still be certified if minor loss of performance occurs during immunity testing? |
| This is allowed providing that no safety related problems can occur, that the loss of
performance is reasonable considering the function of the product and the manufacturer
makes the loss of performance clear in the instructions to the customer.
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| What are the key changes to the latest EMC guidelines from Brussels? |
| The latest guidelines are more detailed and give more specific examples particularly
with regard to the definitions and treatment of components, finished products, systems and
installations. They also place more responsibility on the manufacturer for EMC
performance.
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| Is it possible to certify products without testing? |
| If harmonised standards exist for the product, testing is not mandatory though, of course, it is highly advisable to ensure that the apparatus does comply. For the TCF Route it is unlikely that a Component Body would "sign-off" the file if no testing had been performed. For the Type-examination Route, testing is mandatory. |
