What legislation and standards are applicable for wall mount / table-top clocks operating on 1.5 V pencil cells having no connections to mains?
The applicable EU / UK legislation for CE / UKCA marking would be The EMC Directive / The Electromagnetic Compatibility Regulations and The Restriction of Hazardous Substances Directive / The Restriction of Hazardous Substances Regulations.
If the clock has any radio functions, instead of the EMC legislation mentioned above it would be subject to The Radio Equipment Directive / The Radio Equipment Regulations.
If you are planning to place the product in Great Britain from 1st Jan 2022, you will also have to apply the UKCA marking requirements.
Last updated: 2021-08-16 15:52
We are a UK company buying in individual electronic equipment from the EU (PC, GPRS modem, hub etc), installing software and re-selling them into the UK as a different branded product. Do we need any additional EMC testing, or will the individual Declarations of Conformity from our suppliers be sufficient?
Additional testing requirements will be dependent on the information provided and what the consequence of your installed software is on the original items. If the software installation is consistent with the intended use of the equipment, then further EMC testing would not normally be necessary, since the assessment carried out by its manufacturer should cover such an operation.
Last updated: 2021-08-16 16:00
We are a small lighting manufacturer and put CE marked components (High frequency ballasts, fused terminal blocks, lamp holders, fluorescent lamps, etc) into a housing and sell them as mains light fittings mainly to the industrial sector. Do I need to get these fittings (various styles) independently tested?
Your product will be covered by a combination of the EMC, Low Voltage, ROHS and maybe Eco-Design Directives. None of these directives mandate compulsory third party tests, so you can self-certify all the equipment if you are confident that it does in fact comply with the appropriate standards. You can check this for yourselves by obtaining a copy of the appropriate standard(s) and checking your products against the requirements.
Conformance can help in identifying the applicable standards for your product range.
If you plan to sell your product within Great Britain, UKCA marking will be required from 1st Jan 2022.
Last updated: 2021-08-16 17:56
Our company makes and sells electronic systems consisting of a multi-slot card rack and several types of plug-in cards. Each system is custom configured and can contain any combination of any of the cards. There are a very large number of combinations possible for configurations, so many that it is unreasonable to test each possible configuration for EMC compliance. What is required for this type of system?
This is a typical problem with computers and similar equipment.
Where there are a large number of configurations that can be made, we recommend creating a typical system or a system that contain most of the normal cards or a system that contains all of the component options, that you use in your system.
Then you test those arrangements.
The worst case profile would generally consider the most / longest cable(s) and all possible accessories.
Last updated: 2021-08-16 16:02
We are a manufacturer using a power supply which has CE marking, however. However, when we incorporated it into our equipment, it failed one of the EMC tests which it is required to pass to be sold in Europe. In particular, the IEC 61000-3-2 harmonics regulation which need to pass for CE marking. However, the device failed the test at our accredited EMC test lab. I’m asking for test results to justify their CE marking. Who should we contact about such violations of mis-use of CE mark?
It may be that you are using the power supply as part of your product, out of its operation specification. It could also simply be a faulty power supply. There are other possibilities as to why it may now have ‘failed’ the EMC tests.
In the first instance you should go back to your supplier or the Original Equipment Manufacturer to resolve this issue.
Last updated: 2021-08-16 14:07
I would like to enquire whether lithium battery packs (primary or rechargeable) should be CE marked? Is there any specific CE directive for battery pack? If not, are we supposed to have the CE mark printed on the battery pack?
The batteries will only need to be CE marked if they contain electronics (e.g. a charge control/monitoring circuit) in addition to the cells. Otherwise, they are treated as components and are only CE marked as part of the complete appliance.
You will also need to ensure you comply with the Batteries Directive 2006/66/EC which, among other things, requires the product to be marked with the crossed-out wheelie bin logo.
Last update: 2021-08-16 14:11
We manufacture electric motors and are updating our Declaration of Conformity. Most of manufacturers of motors stated the following on their Declarations: "We are conforming with the essential requirements of EMC Directive as components, regarding the intrinsic characteristics to emission and immunity levels." Is this statement necessary?
Item 2 (d) of Article 2 of the EMC Directive 2014/30/EU states that the Directive does not apply to equipment which is intrinsically incapable of causing electromagnetic disturbance or of being affected by it. The Commission Guide to the Directive gives induction motors without electronic circuits as an example of such equipment.
If equipment is excluded from the Directive then the requirements of the Directive, including the need to comply with the essential requirements and to issue a Declaration of Conformity, are irrelevant and no Declaration is required. The statement you quote is therefore superfluous.
It's important to note that there is no specific exclusion for motors in the Directive, and, indeed, some types of motor (e.g. commutator motors) can be extremely noisy from an electrical point of view. Such motors would not be excluded from the scope of the Directive on the basis of item 1 of Article 2.
Last updated: 2021-08-16 16:12
Our company manufactures video monitors for the arcade and gaming industries. These monitors do not have complete enclosures and are only for installation in the games produced by our customers. Does the EMC CE Directive apply to our products?
If your customer is not the end user, i.e. they integrate your monitors into the finished product to be sold on as part of their product to the end user, then your monitors do not technically fall within the scope of the Directive and therefore you would not need to apply the CE mark to the monitors in relation to the EMC Directive.
If you did have EMC test evidence for the monitors this may be useful to your customer, when performing their conformity assessment process on the integrated monitors.
Last update: 2021-08-16 16:14
We have an item of simple equipment designed for use in an industrial application. It is powered from 24 VDC and contains a very low power electronic circuit. It is CE marked as compliant with Electromagnetic Compatibility Directive. What information do we need to put on a label affixed to the product?
Without knowing what the equipment is, it is difficult to confirm what marking the product specifically requires with respect to the EMC Directive.
As an example, typical marking requirements are:
- Name, registered trade name or registered trade mark and address of the manufacturer.
- Model number or distinguishing name - product, type, batch or serial number (if any).
Last updated: 2021-08-16 16:21
We design and package electronics project kits on a very small scale for a niche market. The kits, once constructed by the end-user generally, are designed to be used within computer equipment manufactured in the 1980s. It would be financially impossible to perform commercial EMC testing of these products, and in any case the shielding properties of the end user hardware is unknown. Could self-certification be considered reasonable on the basis that the products could comply? Should they be prop
The EMC Directive does not require you to test products, but if you do not thoroughly test then you need to decide what alternative evidence you can use to show that the essential requirements of the Directive have been met. I understand the point about not testing every different kit but this does not necessarily mean that no useful testing can be done, unless the kits are all completely different from one another then results from one will tell you at least something about the others.
All Declarations under the EMC Directive are self-certification, so even if you get tests done, this will only support your own Declaration. It is up to you to decide what level of testing is required to get the evidence you need to be comfortable with your claim of compliance.
You also need to bear in mind that there is a due diligence defence and a court is unlikely to be impressed if you made no attempt at all to characterise the EMC performance of your products: showing good intent by setting a budget for testing and getting some regular results is likely to be looked on more favourably even if the results are in practice of questionable technical relevance.
Be aware that a steel case is not usually a reliable means of shielding: at the frequencies likely to be a problem all apertures in the case are likely to be significant, the contact resistance between different parts of the case will also be significant, and the most likely sources of interference will be connected to cables which pass out of the case anyway. While it is perfectly possible to use a metal case as a means of controlling EMC, it usually requires mechanical and electrical design which is a lot more sophisticated than a simple steel box.
Last updated:2021-08-16 16:23
What directives and standards will be applied for our product which is a speed switch transmitter used for measuring the speed of turbine or engine and transmitting it into 4-20mA or 0-1mA form to a PLC or SCADA system to monitor and control the engine speed?
If your product is intended for sale to end users then the EMC Directive will apply. If it is only intended for sale to system integrators then strictly the EMC Directive will not apply, but your customers will probably expect you to have test data for EMC tests anyway.
The RoHS Directive will apply unless your customers are exempt under the Large Scale Industrial Tools or Large Scale Industrial Installations exclusions.
The ATEX Directive will apply if your product is intended for use in hazardous (flammable vapour) zones.
Last updated: 2021-08-16 16:25
Our product does not create nor respond to electromagnetic field, we are about to test this to have a little piece of paper proving this. In order not to have to worry about the EMC Directive, should we attach the result of the test to the technical specification document?
While you may be able to make the case that your product is EMC benign and hence outside the scope of the Directive, you may actually be better off to consider it as being within scope but justify compliance on the basis of a technical argument that it neither generates EMF nor is susceptible to it (at least at the levels defined for the tests in the standards). This allows you to CE mark under the Directive, which is probably what your customers want to see.
Last updated: 2021-08-2021 16:26
I am looking at a small piece of process equipment that has a 24 volt 0.022 hp motor. Would you have expected this to be covered by the EMC Directive? If so, is there an applicable BS EN standard?
Electric motors obviously operate on electrical fields and hence have the potential to cause or be affected by interference, even if the chances of this actually happening are very low. This means that they are potentially 'apparatus' within the meaning of the EMC Directive. However, a motor on its own is only a component and will always need to be built into something else (a machine) in order for it to do anything useful (i.e. have a function).
This being the case, motors are actually excluded from the scope of the EMC Directive because they are not 'intended for the end user' so it's perfectly legitimate for them to be sold without the manufacturer making any statement about EMC compliance.
In practice, some equipment which includes motors will be CE marked for EMC on the basis of the status of its components (the “CE + CE = CE” route) rather than by being separately tested. There is a separate debate to be had about whether or not this is actually a reliable approach to demonstrating compliance with the Directive but it is a fact that this is how the market sometimes operates and in practice, so far as industrial three phase induction motors are concerned, it's difficult to conceive of circumstances where this approach is not valid - the problems only come when you include some complex switchgear or (especially) a variable speed drive.
Motors with some form of switching (a commutator or a centrifugal switched start winding, for example) are much more likely to be a source of emissions, and solid-state commutated brushless 'DC' motors (increasingly common in power tools and servo drives) are almost certain to be a source of noise and may also be vulnerable to external interference if they are not correctly designed and tested. If you are a manufacturer incorporating such motors into your products then you will either need to test the finished product or you may choose to rely on information from the motor manufacturer which indicates that the EMC performance is acceptable. The latter approach is arguable fairly risky, but that does not mean it does not happen, and savvy motor manufacturers know that they can enhance their sales by making statements about the EMC performance of their products. Such statements will commonly be in the form of CE marking the motor under the EMC Directive even though strictly it is excluded from the Directive's scope.
Last updated:2021-08-16 16:27