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26 May 2009

Rob Hillyard, EMC Engineer at TRaC looks at the implications to manufacturers of the latest EMC Directive (2004/108/EC).

20 July marks the end of a two year transitional period during which time manufacturers should have been updating their technical documentation and DoC to meet the requirements of the new EMC Directive 2004/108/ECMonday 20 July 2009 marks the end of a two year transitional period during which time manufacturers should have been updating their technical documentation and Declarations of Conformity (DoC) to meet the requirements of the new EMC Directive 2004/108/EC.

Throughout this transitional period, manufacturers have been able to demonstrate compliance to either the old EMC directive (89/336/EC) or the new one; 2004/108/EC. All apparatus, defined as a finished appliance or unit, component or subassembly, mobile installation or system placed on the market or taken into service from 20 July must have a DoC declaring compliance to the new directive. All declarations (and hence CE marking) against the old directive cease to have any validity after this date. The 2004/108/EC directive requires that all new products offered for sale, taken into service or made available for internal use must comply with the directive.

‘Apparatus’ has always been covered by the scope of the EMC directive, although ‘Fixed installations’ are a new concept in Directive 2004/108/EC and have had to comply with the directive from July 2007. Fixed installations do not require a DoC or to be CE marked, but they must demonstrate compliance with the protection requirements of the new directive.

For manufacturers of apparatus, the changes are largely administrative and the process of complying with the directive is essentially the same; identify relevant harmonised standards, generate test evidence to support compliance to the standard, produce technical documentation, and issue a DoC accordingly.

There is increased flexibility for importers of products tested to non-EU test standards. An ‘EMC assessment’ (testing to harmonised standards also constitutes an EMC assessment) can be performed, which compares the technical documentation against the requirements of the new directive. It allows for a justification in the Technical Documentation as to why compliance to the protection requirements of the EMC directive can be assured.

Highlights of the new directive include:
• Improved definitions
• Improved market surveillance
• Treatment of fixed installations
• Improved clarity of essential requirements
• Clarification of the role of standards
• Simplification of the conformity assessment procedure
• Cutting so-called ‘red tape’ to improve manufacturers' choice and voluntary use of Notified Bodies

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