The phrase, “as to ensure that”, implies some testing would be needed for both emissions and immunity. The directive doesn’t insist on testing, but in order to meet the “essential requirements” testing would seem the only way to reinforce a claim of compliance.
From: bart.de.gee...@telenet.be <bart.de.gee...@telenet.be> Sent: Wednesday, September 27, 2023 7:00 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] 50Hz Product and the EMC Directive Hi Scott, The directive also states: ANNEX I ESSENTIAL REQUIREMENTS 1. General requirements Equipment shall be so designed and manufactured, having regard to the state of the art, as to ensure that: (a) the electromagnetic disturbance generated does not exceed the level above which radio and telecommunications equipment or other equipment cannot operate as intended; (b) it has a level of immunity to the electromagnetic disturbance to be expected in its intended use which allows it to operate without unacceptable degradation of its intended use. * Besides the ‘emission’ part of the test there is also the ‘immunity’ related aspect of it. (You can do electrostatic discharge, EFT, surge and other tests). (and I do not see a reason why products not containing active oscillators would be excluded from immunity testing). * Although your product might not contain an active oscillator, I have seen products that only contained a few passive components, but where the manufacturer still succeeded to make an active oscillator (unwantedly) that exceeded the legal limits by more than 30 dB. Greetings, Bart From: Scott Douglas <sdouglas...@gmail.com <mailto:sdouglas...@gmail.com> > Sent: woensdag 27 september 2023 15:35 To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> Subject: [PSES] 50Hz Product and the EMC Directive Hello List Experts, We have a product that operates at line frequency (50 or 60 Hz). It is a power conditioner which includes filtering, surge suppression, and extreme voltage shut down. It is purely analog and contains nothing more complex than transistors. We believe the EU EMC Directive does not apply to the product because it does not operate any higher than 60 Hz and cannot generate EMI whether radiated or conducted. >From EU Directive 2014/30/EU, Article 2 (2 (d)): 2. This Directive shall not apply to: (d) equipment the inherent nature of the physical characteristics of which is such that: (i) it is incapable of generating or contributing to electromagnetic emissions which exceed a level allowing radio and telecommunication equipment and other equipment to operate as intended; and (ii) it operates without unacceptable degradation in the presence of the electromagnetic disturbance normally consequent upon its intended use; I am not aware of any EMI standards that cover this type of product, most conducted EMI starts at 9kHz or 150 kHz, and radiated EMI typically starts at 30 MHz. There is an inspector in an EU country that believes the EMC Directive does apply. Their letter makes these statements: The EU Declaration of Conformity (DoC) is incorrect or incomplete (Article 15; Annex IV; etc. of EU Directive 2014/30/EU). A conformity assessment procedure seems to be incomplete (Article 14) to demonstrate that the apparatus meets the essential requirements set out in Article 6 and Annex I of EU Directive 2014/30/EU. EU Directive 2014/30/EU is missing. Our DofC does not list the EMC Directive, specifically because we think it does not apply. It also does not list any EMI/EMC standards as we find none that apply. Is there a Harmonized Standard that would cover this type of product for the EMC Directive? Is it normal to list a directive in a DofC if that directive does not apply? How does one convince the inspector that the directive does not apply? Looking forward to any and all comments. Scott _____ This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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