Scott If you read the Guide to the EMC Directive, specifically section 1.4.4 Inherently benign equipment you will find multiple references to certain product categories being exempt only if they are “without active electronic parts or active components;”
A transistor is an active component. So whilst you are very likely to have no EMC emissions or immunity issues, I would not be able to write an argument that exempts your product from the Directive. You EMC assessment against Harmonised Standards does not mandate testing against all aspects of them, but I would imagine that at least some radiated and conducted emissions would be diligent. In the absence of a product standard, the Generic Standards, EN 61000-6-x are the appropriate route and the ones you should assess against and list on the DoC. As an aside, a Notified Body cannot state that a product is inside or outside the scope of the Directive as that is outside of their remit under the Directive and their accreditation. Best regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: https://sulisconsultants.com/ Registered in England and Wales, number 05466247 From: Scott Douglas <sdouglas...@gmail.com> Sent: Wednesday, September 27, 2023 2:35 PM To: 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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