Hey Brian,
Since the question seems to be about addressing the hazards and risks posed by deploying the unit into North American garages and residential areas, I think I can give you a pretty clean answer independent of the limit you tested to. 

I’m going to assume that when you said “some number of dB above the limit” you didn’t mean that you were anywhere near 120 dBuV (1 V/m) which would put you in the range of potentially starting to investigate medical device interference.  

Either way, the purpose of emissions testing is to protect authorized users of RF equipment from interference. 
So your risk approach would be to look at your failure, your installation environment(s), and the FCC to determine where there are any overlaps in frequency and potential devices for authorized users of the spectrum.  (https://www.fcc.gov/sites/default/files/fcctable.pdf)

Interference to any equipment in that range would then give you a first pass risk consequence. 

For example, Garage Doors tend to operate between 310 - 400 MHz, or via wifi. Neither of those would be a concern for a sub 200 kHz outage so no need to worry about the door flying open while the car is charging. 

Good luck, and hopefully this helps!
Michael Viau

Sent from my iPhone

On Aug 26, 2025, at 3:08 AM, John Woodgate <[email protected]> wrote:



CISPR 16-2-1 is about methods of measurement: it does not set limits

On 2025-08-26 00:41, David Schaefer wrote:

UN ECE Reg 10 references CISPR 16-2-1 for powerline conducted emissions, so that seems like the most appropriate method to use.

 

 

 

 

 

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From: Ken Javor <[email protected]>
Sent: Monday, August 25, 2025 11:08 AM
To: [email protected]
Subject: Re: [PSES] Hazards, risks with EMC emissions?

 

CAUTION:This email originated from outside of Element Materials Technology. DO NOT click links or open attachments unless you recognize the sender and know the content is safe. Please report suspicious emails using the Report Phishing button in Outlook.

CISPR 25 only applies to protection of on-board receivers, which means it only applies to equipment part of the automobile.  The EV charger is described as part of the home or office, not the vehicle.  Neither CISPR 25 or CISPR 12 apply.

 

-- 

 

Ken Javor

Ph: (256) 650-5261

 

 

From: Karen Burnham <[email protected]>
Reply-To: ***** IEEE emc-pstc List ***** <[email protected]>
Date: Monday, August 25, 2025 at 10:02 AM
To: <[email protected]>
Subject: Re: [PSES] Hazards, risks with EMC emissions?

 

The test methods between CISPR and FCC are really different, and as John said, CISPR 12 shouldn't apply to this at all. Would it be possible to test to CISPR 25 instead? That's a much closer match. 


Best,

-=-Karen Burnham

President and Chief Engineer, NCE

EMC United, Inc.

 

 

On Fri, Aug 22, 2025 at 1:48PM John Woodgate <[email protected]> wrote:

CISPR 12 does not apply to such a charger. This is quite explicit in the Scope clause. I would tell you to go to the IEC Webstore and take a read-only look at the Scope, but perversely, what you get is the French version. 

CISPR 12 covers radiated emissions, 30 MHz to 1000 MHz, so I don't understand what you are getting at with conducted emissions below 200 kHz.

On 2025-08-22 19:46, Brian Gregory wrote:

 Hello,

 

We market an EV charger to the N. American market.  We've been contacted by major automotive OEMs for partnerships, some white labeling, etc.

Recently, one decided to test a charger in chamber with an EV to CISPR12 levels, even though it's an off-board charger qualified as a residential appliance.

 

So, while the unit passes FCC Class B emissions, some testing during EV charging shows emissions above CISPR12 limits.  We and our potential customer are trying to reason out why the unit failed, and what are the implications for passing FCC Class B, while not passing CISPR12.

 

The way I like to approach sticky issues on the edge of compliance is to identify and address the hazard posed. 

So, with EMC emissions some number of dB(uV) above those limits (all towards the low end of allowed conducted limits, < 200 kHz), in a typical residential installation on or near a garage, and typical usage, i.e., not closely attended for any extended length of time:   what are the hazards or risks posed?

 

 Not being much of an EMC guy, I've never really had to think too much on this issue.  Being a long time safety guy, I have NEVER had an issue related to EMC from which to draw experience.

 

What say you, my colleagues?

 

Colorado Brian 


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