Evaluation Engineering - 16

COMPLIANCE

RECENT DEVELOPMENTS
IN EMC LEGISLATION

Anechoic chamber for EMC
testing in Nemko, Norway.
Wikipedia Commons

by David Mawdsley
During 2018, the Federal Communications Commission changed the
procedural requirements for EMC compliance. Previously, the emphasis was
on measurements acquired by specialized, accredited test laboratories and
consequent certification issued by the
laboratories.
Now, manufacturers or importers of
products can confirm compliance with
the FCC's requirements using a self-test,
self-certification process, without having
to involve any third-party or test laboratory. The previous regime featured two
routes to compliance, verification and
Declaration of Conformity (DoC). These
are now replaced by one, the Supplier's
Declaration of Conformity (SDoC).
2018 was a transition period when
either the old requirements or the new
could be used to effect compliance. Since
January 2019, only the new requirements
should be used.
This new requirement represents a
significant change in the compliance
test requirements. What has now been
adopted is similar to that which has been
legislated in the EU since 1996. The relevant EU Directive is 2014/30/EU. This

EVALUATION ENGINEERING JULY 2019

has been enshrined in law by each of the
28 individual member states, creating
a "level playing field" across the whole
community. At its simplest level, the
Directive simply states that no product
should cause interference to others, or to
any radio/telecom services (emissions),
and should work normally in the environment in which it is intended to be used
(immunity). This immunity requirement
is not required by FCC.
The purpose of this article is to describe
the EU requirements so that U.S. manufacturers have an insight into how the
new rules operate.

The EU basic rules
These were introduced in 1996 and apply without exception throughout the EU.
Other territories such as Australia and
New Zealand, have adopted the same
rules:
* Manufacturers are entirely responsible for their product. This responsibility cannot be "delegated" or
offloaded to test labs (accredited or
otherwise) or a consultant.
* There is no such thing as an "official"
compliance test or type test

* Note that the EU Directive states
"achievement of compliance with
the appropriate standards only provides an assumption of compliance
with the EMC Directive." It is for the
manufacturer to perform any other
tests as may be considered alternative or additional, in order to satisfy
the EU Compliance statement.
* The manufacturer may use test
labs and/or consultants in order to
make measurements, but pass/fail
judgment is the responsibility of the
manufacturer.
* The manufacturer must assess the
results of any tests/measurements
and decide whether they consider
the product is compliant.
* What tests are performed and how
they are performed are at the discretion of the manufacturer.
* Basically, the system relies on the
honesty and integrity of the engineers and managers/owners at the
manufacturer. In general, the system
works well, with organizations from
"one-man-bands" to major internationals fulfilling their obligations
entirely.

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