Can I just up-issue my Declaration of Conformity to show compliance against the New Directive?

Analyse if product meets the latest harmonised EMC standards,

If standards to which product was previously tested are out of date then a comparison needs to be made for each individual test to determine if there are now more onerous requirements (for example your product may not meet all of the requirements for Radiated Immunity due to increases in frequency ranges for test and some test levels)

Depending on the results of this gap analysis it might be possible to base compliance upon technical rationale. If not then further testing may be required.

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Our products are too large to test in an EMC Chamber. What testing am I expected to carry out on my products?

If it is not feasible to test a product in an EMC chamber then in order to satisfy the essential requirements there will need to be a combination of in-situ testing and Risk Analysis work. The in-situ testing can be conducted either at your facilities or at the final place of installation. The tests conducted would be dependant on the equipments location. It may not be feasible or practically possible to conduct certain tests. The technical documentation produced will therefore need to take into account all of the phenomena applicable to equipment in its operating environment. Where tests cannot be performed in-situ then technical rationale will need to be produced and include the good EMC engineering practises that have been employed. This might include shielding, cable segregation and maybe the addition of EMC filters. Installation and maintenance guidance with respect to EMC will also need to be supplied.

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Is mobile installation a new requirement, how is this CE marked?

Mobile installations cannot fall under the fixed installations requirement as they do not fall under a pre-defined location. Mobile installations therefore follow the apparatus route to compliance. Trains for example are mobile apparatus and have their own harmonised standards.

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I want to use a later version of an ETSI Standard than the version of the Harmonized Standard listed in the OJ. What must I do to show compliance?

If you are using other than a listed Harmonized Standard then it would be normal to include a justification in the scope of the test report(s) so that the test house has a clear view of what is expected of them and what tests are to be omitted or changed. This may also have an effect on the scope of their accreditation and the way in which they produce reports. (They will be accredited to a particular version of a standard but if you wish them to use a different version of the standard it may be outside their current accreditation). They need to be consulted first and they might wish to refer the matter to their Accreditation Body for a view. Finally you should produce a justification for using another standard and include this in your technical file. The Notified Body you use will include this in their assessment and Opinion.

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I am not familiar with marine equipment. What does SOLAS mean?

SOLAS equipment means “Safety of Life at Sea.” This essentially means ships above a certain size and capability which have a legal duty to respond to safety and emergency calls. Vessels below a certain size do not. There is also a legal requirement for vessels greater than a certain size to incorporate mandatory safety features. These requirements are complex and you should refer to the SOLAS regulations for further details.

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What about components; are they subject to CE marking?

[TPS Comment] Components are covered by the regulations provided they fall within the scope of the regulations. E.g. a resistor being a passive device and falling outside the scope of the regulations is NOT subject to CE marking. A dc-dc converter module is covered by the regulations and therefore CE marking applies. If we take the case of the Low Voltage Directive only components which are “electrical equipment” need to comply with the regulations. Interestingly and unfortunately the term “electrical equipment” is not defined in the regulations and as such we suggest you use the standard dictionary definition: Electrical – “operated by means of electricity” Equipment – “the things collectively necessary to perform an activity or function”.

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How does CE marking apply to second hand and refurbished equipment?

[TPS Comment] CE marking does not apply to second hand equipment provided that second hand equipment has been previously placed on the market within the EU. If you are importing it into the EU for the first time then CE marking applies. Where equipment is refurbished in accordance with the original specification the requirements for second hand equipment apply. If however the refurbishment incorporates updates or upgrades such as different types of components the equipment is subject to CE marking and must be re-assessed.

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