The importance of fulfilling EMC obligations

Advice to end users on what they need to know about their machinery manufacturer’s electromagnetic compatibility (EMC) obligations and what the future holds.

By Ian Wright June 16, 2023
Courtesy: CFE Media and Technology

EMC insights

  • Electromagentic compatibility (EMC) compliance is critical because it can cause major damage to other equipment if machines generate too much interference.
  • Third-party EMC tests and conformity assessments help ensure a product maintains its desirable features when exposed to adverse conditions and does not cause undue interference.

There can be no doubt about the need for electromagnetic compatibility (EMC) compliance. If the electrical and electronic systems fitted to a machine generate a high level of interference, they may cause other equipment nearby to malfunction and create a dangerous situation. It is vital machinery end-users understand how those manufacturing and supplying their machines are required to ensure their products meet EMC requirements. Section 10 of the Provision and Use of Work Equipment Regulations 1998 (PUWER) states that “every employer shall ensure that an item of work equipment has been designed and constructed in compliance with any essential requirements.”

The importance of EMC testing

Not only does EMC testing ensure that products meet regulatory requirements, it reduces the risk of costly non-compliance. Third-party EMC tests and conformity assessments help to ensure that a product maintains its desirable features when exposed to adverse conditions (immunity test) and does not cause undue interference (emission test).

The machinery manufacturer must also have a relevant conformity assessment procedure carried out and technical documentation drawn up. Once this is completed, the manufacturer is required to draw up a declaration of conformity – a document which declares that the product is in conformity with the relevant statutory requirements applicable to the specific product. Any technical documentation and the declaration of conformity must be kept by the manufacturer for 10 years after the machinery was first placed on the market.

The CE (EU market) or UKCA (GB market) marking must then be affixed to the machinery. The manufacturer must also label machinery with their name, registered trade name or registered trademark, a postal address, and the type batch or serial number. If it is not possible to affix these details to the machinery, this information can be placed on the packaging and the accompanying documents.

Until December 31, 2024, machinery that conforms to EU requirements may be placed on the GB market. So, until that date any new machinery which displays the CE marking is acceptable. This means that such machinery can continue to circulate on either market until they reach their end of use.

Over time, as adjustments are made to the manufacturing process and new or updated components included within a machine, the manufacturer must ensure that procedures are in place for it to remain in conformity. They must therefore take account of any changes in electrical equipment design or characteristics, and any change to a relevant harmonized standard or any technical specifications which are referred to in the Declaration of Conformity.

However, products which are repaired, refurbished or exchanged without changing their original performance, purpose, or type, are not considered “new” and do not need to be recertified and remarked. This includes if the product is exported for repair. Any new spare parts can comply with the same conformity assessment requirements that were in place at the time the original product or system they are ultimately intended to repair, replace or maintain was placed on the market.

Combining machines

While a single item of equipment might meet these limits, there is no guarantee that if multiple items or additional components are combined the overall emission levels will still be satisfactory.

Therefore, the final integrated product, or fixed installation, must be assessed against EMC standards. A fixed installation is defined as ‘a particular combination of several types of apparatus and, where applicable, other devices, which are assembled, installed and intended to be used permanently at a predefined location.’

Large installations may also fall under the definition of a fixed installation, as Article 3 in the EU’s Machinery Directive, and under interpretation in the UK regulations, includes the following definition: “…a particular combination of several types of apparatus, and, where applicable, other devices, which are assembled, installed and intended to be used permanently at a pre-defined location…”

A fixed installation must be installed applying good engineering practices and must respect the information on the intended use of its components, and meet the essential requirements. All of this information must be documented and held by the designated ‘responsible person’, so that it can be made available to the enforcement authority on request.

Operators of fixed installations need to identify the responsible person before it is taken into service. A responsible person is defined as one who holds a position of sufficient responsibility to control the configuration of the fixed installation. However, they do not have to be an EMC expert, as they are allowed to seek appropriate advice.

An EMC management or test plan should be developed for any fixed installation and machinery owners would be well advised to contractually require suppliers to submit technical documentation along with their sub systems.

A management plan for larger installations should specify the intended environment and a list of appropriate standards for suppliers at the outset. It should be noted that all commercially available equipment, which is part of the fixed installation, must be CE or UKCA marked, and should therefore have a declaration of conformity supported by technical documentation.

If there is no means of identifying whether the components, machines or the installation conform to the EMC requirements, machine builders must prove compatibility by way of EMC testing.

While EMC may appear to be complex, it doesn’t mean that machinery manufacturers can ignore their legal obligation to ensure their products meet requirements. Neither should machinery end-users plead ignorance, making the assumption that their supplier is doing the right thing.

– This originally appeared on Control Engineering Europe’s website.

Author Bio: Ian Wright is Chief Engineer at TÜV SÜD.