SLIM Recommendations on EMC Directive (Report September ‘98)

1. SLIM Recommendationson EMC Directive(Report September ‘98)

2. RecommendationsR1-R4 • Free movement of goods • The EMC Directive should remain a total harmonisation directive by which free movement of goods is ensured. • The text should ensure that no additional national measures related to EMC are created. The Directive should cover all relevant aspects of EMC which would otherwise allow for such national measures on the basis of Article 36 of the Treaty. • Global considerations • EMC legislation should not result in added costs for consumers due to unique requirements where this cannot be appropriately justified as being essential for the European market only. • European industry should address a global marketplace without unjustified additional costs and delays.

3. RecommendationsR5-R9 • Safeguarding the public interest (safety) • Functional safety should be addressed in directives containing essential safety requirements. • The impact of functional safety should be investigated in relation to both hardware and software. • The Standing Committee or the Working Parties under these directives should confirm whether or not functional safety is taken into account under their directives. • Immunity requirements should be more fully addressed in the EMC Directive to prevent new national legislation. • The protection requirements of the EMC Directive should contain the emission and immunity requirements in such detail that only specific technical questions (e.g. levels, test methods, requirements specific to certain products are product families) are left to standardisation.

4. RecommendationsR10-R12 • Safeguarding the public interest • The required “high level of protection” should be achieved by mandatory emission requirements as the first line of defence of the limited electromagnetic spectrum. Those emission requirements should take into account radiated and conducted emissions. • The protection requirements should define certain classes of EMC environment and conditions for the intended use of products within those classified environments. • Large machines and installations • Suitable definitions of “large machines” and “installations” should be included in the directive; large machines should be treated as installations. For clarification, the definitions of “small installations”, “large machines” and “networks” should be added.

5. RecommendationsR13-R14 • Large machines and installations (continued) • In the absence of complaints, installations and large machines should not be subject to assessment tests. If assessment is necessary, a possible way may be to monitor emissions from the installation at a reasonable distance from the perimeter of the installation (radiation) or at the utility supply connection point (conduction). • The Directive should be amended in a way that compliance of a fixed installation with the essential requirements of the Directive should be ensured by following the EMC assembly instructions given by the manufacturer of the constituent parts and using a method of installation which is in accordance with good engineering practice within the context of the installation, as well as installation rules (national, regional or local). For fixed installations there should be no need for CE marking, an EC declaration of conformity or involvement of a competent body.

6. RecommendationsR15 • Large machines and installations (continued) • The Directive should allow installations to be constituted by either : - CE marked apparatus (CE+CE=CE) - apparatus with CE marking and parts without, - not CE marked parts at all.In case of a challenge appropriate measures have to be performed either on component or on installation level (compensation measures) to bring the installation in compliance with the protection requirements of the directive.

7. RecommendationsR16-R17 • Standards • The Commission should request from European standardisation bodies the setting up of a strategic review panel of the EMC standards within the framework of the EMC Directive. Such a panel should consist of a representative of the Commission, standardisation experts from Member States, Industry, CENELEC and ETSI. The task of the panel should be to take a critical look at all EMC standards, their relevance and their applicability. Regarding preparation of future standards the panel should further discuss the necessity of a new mandate from the Commission to CENELEC and ETSI in order to produce fewer and more usable standards. • Dealing with EMC requirements of other Directives • The Commission should not propose any new vertical EMC legislation unless it is related to safety or it is clearly demonstrated that the particular issue cannot be dealt with adequately within the EMC directive.

8. RecommendationsR18-R19 • Dealing with EMC requirements of other Directives (continued) • The Commission should consider whether there is any need for EMC provisions in existing vertical directives given that relevant technical standards can be produced under the EMC Directive. • Impact of the EMC Commission Guidelines on the application of the EMC Directive • The Directive should be reviewed with a view to revision taking due account of the Guidelines, in order to incorporate :a. definitions specific to the EMC Directive (components, autonomous function, EMC passive equipment, etc.).b. the EMC analysis processc. the procedure for application of the Directive to installations, apparatus and systems with various configurationsd. any other areas which could be usefully transferred.

9. RecommendationsR20 • Final recommendation of the SLIM EMC team • The Team underlines that several individual recommendation made above relating mainly, but not exclusively, to the Commission Guidelines should result in the Directive being reviewed and amended. The Team therefore recommends that a review of the Directive be initiated by the Commission.

10. EMC Working PartyEMC SLIM Working Group

11. Organization & issues • Organization • EMC Working Party defines the political line to follow concerning the EMC SLIM report • Objective of EMC Working Party is to produce the text of the amendment to the EMC Directive by Autumn 2000 • EMC SLIM Working Group works out technical proposals according to the specifications established by the Working Party • Some issues referred to EMC SLIM WG by EMC Working Party • Suggest a proper way to include the definitions of the EMC Guidelines in an amended Directive. WG to look into ways for improvement of definitions. • Proposal for fixed installations which needs to be addressed by an amended EMC Directive (broad support for R12 to R15, some concerns on R13)

12. Organization & issues • Investigate the impact of the new R&TTE Directive, and how the EMC Directive can be clarified at this respect • Specify protection requirements with the objective that the EMC Directive can be applied uniformly (R9) • Consider the technical feasibility to include the definitions of EMC environments in the Directive

13. Organization & issues • Trends • Discussion mainly focussed on two topics : Installations and Environment • Installations • Current proposals on installations go in the direction of the Commission’s guide on the application of the EMC Directive • Environment • Not conclusive for the moment (Approx. 50/50 split on the need for definition of environments in the Directive) • Idea raised to include three environments in the Directive itself, i.e. - General environment - Industrial environment (for which it is considered to delete immunity requirements) - Special environment

14. Strategic Review Panel(SRP)

15. Terms of Reference • Terms of Reference formulated to implement R16 of the SLIM Report. The strategic review should be performed in order to achieve the following objectives : • To ensure coherence and consistency : • between harmonised standards and protection requirements of the EMC Directive • in the definition and classification of environments for the whole set of EMC harmonised standards • between the number of tests and severity of the limits and the protection requirements of the EMC Directive • between the horizontal and the vertical standards

16. Terms of Reference • To avoid : • unnecessary proliferation of EMC harmonised standards • To identify : • EMC phenomena to be considered in the EMC harmonised standards by taking account of protection requirements • means of simplifying the testing procedures • needs regarding transitional regimes and ensuring required changes • To consider and improve, as necessary, the procedure of co-ordination between various EMC related standardisation activities • All necessary actions to be undertaken following the strategic review should be clearly identified • The strategic review should start within the shortest possible delay, with the final contributions expected for autumn 2000

17. Outcome SRP#1 • Agreement on the Terms of Reference for SRP, as proposed by the Commission • Agreement to structure the discussion according to topics covering the main concerns : • Environments • Phenomena • Levels (of immunity and emission) • Hierarchical order (basic, generic, product stds.) • Inconsistencies • Special equipment • Standardisation process • Proliferation of standards • Relationship CENELEC/IEC

18. Outcome SRP#1 • Input papers for SRP #2 on “Environment”, “Basic, generic & product standards, and their relation”, “Proliferation of standards” will be worked out by ad-hoc groups • Environment • Environments and phenomena topics belongs to standardisation field and should not be included in the EMC Directive • Emission : main stream idea in direction of one environment for RF • Advantages/disadvantages of one or two environments to be worked out • Proposals on how to resolve the difference in environmental classification between the generic standards and product standards, e.g. EN55022

19. Outcome SRP#1 • Basic, generic & product standards, and their relation • Introduction of new idea to have equal status between generic standards and product standards for presumption of conformity with essential requirements • Discussion paper required addressing following topics - current and newly proposed relationship - judgement of consequences of the proposal - completeness of present generic standards (e.g. RF>1GHz) • Proliferation of standards • Proliferation of basic immunity standards : not based on facts but on fears (lack of information and communication) • Proliferation of harmonised product standards : 3 groups responsible for 50% of the documents. ETSI TC-ERM has already started the process to reduce the large number of radio EMC standards.

20. Outcome SRP#2 • Environments and classes • Majority of SRP members is not in favour for possibly removing the precedence of product (family) standards over generic standards, at least not for the time being • Set up of an SRP/AHG3 “Framework of generic standard(s)” • To prepare a framework proposal regarding a possible future generic emission standard, bearing in mind in particular following principles : . How can this generic standard be more complete/universal ? . Which are the formalities to offer more freedom to the user for selecting different options and related limits from this generic standard ? . Which limits are to be foreseen ? . Which (kind of) phenomena are to be included ?and with the understanding that this generic standard contains all emission requirements (radiated and conducted). • Immunity • There is no incentive for modifying the present approach towards immunity

21. Outcome SRP#2 • Proliferation of standards • Proposal regarding transparency of EMC standardisation and required documentation (i.e. collation of documents) for the next SRP meeting • Availability of harmonised standards • A cross-reference list between products and their related standards would be useful • Items under consideration • CENELEC to be requested to apply the same principle as in ETSI • “Under consideration” allowed up to Public Enquiry and then taken out of draft standard