MEETING REPORT. Electro-Magnetic Compatibility (EMC) Directive 2004/108/EC 22 st Working Party in Brussels, 28 th of May :00 14:00

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1 EUROPEAN COMMISSION Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs Industrial Transformation and Advanced Value Chains Advanced Engineering and Manufacturing Systems Brussels, 24 October 2016 Ref: EMC(23)02 EMC WP 22 meeting report PUBLIC.doc EMC/20/02 MEETING REPORT Electro-Magnetic Compatibility (EMC) Directive 2004/108/EC 22 st Working Party in Brussels, 28 th of May APPROVAL OF THE DRAFT AGENDA 12:00 14:00 No comments from delegations on EMC(22) APPROVAL OF MINUTES FROM LAST MEETING No comments were received. The minutes EMC(22)02 were approved. 3. UPDATE OF CONTACT LISTS No comments were received on EMC(22)07, EMC(22)08, EMC(22) LEGAL ISSUES 4. 1 Alignment of EMC Directive 2004/108/EC to (NLF) (information) - EMC transposition Workshop Concerning the alignment, Chairman informed that notifying authorities can start the notification of Notified Bodies (NB) according to the new Directive, provided the required provisions for notification are transposed into national law. Regarding the Workshop, the texts related to 3 Directives (EMC, LVD and RED) are being harmonised in order to circulate those 3 documents. A document should also be displayed quickly about the consequences for other Directives of the applicability of the RED (scope). Comments are welcome and will be discussed in next EMC WP. 4.2 Preparation of the Guide for new EMCD Regarding the preparation of the EMC Guide, Chairman thanked the "EMC ADCO preparation group" and particularly the Chairman for this task, (one of representative of NL). He asked to bear in mind that this document cannot change the legislation. Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2)

2 The EMC guide group Chairman introduced the results of the "preparation group" work on the current EMC Guide (doc EMC(22)16). The Commission is owner of the EMC Guide and the group will propose a revised version. Fourteen volunteers applied to the group with a good representation and balance between the stakeholders. Consumers are note participating unfortunately. The group will start its work at the 29 th of May and it is planned to finish the project by the end of the year. Chairman thanks all the participants of the group. 5. STANDARDISATION 5.3 New EMCD Mandate The Draft was circulated to everybody and comments were introduced. If there are still some comments to suggest, they should be sent rapidly. France asked how the conformity of standards to the mandate (and more generally to the Directive) will be evaluated, as there was recently a gap of work of New Approach (NA) Consultant. Chairman pointed out that the evaluation of the standards conformity is a task that falls also under the responsibility of all the Member States. Indeed there is a NA Consultant which follows the work but it is also very important that the standardisation representative of the Member States also follows the work to identify early the conformity with essential requirements of the legislation. CENELEC explained that first they advised to remove the reference to the mandate M313 in the EMC Mandate, as the work was not finished under this Mandate, but after reflexion, the reference to the M313 should be re-introduced (it was first a misinterpretation of CENELEC) in article 6 "Validity and expiration". Chairman confirmed that this will be examined and changed if appropriate. 5.4 Standardisation work following the 800MHz Decision The ETSI representative presented document EMC(22)49 in which two slides are on Digital Dividend. The joint working group ETSI-CENELEC has prepared a draft report. There is a consensus waiting for final approval. The more controversial discussion with potential interference between LTE and Microphones in this band was solved with Harmonised Standard EN , it was agreed to reduce emission mask of 3 db, and in parallel to improve the immunity of SRD. On TV side, there is a recommendation to create a new standard within the RED for television receivers and the discussion is expected for next ERM in June. In the joint meeting group it was also discussed the impact of LTE on cable networks and the work to be done. 5.5 Workshop 700 MHz - Future orientated EMC standardisation at UHF frequency ranges Chairman indicated that the workshop was considered useful by the stakeholders. Main points of the discussion were about: spectrum policy perspectives in the UHF band and in 700MHz, the prospects of some Member States for the deployment of the 700MHz band and the experience learned with 800MHz. 2

3 5.6 Cable certification scheme The Commission launched the study concerning the cable labelling. Eight companies where consulted, only four were interested in performing the study but finally only one company applied and met the criteria: LM Ingenierie associate to IDATE. A draft questionnaire was set up and a list of persons to contact determined. The report should be finalised in November in order to provide the results at the next EMC WP. 5.7 Article procedure against the harmonized standard CENELEC (Chairman of CLC/TC 210) answered the question raised by Germany on EN which concluded that in the opinion of CENELEC both alternative methods included in the standard do meet the essential requirements. Germany asked how CENELEC came to this conclusion. Thirteen db are too much, a too big difference between both alternative test methods. CENELEC answered that the two test methods are an alternative offered to industry to meet the same requirements. For Swiss Delegation the problem is not to have two different methods of test, but the problem is to obtain two different results from the tests (so 2 different levels of protection). If method 1 meets essential requirements, then why to not increase the limit of method 2, in order to have the same limit. Irrespective of the method used by the manufacturer, the result should be the same. Netherlands Delegation (NL) underlines that Directive does not exclude the use of alternative methods if they both meet the essential requirements. It is useful for industry to have flexibility to choose one or the other and NL would like to keep this flexibility. The main concern would be if one of those methods wouldn t meet the essential requirements, but as shown by CENELEC it is not the case. So NL agrees with CENELEC and would like to keep both of them. CECED explained that during CLC/TC 210 meeting, after technical analyses, one of the reasons of the different results occurs from an open air test which makes difference of vertical and horizontal polarisation. This issue was discussed in CISPR. But unfortunately only the horizontal measure was done. In future the experts were requested to perform both measurements horizontal and vertical. Germany is not against alternative test methods (and agree with NL about this), but the problem for MSA is the comparability of the results between the alternative test methods. It is obvious that the new method has different limits. Ireland agreed with NL and Switzerland, and adds that the spectrum is more and more congested, so the best would be to have one limit for the two methods. EUANB indicate that this is a compromise and it cannot be given a proper protection to all frequencies. If a different method applies, it is not possible to compare their results. CECED understand the German position and propose to cooperate on this topic to align the alternative test methods but propose today to agree with the conclusion of CENELEC. Chairman asked if the work is foreseen by CENELEC to try to improve the comparability of results of both methods. 3

4 CENELEC explained that they are moving to more sophisticate solution to make the test faster. In fact is it impossible to have two different test methods which will provide the same results. You will never have direct correlation of the results, it would be in good case a difference of + or - 6dB. Chairman asked if there is a risk by using these methods, that breaking of essential requirements is not identified. CENELEC indicates that the old method is used more than 40 years and the new methods are using different chambers with a lot of work done in comparison of chambers (on the risk of correlation). So there are 2 different methods but they give the same protection. 5.8 Solar PV Installations and Fixed Installations The UK delegation presented a document on interference issues attributed to a solar panel, following a complaint. The question is about whether the definition of fixed installation for the purpose of EMC Directive should be revisited. The approach of UK would be to specify in the guide that this type of installation is a system or an installation but not necessary a fixed installation. Netherland delegation fully agrees with UK, as a lot of private installations are covered by the item. The problem comes from the definition which is quite limited. The explanations provided by manufacturers about the product are general and it does not depend on who will use it. It does not specify if it is a fixed installation. This should be better explained in the future EMCD Guide. German delegation (DE) did not agree with what was suggested by UK. DE considers that the definitions in the Directive are clear. In the case of a product with a CE marking a user manual has to be set up and will be enough, but what about installers? Companies do the installation not consumers. The manufacturer should provide documentation about how Solar PV should be installed and used. Solar installation should be considered as fixed installation in line with EMCD and it should be defined which type of documentation needs to be requested. Swiss delegation considered that it is difficult to follow this approach as the installations are privately owned. Installers know how to install the Solar PV but the final product is not tested. Denmark Delegation proposes to distinguish between professional and private use. One solution might be that the solar system would be sold as a whole (one package with an installation manual), with cable, panel, and inverters. Then it can be considered that it is not a fixed installation. However, if the products come from different suppliers and the installation is done by a professional installer, then it is a fixed installation and the installer has to provide the documentation. EUANB representative considers that large part of this case will be solved soon as the installation will be soon with wireless remote control so it will fall under RED which does not distinguish between fixed or not installation. Then the case will be solved. UK will bring this issue to ADCO again. Chairman concludes that the issue will be also addressed within the preparation of the new guide and will be re-discussed in the EMC WP. 4

5 5.9 Report by CENELEC CENELEC representative presented an update report of the work in document EMC(22)46 completed by a report of the Chairman of CLC/TC210 and the document EMC(22)47 on 80/80 rules. Concerning the paper of CENELEC on 80/80 rules, the representatives of CENELEC considered that the statements in the standards are not regulatory statements. Swiss delegation considered that it is clear that all products put on the market have to be in conformity with the essential requirements. This 80/80 tool appears as a rule in the harmonised standards. It is a tool for manufacturers and it should be highlighted as a tool. CENELEC explained that the idea is to explain this 80/80 rule in the EMC Guide, and would like to ask the approval of this rule. German delegation representative proposed to forward this issue to EMC ADCO and discuss it with Market Surveillance Authorities. NL delegation considered that all products must meet the essential requirements, indicating that the 80/80 rule allows MSA to make a judgment on production series but prefer a proper analysis and to be able to act in a harmonised manner in terms of market surveillance. Swiss delegation indicated that they agree to keep this 80/80 tool in the standard but it should be precisely specified that this can only be a verification tool for industry. It cannot be a mandatory tool for MSA. Moreover the formulation can create confusion for the manufacturers. They may understand that they are allowed to have some products non-compliant. CENELEC specified that there are two issues that need clarification. One is about MSA and ADCO, the other is on whether 80/80 is a rule that should not be in the standards and should be removed. CENELEC would like to have a discussion about this with the Commission services. For Digital Europe saying that the rule is 80/80 is nothing else than a rule for industry and it is not a rule for MSA is dangerous as it creates a legislative uncertainty. Chairman indicates that the rules are one in the legislation. A standard cannot impose a rule on MSA. MSA should do is what is foreseen in the EMC Directive and in the Regulation about market surveillance. In fact, all the products put on the market have to meet the legal requirements. The Commission services are available for a meeting with CENELEC on this issue Report by ETSI An update report was presented by the ETSI representative, with the document EMC(22)48. Chairman explained that a document about the applicability of the three Directives (EMCD, RED and LVD) will be circulated soon. Document EMC (19)10 about the applicability of two Directive in the case of vehicles will be reviewed and it will be circulated for comments. 5

6 6. MARKET SURVEILLANCE 6.11 Report by EMC ADCO Chair (information) The EMC ADCO Chair, presented the results from last ADCO meeting in Vilnius in April 2015 (document EMC(22)40). One of the major points was the adoption of the code of practice for a joint EMC and LVD campaign on LED floodlights. Inductive and wireless chargers might be a target for a future campaign. Other main topics of the EMC ADCO meeting: Risk assessment performed by MSA, IMP (horizontal) documents, ICSMS, checklist for customs, a market surveillance horizontal guideline, cross border cooperation for non-compliant products. EMC ADCO Chair explained the value-added of the EMC quick guide and would like to present it to next EMC WP after adoption by EMC ADCO. It is foreseen that MS translate the adopted version. Chairman expressed that the EMC quick guide should be in coherence with the EMC guide. He remembered that the EMC quick guide is a document from EMC ADCO. We need to make sure that there will be no confusion about the role of both guides. 7. EUANB 7.12 EUANB Report (information) The technical secretary presented document EMC(22) NEXT MEETING Next EMC WP is planned for the 8 of December AOB Chairman indicated, as from the 1 st June 2015, the change of the name of the DG to Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs and of the Unit to Advanced Engineering and Manufacturing Systems. 6