CE Marking

Implementing the New CE Marking EMC Requirements

Andrew Cutler and Chris Zombolas

It is essential that manufacturers assess their compliance documentation against the requirements of the new standards.

When the EMC Directive was first mandated back in 1996, the list of harmonized standards was rather short. In the early days of the EMC Directive, there were a number of emissions standards based on IEC CISPR standards. However, except for the IEC 1000 series of basic EMC standards, product-specific or product family immunity standards just did not exist.

Shielding plays an important role in EMC compliance. Shielding courtesy of Spira Manufacturing Corp. (North Hollywood, CA).

This left European manufacturers, suppliers, and the European Commission in a difficult position. With this mandate, it was very difficult for manufacturers to demonstrate that their products would meet the essential requirements of the directive when no immunity standards had been harmonized. To overcome this problem, CENELEC introduced generic emissions standards (EN 50081-1 and EN 50081-2) and immunity standards (EN 50082-1 and EN 50082-2) covering two environments: the residential, commercial, and light industry environment and the heavy industry environment.

Initially, the generic immunity standards covered only a limited number of tests (radiated immunity, electrostatic discharge, and electrical fast transient bursts), but in 1997 the range was extended to include all of the common immunity standards.

New Mandatory Generic Standards

The four generic standards have been updated and renumbered to conform to the IEC numbering system. The old versions will be removed from the list of European harmonized standards and will not be available for CE marking purposes.

The EN 50081 and EN 50082 range of standards reached their date of withdrawal in July 2004. These standards can no longer be used to presume conformity to the EMC Directive. Table I shows the new standards that must now be used.

Implications

What does it mean if you have not modified your product since it was originally tested and declared to the old EN 50081 or EN 50082 standards back in 1999?

Technically, as of July 2004, the product could no longer be sold into Europe. The presumption of conformity no longer exists. A new declaration of conformity (DoC) will be required, declaring compliance with the new standards. To continue selling the product, it would seem that the product would need to be retested to the new versions of the standards. This is one option—and it may be worth considering, especially if the product has been modified over the years but never sufficiently for a full test to be carried out.

If no changes have been made to the product, the most prudent course of action would be to compare the new standard with the old standard and carry out difference testing to cover the clauses introduced by the new standards. In many cases, extra testing will not be required, but this will depend on the specific characteristics of the product.

If no additional testing is required, then a note should be made in the compliance file. The note should indicate that the evaluation has been undertaken, that there are no differences, and that a presumption of conformity to the new standard can be made based upon the existing test report to the EN 50081 or EN 50082 versions. It will also be necessary to update the DoC, especially if the original declaration contained a reference to the old standards that were used as the basis for making the declaration.

Old Versus New Generic Standards

There are a number of important differences between the old and new versions of the standards. Many minor changes have been made, so it is imperative that manufacturers read the standards carefully to note less-obvious changes. Some changes may only become apparent for specific products. The major differences for each standard are noted below.

Generic Immunity—Residential Environment: EN 61000-6-1 versus EN 50082-1. Major changes:

• Radio-frequency electromagnetic keyed carrier tests are no longer required for the radiated immunity tests.

• The voltage dips and interrupts timing is now in units of periods rather than milliseconds.

Generic Immunity—Heavy Industry Environment: EN 61000-6-2 versus EN 50082-2. Major changes:

• The new standard has no additional testing annex tables.

• Tables 2 and 3 of EN 50082-2 have been combined into one table, which is now known simply as signal ports.

• Radio-frequency electromagnetic keyed carrier tests are no longer required.

• High-voltage surge testing is now required on signal, dc, ac, and earth ports where applicable.

• Electrical fast transient bursts (EFT/B) testing on signal ports has been standardized at ±1 kV.

• EFT/B testing on ac and earth ports is now required where applicable.

• Voltage dips and interrupts testing is now required on ac ports.

Generic Emissions—Residential Environment: EN 61000-6-3 versus EN 50081-1. Major changes:

• The new standard has no additional testing annex tables.

• Flicker and harmonics testing is now carried out according to the EN 61000-3-2 and EN 61000-3-3 range of standards.

• Conducted-emissions testing on signal, control, and dc power ports is now required.

Generic Emissions—Heavy Industry Environment: EN 61000-6-4 versus EN 50081-2. There are no significant differences between the new and old standards.

Conclusion

Three of the four generic standards have changes that could significantly affect the continued CE compliance of products being sold in Europe. The changes have been in effect since July 2004, so manufacturers should have checked the compliance of their products, including those products already on the market. Many of the changes are not merely editorial, and in some cases, changes may involve retesting so that the presumption of conformity is maintained.

The most important changes have been made to EN 50081-1 (replaced by EN 61000-6-3) with the introduction of conducted-emissions limits for external dc power ports and for signal ports. The limits and method described introduce new test methods and procedures.

Important changes have also been made to EN 50082-2 (replaced by EN 61000-6-2) where surge, EFT/B, and voltage dips and interrupts testing have been introduced to ports that did not previously require testing.

Clearly, doing nothing exposes manufacturers to the risk of noncompliance and possible regulatory breaches. It is essential that manufacturers review the existing test reports and compliance documentation and assess them against the requirements of the new standards. If necessary, difference testing should be performed and a new updated DoC must be issued.

Andrew Cutler is general manager of EMC Technologies NZ Ltd. (Auckland, New Zealand). He can be reached at aucklab@ihug.co.nz. Chris Zombolas is technical director of the EMC Technologies group and is based in Melbourne, Australia. He can be reached at chris@emctech.com.au.