This website uses cookies primarily for visitor analytics. Certain pages will ask you to fill in contact details to receive additional information. On these pages you have the option of having the site log your details for future visits. Indicating you want the site to remember your details will place a cookie on your device. To view our full cookie policy, please click here. You can also view it at any time by going to our Contact Us page.

Close

Understanding your EMC obligations

24 May 2023

Ian Wright offers advice to end users on what they need to know about their machinery manufacturer’s EMC obligations.

For any machine – and that includes electrical or electronic components – to comply with the UK’s Supply of Machinery (Safety) Regulations 2008 it must also meet the Electromagnetic Compatibility Regulations 2016. In the EU, the equivalent is the Machinery Directive 2006/42/EC and EMC Directive 2014/30/EU, and all the same requirements apply.

There can be no doubt about the need for 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 therefore vital that machinery end-users understand how those manufacturing and supplying their machines are required to ensure their products meet EMC requirements. Indeed, 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’. 

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 11pm 31 December 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 harmonised 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 therefore 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.

We would therefore advise that an EMC management or test plan is 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. 

Ian Wright is Chief Engineer at TÜV SÜD.


Contact Details and Archive...

Print this page | E-mail this page