The EMC Directive is one of the most widely reaching new-approach
directives enacted by the European Union (EU). As the dust settles a year after its full implementation, several questions arise:
How did U.S. manufacturers fare?
What types of problems arose during the implementation?
How did the directive change or affect test labs?
What is in store for this year?
After a hectic two years, a near steady state has been reached. The supply-and-demand conflicts created by the deadline have started to balance. The competition for test time and test equipment, and the quest for qualified personnel and EMC parts are becoming more manageable. A year ago, every EMC lab around the world was sitting in the catbird seat. Soon, the competition for lab customers will start to heat up.
Lessons Learned
To fulfill the requirements of the directive, it is necessary to bombard equipment with various radio-frequency, pulse and transient stimuli. Surge suppression and increased attention to filtering are necessary to pass a number of these tests. For the preponderance of manufacturers, this was the first time equipment immunity needed to be considered. Whole industries, such as instrumentation, industrial-control and appliance manufacturers, had to learn EMC from the beginning.
On the whole, U.S. manufacturers braved the changes well. The false-start deadline of 1992 prepared many companies for the inevitable. Coupled with information from private and public sources, many companies were well prepared and had well-thought-out certification plans and contingencies.
On the flip side, other manufacturers called the local EMC laboratory Dec. 1, 1995, to schedule test time, only to find February (or later) promise dates common. And there was some unwelcomed news: Most of the products that needed to be certified included existing designs and changes necessary to pass one or more of the tests.
Many companies that provided commercial and consumer products to the marketplace had experience with FCC compliance. They managed to dovetail the CE Marking process into their product-certification mechanism.
For other industries, it was their introduction to EMC. Many of them were—and still are—exempt from the FCC emissions requirements.
Several industries, in particular medical devices, some telecommunications products, test equipment and industrial equipment, have enjoyed a pass from the FCC’s unintentional emissions requirements. The EMC Directive, however, claims dominion over all electrical apparatus, which means that nearly every active electrical or electronic device must conform to the requirements.
To be sure, the companies that endured the end-of-year rush have made EMC part of their permanent lexicon. The end of 1996 found next-generation products making their way through the certification process with increased awareness of the things that make EMC achievable: good grounding, bonding, shielding, clock termination, proper waveshaping and signal routing, filtering, bypassing and decoupling.
With the Jan. 1, 1997, deadline of the Low-Voltage Directive (LVD), the stage has been set for additional certification requirements. At least the routine is somewhat familiar.
The hardest-hit EMC test-lab clients were those that waited until the last minute to book test time. In many cases, the price reflected the age-old axiom regarding supply and demand. Test labs reacted by hiring more workers, consultants and contractors; adding shifts and working long hours.
The Impact on Test Labs
The business opportunities brought about by the European Directives have created an entire work force and established many strategic allies, business partnerships, buyouts and sellouts. Newly minted EMC engineers and technicians ply their trade at recently opened facilities and existing facilities are upgrading their equipment out of necessity.
The early to mid-1990s were characterized by acquisitions of U.S. test labs by Europeans. Test lab and business interests in Germany and the United Kingdom have been extremely active in their pursuit of U.S. test labs, forming partnerships among the various national and private certification bodies.
Other laboratories and certification bodies in North America have increased their size and clout, trying to gain market share and skirting their not-for-profit status. A recent sell-off of a $600 million testing division by a large multinational trading firm underscores what may be the beginning of a shakeout in the EMC business.
The prices for certification testing are being driven by many factors. For example, immunity testing is a requirement of the directive, and test labs must continually upgrade their capital equipment pool in response to changing and evolving specifications. Adding the radiated immunity test capability, for example, could cost at least $200,000 for a modest chamber plus the equipment to produce, monitor and control reasonable field strengths.
As lead times shrink and lab competition heats up, test prices should stabilize and start to fall. An analogous situation occurred around 1990 when the number of FCC test labs grew. During that time, the FCC was in a full- enforcement mode, which drove many PC manufacturers to the laboratories. As the FCC eased its enforcement and additional test labs came on the scene, the prices for FCC testing relaxed.
This type of scenario is bound to happen—eventually. The two factors that could prolong the brisk pace of the testing and certification business are the continually evolving test standards, such as product-specific standards or changing requirements, and the development of new directives.
In short, as long as the concept and reality of the EU continue intact, business should remain good for certification, testing and engineering bodies.
Global Harmonization?
Australia, New Zealand, Taiwan, Korea, China and others in the Pacific Rim are on the growing list of countries adopting versions of the EU EMC requirements. The predominant requirements in the Pacific Rim are standards and test specifications based on the International Special Committee on Radio Interference (CISPR) requirements for emissions.
Product safety, along with EMC, is a concern in many of these countries. As the global requirements become more harmonized, the individual requirements converge into a common set, based mainly on International Electrotechnical Commission (IEC) 950 and its “cousins.”
Although the technical provisions are similar, each country invokes their sovereign right to some national twist. Some require testing be performed at an accredited (read: in-country) test lab. Some countries require an agent to be located in the country of approval. Others say the test report must be written in the native language.
Japan has had voluntary EMC emissions limits under the auspices of the Voluntary Control Council on Interference (VCCI) since the late 1980s. Although there are no regulatory requirements for compliance with the limits (based on CISPR 22), the company claiming conformance with the requirements must be a VCCI member (admission fee—$3,000). The submission of conformance reports is a fairly straightforward and abbreviated affair when compared to the FCC’s reporting requirements. Results, however, must be obtained at a VCCI-accredited laboratory.
Closer to home, with the ongoing adoption of provisions to ensure compliance with the North American Free Trade Agreement, Mexican product-safety compliance is occurring more often. Again, the technical standards are similar to the UL/IEC requirements; however, the approval process may require a torturous trip through a Mexican accredited laboratory.
So even as technical harmonization improves, the administrative requirements may not get easier. In fact, as countries enact specific regulations, the burden on the manufacturer increases as the compliance issues become another important requirement to satisfy. Still other countries use the EU model and the concept of the Declaration of Conformity, in some form that allows the manufacturer to self-declare.
For some exporters, the stickiest problems are getting compliance with National Approvals for radio, telecommunications and, in some cases, medical products. For the radio and telecommunications equipment, Byzantine-type approval requirements in various countries mean that individual approvals must still be sought from the National Approval Authority or some designated in-country laboratory.
Hopefully, these requirements will begin to erode over the next few years as mutual recognition agreements (MRAs) are put in place and harmonized international standards continue to crystallize. For example, progress has been made in the adoption of various European Telecommunications Standards Institute requirements for radio equipment and Common Technical Requirements for telecommunications equipment. These standards form the basis for approvals in the radio frequency communications and telecommunications industries, respectively.
The U.S. Response
Meanwhile back in Washington, the rules that started much of this compliance business have been altered—and not insignificantly. FCC Rule Part 15 governing unintentional radiators, low-powered transmitters and the like was amended to eliminate the certification requirement for personal computers and peripherals. Under the new requirements, the issuance of a Declaration of Conformity by the manufacturer satisfies the emissions requirements. The hitch—testing must be performed at an accredited laboratory.
At the time of this writing, two such schemes satisfy the FCC’s requirements for accrediting independent laboratories: National Voluntary Laboratory Accreditation Program, administered by the National Institute of Standards and Technology, and American Association of Laboratory Accreditors.
The acceptance of accreditation schemes from other countries by the FCC may be contingent on their willingness to negotiate on MRAs. Certainly, some leverage is available and it should be incumbent on all parties to simplify the accreditation schemes and promote trade free of technical barriers. However, the FCC still does not discriminate against laboratories outside the United States.
Besides test laboratories, consultants and product standards committee members, another very active segment of the compliance market is accreditors. Investigation, registration, accreditation and certification to ISO 9000 and its various derivative quality standards are part of doing business in the 1990s.
Some organizations have four or five accreditations to various certifying and noncertifying bodies. An immediate spin-off of a worldwide acceptance scheme would reduce these various accreditations and the attendant yearly inspections, audits, fees and internal overhead.
More Directives and Standards
What’s next? How about the LVD, the Medical Device Directive (MDD), the Satellite Earth Station Directive or the Vehicle Security Directive?
The LVD, mandatory on Jan. 1, 1997, is potentially as far-reaching as the EMC Directive. The MDD, effective in mid-1998, will affect traditional medical diagnostic equipment as well as other treatment and health-care-related products.
The enforcement date of the satellite directive is still an open question. Standards are emerging that cover this type of equipment and the end of the transition period will no doubt come. As for the Vehicle Security Directive, all new products on the market Jan. 1, 1997, must conform with this directive.
The turmoil has still not abated. But the progress and lessons learned during the recent past should make continued compliance with existing requirements and the adoption of new requirements easier.
About the Author
Mike Violette, president of Washington Laboratories, has been active in the field of EMC engineering since 1984. After graduating from Virginia Tech with a B.S.E.E. degree, he joined Violette Engineering as a project engineer. There he worked on a variety of EMC-related projects, including the lightning protection system for the Statue of Liberty. Violette, a NARTE-certified EMC engineer, is chairman of the Washington D.C./Northern Virginia Chapter of the IEEE EMC Society. Washington Laboratories, 7560 Lindbergh Dr., Gaithersburg, MD 20879, (301) 417-0220.
Copyright 1997 Nelson Publishing Inc.
January 1997