We don't do EMC for the sake of the CE marking

16 May 2019

We don’t do EMC for the sake of the CE marking!

Discussion:

A rather high proportion of the CE-marked products that are available on the EU’s Single Market are not compliant with all of the Directives as they should be.

This point is proven by the market surveillance reports published by the EC most years, and here are a few shocking examples:

6th EMC market surveillance campaign, on solar panel inverters, 2014, http://ec.europa.eu/DocsRoom/documents/8064/attachments/1/translations

7th EMC-ADCO market surveillance campaign, on LED floodlamps, 2017: https://ec.europa.eu/docsroom/documents/26363

8th EMC-ADCO market surveillance campaign. on inductive appliances, 2017: https://ec.europa.eu/docsroom/documents/26362

Read them and weep!

There are more of these, posted under “Documents from the AdCo Groups” at: http://ec.europa.eu/growth/single-market/goods/building-blocks/market-surveillance/organisation/administrative-cooperation-groups_en

Quite apart from the problems faced by Systems Integrators when buying non-compliant CE-marked products to build systems, and one of the reasons why the (so-called) “CE + CE = CE” approach cannot work –

– don’t these poor compliance results mean we need not bother with EMC compliance – because many other manufacturers clearly don’t?

No.

It doesn’t mean that, at all!

Manufacturing companies exist to make money.

If our products don’t pass all relevant EMC tests under the EMCD, if/when they are tested, they don’t make as much money as they could.

The test standards under the EMCD are listed at: https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/electromagnetic-compatibility_en)

They are quite likely to cause or suffer EMI in real life, leading to high Warranty Costs and dissatisfied customers who will probably go elsewhere for their future purchases.

These are costly issues, made worse by the fact that the effects of the EMI are often not recognised as being due to EMI, so warranty returns are often ‘No Fault Found’ and no-one knows how to reduce them and reduce costs.

Here is a true story that many of you will have heard me tell before:

A UK manufacturer discovered spent £100,000 on retesting and redesigning their range of products to comply with the new issues of the EMC Directive’s immunity standards around mid-2001. Their Technical Director was present throughout all the EMC retesting and complained bitterly about “Bloody Brussels Bureaucrats” who “Knew nothing about trying to make an electronics company be successful in these tough times” and “Were going to be the death of the industry” all the time, annoying the test engineers.

Much to the Director’s complete surprise, during their first year of selling their revamped designs, their warranty costs were reduced by £2.7 million! Now, a return of £2.7 million every year on an investment of a mere £100k is a truly superb financial result!

They had clearly been suffering a high level of warranty returns due to EMI, but had never identified EMI as being the problem (like I said, many such returns are ‘No Fault Found’). So who knew better how to run a modern electronics company in those tough times, eh? Turns out it was those “bloody bureaucrats in Brussels” knew a few tricks that the Technical Director did not!

The EMC test standards listed under the EMCD are not at all tough!

In fact, they are barely adequate for the modern world and always lag at least 5 years behind the real-life electromagnetic environment, which is getting worse all the time. And we generally want to design products that will sell well and continue to make good profits for a few years before we have to redesign them, by which time the test standards will be even more out of date.

If we want to sell a high-quality product with a high Gross Margin (lots of lovely profit) we would be well advised to do much tougher EMC tests than these – because people are less forgiving when expensive products cause problems or don’t work as well as they should.

Of course, there is no requirement to actually have any EMC tests done to declare compliance with the EMCD, see: www.emcstandards.co.uk/complying-with-the-eu-s-emc-directive-without.

But we do need to make sure that if our products were to be tested to the relevant EMCD standards, they would pass – and this is exactly what we are claiming when we sign an EU Declaration of EMC Conformity prior to affixing the CE marking.

Conclusions:

We need to do EMC for sound commercial/financial reasons.

Creating a Declaration of EMC Conformity for a product and affixing the CE marking to it, is a marketing requirement for the EU, but because we do EMC anyway to help make lots of money – it is merely an administrative matter.

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