The directives EMCD and RED are administered by the EU commission, and the supporting standards are handled by the technical commitee TC210. Together with a specialist in the field, the committee maintains a list of the standards that can be used to declare conformity with the directives. This work is ongoing.

The Radio Equipment Directive (RED) has now been fully in force since 13 June 2017. The EMC Directive was introduced just a year earlier. The texts of the directives operate in conjunction with a website, so that the technical requirements can be maintained gradually without having to rewrite the directives text on a regular basis.

Regular updates to the list of harmonised standards

A committee under CENELEC has the task of ensuring the technical basis of the directives is solid. As the directive text itself does not contain a lot of technically detailed content, the technical content can be found online instead on a website, where the EU Commission maintains a summary of the standards that can be used as the basis for certification. The list is generally referred to as the ‘Official Journal’ (or OJ), although there are lists for each of the CE marking-based directives. The website has enabled the EU Commission to gradually update the technical basis by simply publishing new, updated standards as soon as they are accepted by TC210.  Once a standard has been published on the list, it has been ‘harmonised’ in relation to the directives.

TC210 comprises as number of EMC and radio specialists from EU countries. They take part in the work via each country’s national membership of the EU organisation CENELEC. Denmark takes part through Danish Standards, where the S710 committee follows the developments in European standardisation. The committee holds two meetings a year, usually at CENELEC’s head office in Brussels. Conclusions and results from the committee’s work are reported to the EU Commission. It is the commission, and not the committee alone, that decides what will happen based upon the committee’s input.

EMC consultant is the ‘highest ranking body’

The EU Commission’s officials do not necessarily possess the detailed technical expertise in the areas of EMC and radio equipment. The commission has therefore an EMC consultant, who takes part in the work involving standards. This position is currently occupied by the consultant Ronald Storrs. He has a background in the administration of the Swedish telephone authority’s EMC/radio requirements and is an active member in the ERM EMC group of the radio standardisation organisation ETSI.

The EMC consultant is the ‘highest ranking body’ in disputes over compliance with EMC requirements. In reality, he is also the highest ranking body on radio requirements, as there is no appointed RED consultant in the EU. In principle, the EMC consultant also has the last word when it comes to approval of new EMC and radio standards, before these are placed on the OJ list of harmonised standards.

Huge challenge regarding RED

The consultant’s role and the specialist position as backstop has been relevant in connection with the introduction of the EMC and RED directives. A new list of harmonised standards adapted to the new directives has been established for both directives. Although there is not a huge difference technically between the old and new directives, much of the wording has been changed, and manufacturers must under all circumstances indicate the correct standards and directives on their declaration of conformity for the products.

For the RED directive in particular, using and indicating the correct standards has proved to be a huge challenge. As the directive could still be used in 2016, OJ was not updated with the new RED standards, and only the old list from the R&TTE directive was published. Luckily, the RED directive permitted a one-year overlap period, so that certification could continue in accordance with R&TTE for a further year. However, this possibility expired on 13 June 2017.

The latest count of standards now shows 206 documents on the EMC directive list and 143 documents on the RED list in OJ. Many standards are still missing from the lists, especially for RED, and new documents are being added daily. Manufacturers must constantly keep themselves up-to-date with the arrival of new product standards, as new standards must be used and included in the manufacturer’s documentation as per the date indicated in OJ.

Work with product standards continues

TC210 has established a working group (WG14), which has the mandate of determining detailed requirements for how future product standards can best be adapted to include the need for harmonisation. This work will continue when the committee reconvenes in December 2017.

Furthermore, the issue of missing standards will no doubt dominate the agenda again. When a harmonised standard is missing for a product, the industry’s only option for being able to certify conformity with the EMC and RED directives is to use a Notified Body (NB). In Denmark, FORCE Technology is a Notified Body for the RED and EMC directives.

More info

For more information about the committee’s work on the EMC and radio directives, contact Senior Technology Specialist Per Thåstrup Jensen, tel. +45 43 25 13 62.