From 2014 until November 2022, there were no EMC standards for radio equipment (EN 301-489-X) listed in the EU Official Journal. In November 2022, the first three standards of the 301 489 series were already listed with restrictions. Some have been added this year. That’s why many people were delighted with this year’s listings. But if you take a closer look, none of the listed standards provide a presumption of conformity.
I will try to explain the EU Commission's reasoning using the following standard, which was the last to be listed.
EN 301 489-28 V2.1.1
ElectroMagnetic Compatibility (EMC) standard for radio equipment and services; Part 28:
Specific conditions for wireless digital video links;
Harmonized Standard for ElectroMagnetic Compatibility
Notice 1: This harmonised standard does not address emission requirements in frequency bands below 9 kHz
and does not therefore confer a presumption of conformity as regards this parameter in this band.
Notice 2: This harmonised standard does not confer a presumption of conformity to the essential requirement
set out in Article 3(1), point (b), of Directive 2014/53/EU, if its clause 6 is applied.'
Link to the free download of the standard → ETSI EN 301 489-28
This harmless-looking "Notice" prevents the presumption of conformity.
To Notice 1:
Interference emission
The RED no longer has a lower frequency limit (previously the R&TTE applied to frequencies above 9 kHz). The Commission has been waiting since 2014 for measurement methods and limit values to be defined for frequencies below 9 kHz. This has not yet been sufficiently successful and EMC standards therefore often do not reference the frequency range below 9 kHz.
Proposed solution for manufacturers:
Provide technical justification in the risk assessment that no such interference emissions can emanate from the product.
The function, the size of the device and the definition of connected cables (cable length)
should in most cases mean that this gap can be closed even without measurements.
This exception (Notice 1) will, if not already done, become part of the listing of all EN 301 489-X series standards.
Notice 2: Section 6 of the standard.
This is where it gets more difficult. If section 6 of the corresponding EN 301 489-X is applied, we do not receive the presumption of conformity for this part. The initial impulse to „just leave that section out” is unfortunately not effective. In the EU, products must meet requirements for emitted interference and immunity. Section 6 of the EN 301 489 series of standards describes the "Performance criteria" (evaluation criteria) that are used to evaluate products when carrying out immunity measurements. The Commission considers the criteria to be insufficiently clear because, in its view, they allow manufacturers too much leeway, even though ETSI has already made many improvements.
A few other product standards in this series refer to the corresponding section 6 (Performance Criteria) of EN 301 489-1 (Generic Radio EMC Standard) for some test cases, which of course cannot be specific because it does not know the functional details precisely enough. The wording "as intended" is too unspecific. Who decides what is “as intended”?
It remains simple if no functional losses are detected during the immunity tests. The assessment of functional losses should be carried out by the manufacturer or, better still, should be derived from the operating instructions.
Conflicts often arise with test laboratories. The test customer expects the laboratory to make specifications. If there is no limit value guideline, this is very difficult for the laboratory, especially as it cannot recognize every application. Therefore, the description “as intended” generally remains with the manufacturer, which, according to the EU Commission, is not permitted to specify this. The manufacturer must therefore again work on a good risk assessment so that the topic is well covered.
The issue will therefore continue to haunt us for a while until the relevant assessment criteria are written down in the standards in such a way that they are clear and accepted by the EU Commission and its consultants.
Spoiler: The EU Commission wants to list a few more radio standards in the OJEU this year. We are waiting for the publication.
We will keep you up to date and will be happy to provide you with further details.
Author's note
This article has been machine translated into English.
TERMS AND ABBREVIATIONS
OJEU: Official Journal of the EU
RED: Radio Equipment Directive
ETSI: European Telecommunications Standards Institute.
One of the three EU Standards Organizations (ESO)
Standards: Standards
