Electromagnetic Compatibility – Do End-Users need to comply with the regulations?
You only need to consider UKCA/CE marking to the Electromagnetic Compatibility (EMC) Product Regulations when acting as a ‘manufacturer’.
When you are purchasing completed products from third parties, they are the party that needs to ensure compliance with marking to the EMC Product Regulations.
These regulations can be complied with either by a route of self-certification or by employing a UK Approved Body to undertake a formal assessment.
The choice is that of the ‘manufacturer’. There is no regulatory requirement to use an Approved Body.
If self-certification is decided on, the ‘manufacturer’ can still employ the services of a third party (but not one acting as an Approved Body) to assist, review or test the product.
EMC testing is the most usual sourced out activity for these regulations either when self-certification or when there is Approved Body involvement.
EMC testing is not a legal necessity but does have the advantage of being less complex and ‘more straightforward’. There would be more than one test, at least two (one for immunity and one for radiated emission) but frequently others as well, especially for emissions related to the power supply. Note, that many products fail an EMC test the first time around unless the designer is very experienced in EMC issues.
For self-certification and when if testing is not done other options exist. These relate to an understanding of the EM environment and a formalised build specification employing very good EMC build practices. Some manufacturers prefer to develop their own build specifications using techniques that are known to ensure compliance.
For some products that only ever get used in one known location an approach based on defining the product as ‘apparatus intended for use in a fixed installation’ is sometimes used. In these instances, the product is not UKCA or CE marked to the EMC Regulations and specific warnings and statements are made in the instructions.
Most often manufacturers are taken to task for non-compliance when there is a complaint by an end user, a member of the public or another party experiencing interference. On large sites, ones their own high voltage supply, it is probably only the end user that would experience interference. If the end user is also the ‘manufacturer’, it is unlikely that they would make a complaint about themselves!
For end users that manufacture products for their own use, good EMC practices in the build and the use of suitable components would most likely suffice with the use of UK Approved Bodies or even third-party test houses being probably more onerous than actually needed. Having a good EMC build specification, knowledge of good practices and how EMI results would be however very useful.
End-user sites do still, however, need to meet the essential requirements of the EMC Regulations and are generally defined as ‘fixed installations’. ‘Fixed installations’ still have requirements but are not UKCA/CE marked. The requirements are there to ensure the installation does not interfere with others. Operators of such sites should take into account good EM engineering practices, ensure third-party products are EMC compliant and follow the information provided by these providers in order to comply with these Essential Requirements. End users should note that EMI issues increase every time a new plant or product is added, even if that plant or product is itself compliant. EMI compounds and ‘its’ summation increase with each additional item.
If you ever need assistance on UKCA marking, please do not hesitate to give Finch Consulting a call on 01530 412777, or email us at [email protected].
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