EC regulation and CE marking – a brief guide
The subject of CE marking has been fraught with partial understanding and confusion. We felt a brief outline of what is a complicated political, legal, commercial and technical subject might help clarify matters for our customers.
Before 1985, many countries within the EEC had a wide variety of technical standards and enforcement policies affecting the products sold in those nations. This meant that products made in one country might not have been considered safe or legal to be sold in another. As part of the single European act, the member states began to adopt a range of ‘New Approach’ directives designed to remove these technical barriers to free trade and to promote a unified consumer protection and safety policy throughout the single market. These directives have gradually replaced the differing national regulations with common rules and lay down the essential requirements for protection. Most countries in the EEA/EFTA outside the EU also have similar regulations.
There are three directives of most concern to the professional audio/video industry:
Low Voltage Directive. The LVD deals with the potential safety hazards of electrical equipment such as mechanical, fire, and of course, electric shock. It applies to all equipment which uses voltages of between 50-1000 VAC or 75-1500 VDC. The essential requirement of the LVD is that the equipment must be safe in normal use, ie: when properly installed and maintained and used in the application for which it was intended.
Electromagnetic Compatibility (EMC) Directive. The essential requirements are that a product in normal use must be constructed so that it:
- does not generate electrical or radio (electromagnetic) interference above a level which prevents other apparatus from operating as intended (emissions)
- has an adequate level of intrinsic immunity to electromagnetic disturbance to enable it to operate as intended.
The EMC Directive applies to almost all electrical products which are liable to cause or be affected by electromagnetic interference, with the general exceptions of:
- electromagnetically benign apparatus
- spare parts
- second hand equipment
- equipment for export and use outside the EEA
- equipment specifically covered by other Directives
- excluded installations
The CE Marking Directive amended both of these directives. Taken together, they govern the conformity assessment procedures that the manufacturer, the authorised representative or the importer into the EU/EEA must comply with to affix the required CE mark to the equipment, the user documentation, or the packaging. This mark tells the consumer and the enforcement authorities that the required standards have been satisfied and declares in law that the product meets the essential protection requirements of all directives which apply to the product. Since implementation of the LV and EMC Directives, both have been subject to revision in 2006 and 2004 respectively as explained below.
Many products are not covered at all by any directive, and must not be CE marked. Mains powered equipment will usually need to comply with both the LVD and the EMC Directive. Some products, such as component power supplies for use within a piece of equipment, are covered by the LVD, but not by the EMC Directive. Other equipment, such as those powered by low voltage batteries or a DC adapter, come under EMC only, however the DC adaptor itself will be subject to the LV Directive when it is powered by a voltage between 50-1000 VAC or 75-1500 VDC.
From the date of introduction of a directive, all products within its scope must both meet the essential protection requirements of that directive and be CE marked to indicate compliance. Under the regulations, it is an offence to:
- place on the market or take into service, apparatus which is within the scope of a relevant Directive and which does not have the CE mark.
- affix the CE mark to products which do not comply with the essential requirements of all relevant Directives in force.
- to affix the CE mark to products which do not fall within the scope of any Directive.
The product user documentation must identify the directives for which conformity is claimed and the CE mark applied. A Declaration of Conformity must be drawn up by the manufacturer, authorised representative or the importer into the EU/EEA, which states the recognised standards and tests which have been used in certifying compliance to the relevant directives. Strictly, this is a legal document available only to enforcement officials. In due course, for simplicity and with environmental friendliness in mind, Canford intend that the DoC will be included on the website, and be accessible via the product data to which it relates. This may assist system installers and others by listing the standards which have been applied. Most A/V equipment will currently be covered by harmonised European standards BS EN 60065 (formerly BS415) or BS EN 60950 for electrical safety. For EMC, BS EN 55103.1 (emissions) and BS EN 55103.2 (immunity) are applicable to professional audio-visual equipment, whilst BS EN 55013 (emissions) and BS EN 55020 / BS EN 50082.1 (immunity) are appropriate for consumer products. Canford intend that, wherever possible, the CE mark will be affixed to both the equipment and the user instructions or datasheet.
The EMC Directive took full effect from 1/1/96. In 2004 the original directive was repealed by directive 2004/108/EC with the following changes being implemented. Manufacturers no longer require mandatory third party involvement to assess conformity providing the requirements of the directive have been followed. More detailed information is required to be recorded in respect of product and manufacturer. Fixed installations are now included within the scope of the directive, however they have their own guidelines to conformity. It is Canford policy that all equipment covered by the scope of a directive shall comply and a rolling review seeks to ensure that compliance is maintained to current versions of the relevant standards. Canford also seeks to assist the work of industry bodies to ensure that we are involved in the process of agreeing any amendments to those standards.
The LVD has been reflected in the law of the UK and many other European countries for over fifteen years. Although products had to meet the protec¬tion requirements of the directive since implementation, certification and CE marking with respect to the LVD had been optional. As of 1/1/97, this became mandatory. The original directive has since been repealed by directive 2006/95/EC which effectively consolidated the original directive 73/23/EEC with the CE marking
Within the professional audio/video industry, standards of electrical safety have always been high. Likewise, awareness of EMC issues has been required, often demanding practical solutions to system problems. To this extent, the LVD and EMC Directives reflect what has always been best practice within the industry. Canford is committed to ensuring that all of our products will meet the requirements of the relevant European Directives; we will not supply equipment which is within the scope of a directive and which does not comply with its essential protection requirements. We have in place a continuous program of product review; and where appropriate, assessment, testing and certification, of both our own manufactured products and those of some of our hundreds of smaller and overseas suppliers. There are over 14,000 products in our catalogue in a wide range of categories; we supply passive electrical components and electronic devices as well as modules, sub assemblies and complete pieces of equipment.
Many of our products are not within the scope of any directive, however those products which do fall under the scope of a particular directive meet the essential protection requirements and are CE marked. This includes compliance with directives not mentioned above, such as the Radio and Telecommunications Terminal Equipment directive (RTTE). Canford actively monitors the development of standards, and is involved with industry bodies in their work to develop and update standards as technology moves forward.
In keeping with our policy of trying to keep our customers informed about legislation and issues that may affect our industry, the EC has published four further Directives which seek to address some of the environ¬mental issues of concern to the electronics industry, in particular by trying to encourage recycling and responsible disposal of equipment at the end of its useful life (the WEEE Directive), by restricting the use of certain chemicals in products to minimize their concentrations at disposal sites thereby avoiding, for example, pollution by leaching into surrounding areas (the RoHS Directive) and a combination of both requirements relating to batteries and accumulators (the Batteries Directive). There is also a directive aimed at encouraging energy efficiency of products through design measures (the Energy Using Products Directive). Separate notes regarding Canford's implementation strategy and information in relation to these directives can be found here: RoHS & WEEE, Batteries & Accumulators.