Hello List Experts,
We have a product that operates at line frequency (50 or 60 Hz). It is a
power conditioner which includes filtering, surge suppression, and
extreme voltage shut down. It is purely analog and contains nothing more
complex than transistors.
We believe the EU EMC Directive does not apply to the product because it
does not operate any higher than 60 Hz and cannot generate EMI whether
radiated or conducted.
FromEU Directive 2014/30/EU, Article 2 (2 (d)):
2. This Directive shall not apply to:
(d) equipment the inherent nature of the physical characteristics of
which is such that:
(i) it is incapable of generating or contributing to electromagnetic
emissions which exceed a level allowing radio and telecommunication
equipment and other equipment to operate as intended; and
(ii) it operates without unacceptable degradation in the presence of the
electromagnetic disturbance normally consequent upon its intended use;
I am not aware of any EMI standards that cover this type of product,
most conducted EMI starts at 9kHz or 150 kHz, and radiated EMI typically
starts at 30 MHz.
There is an inspector in an EU country that believes the EMC Directive
does apply. Their letter makes these statements:
The EU Declaration of Conformity (DoC) is incorrect or incomplete
(Article 15; Annex IV; etc. of EU Directive 2014/30/EU).
A conformity assessment procedure seems to be incomplete (Article 14) to
demonstrate that the apparatus meets the essential requirements set out
in Article 6 and Annex I of EU Directive 2014/30/EU. EU Directive
2014/30/EU is missing.
Our DofC does not list the EMC Directive, specifically because we think
it does not apply. It also does not list any EMI/EMC standards as we
find none that apply.
Is there a Harmonized Standard that would cover this type of product for
the EMC Directive?
Is it normal to list a directive in a DofC if that directive does not
apply?
How does one convince the inspector that the directive does not apply?
Looking forward to any and all comments.
Scott
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