EMCD (Electromagnetic Compatibility Directive)
The purpose of electromagnetic compatibility (EMC) is to keep all the side effects of electronic devices interfering with each other when within close proximity under reasonable control.
Last updated
The purpose of electromagnetic compatibility (EMC) is to keep all the side effects of electronic devices interfering with each other when within close proximity under reasonable control.
Last updated
The electromagnetic compatibility (EMC) Directive 2014/30/EU ensures that electrical and electronic equipment does not generate, or is not affected by, electromagnetic disturbance.
The EMC directive limits electromagnetic emissions from equipment in order to ensure that, when used as intended, such equipment does not disturb radio and telecommunication, as well as other equipment.
The following document is a good guide on ensuring electromagnetic compatibility of our equipment, and is also the main document on which this report is based:
In order to achieve an acceptable electromagnetic environment whilst ensuring that equipment will function as intended in that environment, a harmonised and acceptable level of protection is required by the Directive, based on Article 114 of the TFEU, leading to full harmonisation in the Union.
The following chart is helpful for deciding if the equipment is excluded from the EMCD.
Inherently benign equipment is defined as such:
Equipment is considered inherently benign in terms of electromagnetic compatibility if its inherent physical characteristics are such that it:
is incapable of generating or contributing to electromagnetic emissions which exceed a level allowing radio and telecommunications equipment and other equipment to operate as intended; and,
will operate without unacceptable degradation in the presence of the electromagnetic disturbance normally present in its intended environment.
Both conditions need to be met in order to classify equipment as inherently benign.
So, to be excluded from EMCD, we need to make sure our G'petto cannot disturb radio and telecommunications equipment and it can operate in shopping malls.
If the EMC assessment establishes that the apparatus concerned is inherently benign in terms of electromagnetic compatibility (both for emission and immunity) according to Article 2.2.d, the EMCD shall not apply. However, it is recommended to document the results of the assessment and its conclusion.
A product is considered "placed on the market" when it is made available for the first time on the Union market. Placing on the market refers to each individual product, not to a type of product, and whether it was manufactured as an individual unit or in series.
Note that when the terms “European Union”, “Union”, “territory” or 'Member States' are used in the EMC guide, they apply to the EEA-EFTA States (Liechtenstein, Iceland, and Norway) and Turkey.
According to Chapter 2.3 "Placing on the market" of the Blue Guide, placing on the market is considered not to take place where a product is displayed or operated under controlled conditions at trade fairs, exhibitions or demonstrations.
Displaying or operating an equipment at trade fairs, exhibitions, or demonstrations does not mean that product is placed on the market.
When using the equipment in the above environments, a sign should be displayed. The sign must indicate that such equipment may not be made available on the market and/or put into service until it has been brought into conformity with EMCD. Also, demonstration can only take place if adequate measures have been taken to avoid electromagnetic disturbances.
The EMCD defines equipment as any apparatus or fixed installation.
The EMCD25 defines "apparatus" as any finished appliance, or combination thereof made available (i.e. making available) on the market as a single functional unit*, intended for the end-user, and liable to generate electromagnetic disturbance, or the performance of which is liable to be affected by such a disturbance.
Functional unit: An entity of hardware or software, or both together, capable of accomplishing a specified purpose. For EMC purposes this can only be hardware or combination of hardware & software
G'petto is a combination of finished appliances to be made available on the market as a single combination of hardware and software. So, it is classified as an apparatus.
According to Article 3(2) of the Directive "components” or “sub-assemblies” intended for incorporation into an apparatus by the end-user and "mobile installations" are also deemed to be apparatus.
End user: Any natural person (e.g. consumer) or legal entity (e.g. enterprise) using or intending to use the apparatus for its intended purpose.
In our case, "OXXO" is an example of an end user.
Combining two or more CE marked finished appliances does not automatically produce a “compliant” system e.g.: a combination of CE marked Programmable Logic Controllers and motor drives may fail to meet the essential requirements.
According to the directive, G'petto is not classified as a fixed installation since it is not intended to be permanently installed into any environment. Either way, the essential requirements are the same for both categories except some special ones for the fixed installations.
Equipment shall be so designed and manufactured, having regard to the state of the art, as to ensure that:
These standards are there to make sure the apparatus is compliant with the essential requirements. Authorities usually use these to determine whether a product meets the essential requirements.
List of harmonised standards can be found in the following document:
The manufacturer shall establish the technical documentation. The documentation shall make it possible to assess the apparatus conformity to the relevant requirements, and shall include an adequate analysis and assessment of the risk(s).
The technical documentation shall specify the applicable requirements and cover, as far as relevant for the assessment, the design, manufacture and operation of the apparatus. The technical documentation shall, wherever applicable, contain at least the following elements:
We need to prepare a technical documentation complying with the above criteria and have it within reach of any legal authority that requests it in the next 10 years.
Technical documentation shall be prepared by the manufacturer to demonstrate evidence of compliance with the essential requirements. This includes evidence that the apparatus complies with the relevant harmonised standards or, if harmonised standards are not used or only used in part, a detailed technical justification including a list of other relevant technical specifications applied.
(a)
the electromagnetic disturbance generated does not exceed the level above which radio and telecommunications equipment or other equipment cannot operate as intended;
(b)
it has a level of immunity to the electromagnetic disturbance to be expected in its intended use which allows it to operate without unacceptable degradation of its intended use.
(a) a general description of the apparatus;
(b)
conceptual design and manufacturing drawings and schemes of components, sub-assemblies, circuits, etc.;
(c)
descriptions and explanations necessary for the understanding of those drawings and schemes and the operation of the apparatus;
(d)
a list of the harmonised standards applied in full or in part the references of which have been published in the Official Journal of the European Union and, where those harmonised standards have not been applied, descriptions of the solutions adopted to meet the essential requirements of this Directive, including a list of other relevant technical specifications applied. In the event of partly applied harmonised standards, the technical documentation shall specify the parts which have been applied;
(e)
results of design calculations made, examinations carried out, etc.;
(f)
test reports.
CE Marking
The manufacturer shall affix the CE marking to each individual apparatus that satisfies the applicable requirements of this Directive.
The manufacturer shall draw up a written EU declaration of conformity for an apparatus model and keep it together with the technical documentation at the disposal of the national authorities for 10 years after the apparatus has been placed on the market. The EU declaration of conformity shall identify the apparatus for which it has been drawn up.
