The EMC Directive and “Fixed Installations”

A common discussion point with manufacturers is the notion of the “fixed installation”. Probably mostly due to recital (36) in the beginning of the EMC Directive 2014/30/EU:

2014.30.eu.recital36

Fixed installations are clearly defined in Article 3 (1.) (3.) of the EMC Directive 2014/30/EU:

2014.30.eu.article.3.1.3

Article 19 of 2014/30/EU specifies what is and is not required for EMC compliance for fixed installations. Mainly we see that Annex I (1.) General requirements are not applicable and that the requirements from Annex I (2.) are, and they are much more lax: “good engineering practices”. This is in stark contrast to the requirements in Annex I (1.). Of course it would be easier to comply with Annex I (2.) instead of Annex I (1.).

That “easier” compliance method coupled with the definition of a fixed installation listed in Article 3 (1.) (3.) leads some to believe that their industrial machine can benefit from the fixed installation “good engineering” practices. Unfortunately, it can’t.

One would think that a big, industrial machine which ships in pieces and is installed by professionals, and bolted to the floor is, “fixed,” but that is not what it means. To understand what is, we look to the guidance documents published by the European Commission in support of the law.

This guidance document references the now-expired EMC Directive 2004/108/EC: as of today there is no official guidance document for 2014/30/EU.

See the examples given for what a fixed installation is, insofar as the EMC Directive is concerned, in section 1.3 (1.3.1) (para 5) of the EMC guidance document:

emcguidelines.section1.3.para5

This suggests that a fixed installation is not only “fixed” but also, very large. As a result, industrial machines which are bolted to the floor are not considered “fixed installations” in the EMC Directive and do not benefit from the exclusion. Entire structures are considered as “fixed installations” but the equipment installed in it is not. This makes sense when you consider that it would be very difficult to proclaim an entire facility as compliant to the EMC Directive 2014/30/EU because testing the entire facility as one unit would be impossible. The component assemblies (i.e., the machinery and systems in it) can be tested.

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