F2 Tech Notes

Most of our customers must comply with the EMC Directive 2014/30/EU prior to application of a CE marking to their products. This is because the EMC Directive is applicable to almost everything with active electronics. Unlike North American EMC compliance (FCC and ICES) which requires emissions compliance only, EU compliance to the EMC Directive requires emissions and immunity testing.

Proving this in most cases means testing to one or a pair of harmonized EN standards for EMC. These harmonized standards indicate the required tests – which are usually contained in other standards we call “test standards”. The most frequently used EMC test standards are below.

• EN 61000-4-2 – ESD Immunity
• EN 610004-3 – Radiated Immunity
• EN 61000-4-4 – EFT Immunity
• EN 61000-4-5 – Surge Immunity
• EN 61000-4-6 – Conducted Immunity
• EN 61000-4-8 – Magnetic Fields Immunity
• EN 61000-4-11 – Voltage Dips/Interrupts
• EN 55011 – Radiated and Conducted Emissions
• EN 61000-3-2 – Harmonic Current Emissions
• EN 61000-3-3 Flicker/Voltage Fluctuations Emissions

Now we come to the purpose of this article: power supplies and the problems that can be created for your compliance project if you select one that is not suitably approved. We frequently see documentation for power supplies that does not prove compliance. These power supplies can be the source of EMC testing failures in our chamber because power supplies can cause emission issues. And non-compliant power supplies cause more issues than compliant power supplies.

The documentation for a power supply may look, on its face, like the product is compliant but a little investigative work often shows that it is not. Keep in mind that anyone can place a CE marking on a product. Actually complying with the requirements is different. Because of this we suggest asking for the test report or reports from the manufacturer.

We have seen many reports that were generated by a manufacturer internally. In the world of compliance these are not valid. Why? To be an actual test report the testing lab must have laboratory accreditation and the gear used to test the products must be continually calibrated. That gear and the calibration dates must be listed in the report. The testing standard must also be listed in the report.

Our sales department can discuss these issues with you. In fact, our salespeople look at these documents so frequently that we can often immediately tell you if a test report or declaration of conformity appears valid.

I hope this helps. Please contact us today with any questions or to discuss your project.

877-405-1580

Yes, for now. Notice that CE marking will be accepted until at least the end of 2020 and then the UKCA mark will be the replacement mark for products sent to the UK. The link to the UK page regarding this new information is here.

We can be contacted via this link. We can be reached by phone at
877-405-1580 and are here to help you.

F2 Labs is here to help.

In the interest of full disclosure, I own a Fender American Professional Telecaster, in butterscotch blonde of course, and a Fender Custom ’57 Champ Amp. I love Fender products. If it says “Fender” on it… I am usually considering the need to buy that product!

However, I found it very notable that the company has been fined in the UK for price fixing. This does not involve any sort of engineering compliance issue, but it does show the international reach of market surveillance authorities. These UK authorities determined that Fender employees intentionally did not write things down about this. Presumably (my assumption) is that these employees were concerned about subpoenas for emails.

The CMA (Competition for markets authority) uncovered this during the investigation. I find this worthy of posting to our blog because it is just as important – or maybe more important – to make sure your CE marking compliance issues are taken care of, correctly.

We are separated from the EU by an ocean but it is our continuing responsibility to ensure products placed on the market in the EU are compliant and safe.

We can be contacted via this link. We can be reached by phone at
877-405-1580 and are here to help you.

F2 Labs is here to help.

Complying with any EU CE marking Directive will require a trip to one of many European Commission websites that are set up to assist with the process. They are great sources of information, I have them bookmarked, and one or more are open on my computer usually during the day.

The Machinery Directive 2006/42/EC site is here: https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/machinery/

Clicking that link will take you to a lot of good information. I have been asked a few times in the past two weeks about this so now is the time to lay it out in a (hopefully) useful F2 Tech Notes blog article.

The first thing you will see on that page is this chart:

There are two very important links in that chart. The innocuous label “OL No L 157, 9 June 2006” is a link to the Machinery Directive 2006/42/EC. Open that link and you will see the text of the Directive but also this:

English is my first language, so I scroll over to the “EN” and then click the pdf symbol below it. That opens a pdf version of the Machinery Directive in English, here. It opens as displayed below.

Are you new to CE marking and the Machinery Directive? I tell every F2 Labs customer the following, “Skip the recitals and go straight to Article 1. It’s all in plain English.” See below.

Next, go to Article 2 to see that everything in Article 1 has an easy-to-read definition.

The second very useful item in the chart from the top of this article is this:

I highly suggest clicking the link for the Guide to application of the Machinery Directive 2006/42/EC and saving it somewhere that is easy to get to. Because if you make machinery and you export to the EU you may learn that it is an invaluable tool that can be constantly referenced and learned from.

Next (and last) on the overall Machinery Directive page are the links to the Official Journal of the EU lists of harmonized EN standards. These are very important because only harmonized standards offer the presumption of conformity for your machinery.

Side note: What does this mean? It means that if you are complying with the Machinery Directive and you use the appropriate and applicable harmonized EN standards (harmonized means the standard is officially “linked” to the corresponding Directive) to evaluate and test – and it passes – then your equipment has the presumption of conformity. The authorities or anyone else looking at the equipment should assume it complies with the reference legislation when reviewing your EU declaration of conformity if you used harmonized EN standards.

Now, we turn our attention back to the Machinery Directive page we began this article with. Please, see three long links:

Those links are all important but they are all different. Choose wisely!

The first, for (EU) 2019/863, lists a number of standards that are withdrawn as harmonized standards for the Machinery Directive. The associated dates next to each standard tell you when you can no longer indicate these standards on your declaration of conformity if they are applicable to your equipment. You will have to find a different set of standards to test/evaluate. This Commission Implementing Decision was published this month (November 2019) to address some ambiguities and mistakes made in the second link ((EU) 2019/436). One notable mistake is that (EU) 2019/436 calls for the withdrawal of EN ISO 12100:2010. We wrote about that, here, because it was a major development.

Another correction to (EU) 2019/436 is that it lists standards to be withdrawn but does not indicate the date at which they (the indicated, withdrawn standards) no longer confer a presumption of conformity (i.e., the date you can no longer use them to prove compliance to the Machinery Directive).

The second, for (EU) 2019/436, lists the following:

• Annex I – applicable new or amended harmonized EN standards
• Annex II – harmonized EN standards that now have restrictions
• Annex III harmonized EN standards to be withdrawn (but no date for withdrawal, see (EU) 2019/863)

Finally, we arrive at the current “list” of harmonized EN standards for the Machinery Directive in the last link:

That link takes you to the current list that is published in the Official Journal of the EU, or “OJ” as it is often referred.

At this time, for any new projects, we suggest that (EU) all three links must be consulted if you are determining which EN standards are applicable to your equipment. Or, contact us at F2 Labs. We can help sort it out.

We can be contacted via this link. We can be reached by phone at 877-405-1580 and are here to help you.

F2 Labs is here to help.

We are starting to feel some more effects from the upcoming replacement of EN 60950-1 by EN 62368-1. This is causing some confusion in the compliance world as well and I wanted to share a recent example that we were contacted about.

The customer builds equipment that is a combination of three subassemblies that are themselves independently operational. These devices, when combined, create a new device which itself must carry a CE marking (remember, “CE + CE does not always = CE”).

This customer engaged F2 Labs after working with another lab and even had me come to his facility for a two-day training seminar this past summer.

He contacted me because the other lab refused to accept that one of the assemblies was tested to EN 60950-1. The lab indicated that the assembly must be tested to EN 62368-1 to be acceptable because EN 60950-1 is expired.

Upon reading the email from our customer I next opened the link to the Official Journal of the EU’s list of harmonized EN standards for the Low Voltage Directive 2014/35/EU, here. Next, I searched for EN 60950-1 and it appeared in the chart next to EN 62368-1. See below.

What does this mean? I have written about this topic, previously, here. There is another article on our blog that goes into this topic in much greater detail, here. EN 60950-1 is formally expiring on December 20, 2020 and at that time you will no longer be able to send equipment to Europe under EN 60950-1. You will need to submit the equipment for testing to EN 62368-1 so that you have a technical report, from an A2LA accredited lab, in your Technical File.

It’s also helpful to read the “Note 2.1” that is in the bottom of the grid square that lists EN 60950-1. See below.

So, our advice is that if you have a product to send now and it was tested to the current version of EN 60950-1 then you can do it. However, expect to be questioned about it (by your EU customer or maybe even in customs) and it is probably a good idea to schedule testing to EN 62368-1, soon. We expect a lot of last minute EN 62368-1 projects in Q3 and Q4 of 2020.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 877-405-1580 and are here to help you.

Don’t stress about any of this… call F2 Labs!

Ronin Revolution Corporation worked with F2 Labs to evaluate and test the
Ronin Lift for compliance with the relevant CE marking Directives required to sell their product in Europe. The Ronin Lift is a personal ascender used to lift people for both recreation and tasks.

We advised the engineering staff at Ronin that the equipment, a lifting device for people, is in the scope of the equipment listed in Annex IV of the Machinery Directive 2006/42/EC. Particularly, Annex IV (17), see below.

Equipment that is indicated in Annex IV is the only category of machinery that requires Notified Body involvement, in the form of an EC type-examination certificate. This is required under the following conditions:

1. The equipment is listed in Annex IV.
2. All the risks are not addressed by harmonized standards.

See Article 12 (4.) (a) below:

The engineering staff at both F2 Labs and Ronin Revolution Corporation worked together, extensively, to resolve the detailed risk assessment generated for the Ronin Lift and then set about testing every facet of the equipment. No stone was left unturned in preparation of the EC-type Examination. F2 Labs next assembled a complete Technical File, per 2006/42/EC, Annex VII (A.) and made contact with a Notified Body in the EU to finish the process.

After many rounds of testing, evaluation, and numerous conference calls, we are pleased to announce that Ronin Revolution Corporation has earned the EC type-examination certificate for the Ronin Lift. Congratulations from your friends and colleagues at F2 Labs!

F2 Labs is here to help.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 877-405-1580 and are here to help you.