Post on 31-Jan-2018
TÜV Product Service Ltd
Introduction to EMC Directive
Conformity of Defence Equipment
Presented by Pete Dorey Senior Consultant, TÜV SÜD Product Service
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CLC/TR 50538:2010
• “Guide to EMC Directive conformity of equipment
designed for military purposes”
• Prepared by CENELEC TC210 WG 9 to replace R210-
008:2002
• It is a „Technical Report‟ not a standard
• Purpose: To provide guidance to manufacturers,
suppliers, importers, procurement authorities and those
taking equipment into service within Member States on
the application of the EMC Directive to military
equipment
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TR 50538 Content
• Introduction
• Background
• Scope
• Directives for EMC Conformity
• Application of the EMC Directive to military equipment
• Annex A Defence Procurement Directive
• Annex B Article 346 of the Treaty of Lisbon
• Annex C Council Decision 255/58 EC
Council list of items
• Annex D Environments
• Annex E Flow diagram for apparatus
• Annex F Flow diagram for fixed installations
• Annex G Read across tables, military and
harmonised standards
• Annex H Comparison of EMC test methods
• Annex I Examples of gap analysis
• Annex J Example case studies
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Background
• No reference to military equipment in EMC Directive
• But defence contracts fall under EU internal market rules
• Can be exempted under EU Treaty of Lisbon Article 346 -
considering EC Interpretive Communication COM(2006) 779
final (i.e. case by case not blanket exemption)
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• Need for European defence equipment market
• CEN WS 10 EG7 review of military standards
and procurement handbook
• Public Procurement Directive 2004/18/EC
• Defence Procurement Directive 2009/81/EC (in
August 2011)
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Scope
• Section 1 Scope:
• Applies to non-exempt military / defence equipment
(under Article 346)
• Excludes military standard requirements (e.g.
contractual standards MIL-STD 461, Def Stan 59-
411)
• EMC aspects only
• Applies to:
2006-05-10 5Apparatus Fixed Installation
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Mobile Installations
• Mobile Installations are defined as
a combination of apparatus
intended to be moved and
operated in a range of locations
• Mobile Installations are Apparatus
• The TR 50538 does not give
specific definitions of mobile
installations but notes that ships
and military aircraft are not „fixed
installations‟
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Directives for EMC Conformity
• Section 2 Considers:
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EMC Directive
2004/108/EC
R&TTE Directive
1999/5/EC
Marine Equipment
Directive
96/98/EC & Amdts
Automotive
Directive
2004/104/EC
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What does the manufacturer need to consider?
• Intended Use –HOW does the manufacturer intend the
equipment to be used?
– This may include a decision as to WHEN particular modes
of operation are used; e.g. peacetime/at war modes
• Interfaces – WHERE does the equipment interface to public
users; e.g. radiated impact on Radio/TV reception,
connection to public mains power, connection to public
telecommunications systems
• Environment – WHAT environment does the equipment
operate in? e.g. an environment represented by military
standards or also in environments where other standards
(e.g. harmonised standards) apply?
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Section 3 Application of the EMC Directive to military equipment raises some
questions for the manufacturer
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Military Apparatus Compliance Process
9
Annex E
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Harmonised Standards
• If the manufacturer wants to demonstrate conformity with
environments represented by harmonised standards they can
simply test the equipment in accordance with harmonised
standards
• This may be attractive to a manufacturer who wishes to keep
the military / contractual test evidence completely separate
from the EMC Technical Documentation compliance evidence
• The process follows the normal apparatus conformity process
where the use of harmonised standards gives a presumption
of conformity (low risk)
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Detailed Technical Assessment
• The EMC Directive and its guide are not very explicit on what tools and
techniques to use, so the TR 50538 Guide has provided further guidance
in section 3.2.4:
• Existing EMC test evidence – e.g. results from military standard testing can
be used directly in the Technical Documentation or analysed for meeting
the essential protection requirements
• Engineering tests – results of alternative testing e.g. in-situ, trials
• Modelling & Simulation – Computational Electromagnetic Modelling (CEM)
• Design evidence – good EMC engineering practices
• Similarity – to other compliant models/variants
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• Mitigation & Control – restrictions on
use (where or how used)
• Gap analysis – assess equivalence of
military standards/results to
harmonised standards where these
also represent intended operating
environments
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Military Standards
• Military/Defence standards are not harmonised under the EMC
Directive
• Since the military standard represents the intended environment (in
total or in part) the test results can be used in the detailed assessment
for EMC Directive compliance
• Non-harmonised standards do not give a presumption of conformity –
manufacturer‟s judgement on meeting the essential protection
requirements
Def Stan 59-411 MIL-STD 461 AECTP 500
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Why consider other standards?
• Depending on the original design intent, the manufacturer
should consider environments/standards for:
– User trials
– Storage
– Training establishments
– Military establishments
– Dockyards
– Airfields
– Peacetime operations
– Policing activities
• Therefore harmonised standards for residential, light
industrial, commercial or industrial environments may be
relevant
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Annex D discusses environments and selection of standards:
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Technical Documentation
The manufacturer compiles EMC Technical Documentation,
example:
• Equipment Description
• EMC management documentation – conformity approach
• Operating conditions, interfaces, environments
• Military test standards & report
• Relevant harmonised standards & report
• Detailed technical assessment
• Restrictions on use
• Declaration of Conformity
Optional assessment
by Notified Body
Notified Body
Statement of
Compliance
Section 3.2.5 provides guidance on the Technical Documentation:
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EMC Declaration of Conformity
• The manufacturer is ultimately responsible
• The Declaration of Conformity requires a reference to the
specifications under which conformity is declared. These may
be:
– Harmonised standards
– Military standards
– Technical Documentation (containing other detailed
technical assessments)
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Fixed Installation Compliance Process
• Examples of Possible Fixed Installations:
– Army camp
– Barracks
– Dockyard
– Land based test site
– Training facility
– Trials site
– But not mobile installations
• EMC assessment, DoC, CE Marking not required
• Fixed Installation Requirement:
– Assess existing military EMC installation practices against the
essential protection requirements for emission/immunity
– Document good engineering installation practices used
– „Responsible Person‟ holds documentation to be available to
enforcement authorities
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Section 3.3 provides guidance on Fixed Installations:
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Military Fixed Installation Conformity Process
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Annex F
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Pete Dorey
Senior Consultant, TÜV SÜD Product Service
Tel: +44(0)1489 558211
pdorey@tuvps.co.uk
ww.tuvps.co.uk