Automotive ‘e’ Marking: The UK Dilemma

By Geoff Hann, Automotive Test Engineer SGS International

As ‘e’ marking continues its entrenchment within Europe, EU automotive EMC Directives soon come into force with major requirements for the UK. That means mandatory approvals to meet those directives. For those not ready, Geoff Hann takes a look at what’s in store for UK suppliers of electrical products and equipment to the automotive sector.

October 1, 2002 is changeover day for the UK whereby anything and everything that goes into a vehicle where EMC is an issue, has to be ‘e’ marked. EU Directives are already in place in the rest of Europe whilst currently for the UK, there has been the option to either CE mark or ‘e’ mark. But come next year’s October revolution, there will be no choice, ‘e’ marking will be mandatory.

Many manufacturers in the UK have a great deal of work to do as they have little or nothing internally in place to cater for their need to meet the requirements, according to SGS’s Chris Wood who constantly sees the sharp end of the industry sector. “The problem is that manufacturers aren’t really aware of the seriousness of the changeover and where I have had to point out to manufacturers just what is on the horizon, it brings on immediate consternation!”

Theorising a little, obtaining ‘e’ mark approval, obviously depending on the specific product, generally takes around 15 days of testing and then a further four to six weeks or more to issue accreditations etc. Take into account a manufacturer having to organise ‘e’ marking assessment with the VCA or a test house for a product and it could be a protracted four months or more to achieve the mark from the outset. That severely shortens the time available for manufacturers to get their acts into gear to meet the Directives.

“When the day comes next year, there is no self-certification get-out. Everything coming under the automotive EMC Directives has to be tested and certificated,” continued Chris Wood. For the suppliers to the automotive sector that means that even low cost parts will need ‘e’ marking, which creates testing problems and of course an expense to be absorbed, ultimately by the end user. “Already,” stresses Chris Wood, “the rest of Europe is operating under these Directives.”

The approval of components for use in any vehicle within the EU is now covered by EU Directives defined under 95/54/ec for vehicle categories N1 to M1, 97/24/ec for two and three wheeled vehicles, and EU Directive 95/56/ec specifically relating to vehicle security systems.

All these Directives call for the ‘e’ mark approval of a component for use on a vehicle by an EU Technical Service and in the UK, this is the Vehicle Certification Agency, VCA.

The VCA, which has a number of appointed test houses qualified to carry out testing on its behalf, remains the best route for any company to obtain component approval for ‘e’ marking. Manufacturers can simply call the VCA who will advise them exactly on what is required and how to proceed. Alternatively, manufacturers can contact one of the VCA approved test houses such as SGS.

The test house will, after discussing the use and application of a proposed test component and its variants, propose either pre-testing or justify a worst case manufacturing sample for compliance testing to cover the variants for the ‘e’ mark approval.

Automotive Testing at SGS

EU Directive 95/54/ec

In the case of EU Directive 95/54/ec, any component will fall into one of two categories. STU covers a component that is to be fitted to a named model or vehicle and ESA covers components for use on any vehicle. In attaining approval to Directive 95/54/ec, components are also subjected to testing to annexe 7, 8 and 9. Annexe 7 and 8 are the respective requirements for narrow band and broad band emissions and annexe 9 is the immunity requirement.

Emission testing is carried out for compliance over 30 to 1000MHz using an antenna in both the horizontal and vertical positions.  Spot frequency checks are also carried out and all emissions measured must be below the limits.

Immunity testing is carried out over 20 to 1000MHz at 30V/M, with a 1kHz AM modulation 80% applied. Components also undergo a free-field test and for compliance, they must not malfunction.

EU Directive 97/24/ec

For compliance to EU Directive 97/24/ec, the procedures carried out by the test house are very  similar to those of 95/54/ec but EMC is covered under chapter 8 of the Directive.

Once a test house has completed compliance testing on a product, a report is then submitted, together with a technical file on the component and/or its variants, to the VCA for final approval. This involves a Conformity of Production, CoP, and assessment by the VCA in conjunction with the manufacturer. Once this procedure has been completed, the VCA then issues an ‘e’ mark number and certificate for the component and/or its variants.

If, in the future, the product tested is modified or changed in any way, these changes will require an extension to the e-mark certificate and subsequently be approved. This may involve re-testing and/or a pre-test to prove compliance before a report and technical file are submitted for approval to the ‘e’ mark number.

95/56/ec security systems

The compliance procedure to EU Directive 95/56/ec for vehicle security systems is similar in principle to Directive 95/54/ec but with additional security testing of the products. For VCA ‘e’ mark approval, a CoP is still required but with compliance to Directive 95/56/ec.

Security products must comply with EMC Directive 95/54/ec and ISO 10605 covering ESD, as well as ISO 7637, which covers transients. If a vehicle security system incorporates a radio system for arming and disarming, then radio approval is also required before the 95/56/ec ‘e’ mark approval can be issued.

It should be noted that there are cases where a product can be used on a two or three wheeled vehicle, as well as an N1 to M1 vehicle. Such products require compliance to both EU Directives 95/54/ec and 97/24/ec.

For automotive products that require dual marking with the e and CE marks, a procedure of compliance can be sort via a Technical Construction File, TCF, route. This requires a range of EMC testing and a technical file created with the respective test reports added.  This document should then be presented to an Automotive Competent Body which has the required automotive expertise for assessment as a TCF to apply the CE.

SGS as a competent automotive test house, carries out pre-compliance, compliance and diagnostic testing. For EMC ‘e’ marking, it provides a fully technical service covering compliance to EU Directives 95/54/ec and 97/24/ec for two and three wheeled vehicles, as well as for Directive 95/56/ec. The company’s test capability portfolio also extends to 75/322/EEC agricultural or forestry tractors, ECE Regulation 10.02, 71/320/EEC Annexe X paragraph 4.6 and ECE Regulation 13 Annexe 13 paragraph 4.6 for braking systems. The company can also cater for anti-theft devices, ECE Regulation 18.02 paragraph 7 and ECE Regulation 97.

Part of brand new £30,000 investment by SGS specifically for Automotive 'e' marking test approvals

For automotive EMC, SGS capabilities include testing to ISO 7637 for transients, ISO 10605 for ESD, ISO 11452 for emissions and immunity and CISPR 25 for radiated and conducted emissions. As an MIRRC Thatcham approved test laboratory, SGS carries out Phase three testing for HGVs, LCVs, passenger cars and motorcycles, as well as the SCM Homologation Directive AA03 for passenger cars.

For automotive components, SGS certification services include vehicle security systems and devices including alarms, immobilisers and tracking systems, in-car entertainment systems including audio and video systems, as well as OE fitted and after-market products and components.

SGS provides a one stop test house for approval covering ‘e’ marking, CE marking and safety testing for TCF approval as an authorised competent body. Its services also extend to automotive environmental testing covering vibration, atmospheric including salt mist, temperature and humidity including dry heat and cold, and testing for IP rating compliance.

Geoff Hann is SGS International’s Automotive Test Engineer, based in Durham in the UK. 

Contact Kevin Welch on +44 (0)20 9991 4884, email: sgsiea@sgsgroup.com or visit the web site www.sgs.co.uk.