SLIM Progress
Simpler Legislation for the Internal Market

Following on from the announcement on our web site 6th March and the letter from the DTI in our last issue we can now give you a summary of the action timetable.

Timetable Summary

Why SLIM (Simpler Legislation for the Internal Market)

The UK fully accepts the necessity for the EMC Directive and its role will become even more important as the electronics" world evolves. However there is a strong belief that the Directive could be regarded as a "sledge hammer to crack a nut". Among some of the concerns included in the DTI"s review we understand are ...Compliance Costs Especially for Smaller Companies... The problem of one-offs and limited/small production runs is not properly addressed by the Directive, this leads to confusion and avoidance of the Directive altogether by many smaller manufacturers. A review of how much testing is required as an absolute minimum should be carried out. This would, we believe, help reduce unnecessary testing from being carried out and therefore reduce costs. Consideration should also be given to reference/inclusion in the Directive or the guidelines of a section dealing with manufacturer"s "risk assessment".

Scope of the Directive

The EMC Directive is one of the broadest of all the "new approach" Directives in terms of its scope, affecting diverse industry sectors from toys to commercial aircraft; from boat builders to electricity generators; and from veterinary products to sign manufacturers etc.
The review should consider the need for so many sectors to he covered by the Directive. Is there scope to remove from the coverage of the Directive certain sectors? Another view might be that it could be easier for industry if some of the other Directives already in existence had EMC requirements built into their scope e.g. Including EMC requirements in the "Equipment for use in Potentially Explosive Atmospheres (ATEX) Directive"; having a specific EMC Directive for all radiocommunications and telecommunications apparatus, including telephone exchanges etc.

EMC Directive/EMC Guidelines Differences.

The Commission"s new EMC guidelines have addressed and resolved many problems. However, in attempting to provide advice the guidelines are now in conflict with the Directive i.e. in some areas they go further than the Directive (the advice on "installations" is a good example). It would be sensible to review the Directive against the guidelines, especially since the guidelines have a high level of acceptance amongst Member States, industry, the Commission and other interested parties, and were the result of eighteen months of experience of working with the Directive.
The SLIM review, should also provide the opportunity to review the guidelines in areas where they are being misinterpreted e.g. the effect on overall compliance of products assembled from CE Marked components (personal computers, burglar alarms etc).

EMC standards.

The harmonised European standards which support the Directive should provide, potentially, the easiest route to conformity. However, the proliferation of standards and the interaction between new standards and those being withdrawn leads to uncertainty as to which are the current, correct standards.
The SLIM review should consider a complete stop to the promulgation (or parallel voting) of any new standards whilst those already in existence are reviewed as to their suitability. This is particularly important in the EN61000/1EC1000 series (standards covering different EMC phenomena).
In relation to Compliance Costs the SLIM review should aim to provide clarification as to how to apply EMC standards in the most cost effective manner. The Directive is extremely ambiguous in this respect, as it says that manufacturers are provided with a presumption of conformity if they have applied the harmonised standards. What does apply mean in this respect? For example, is it to test to the standards, or pay regard to the standards, etc.? Over-representation on standards committees by organisations with a vested interest is also a problem which needs to he addressed. (Although this problem is not unique to EMC.) However, there is no reason why this issue, which has caused problems in some EMC standards cannot be looked at through the EMC Directive experience as part of the review of the Directive.

Removing Ambiguity or Ease Compliance.

  1. The Directive should make a clear statement that products outside of the scope of the Directive e.g. components not performing a direct function should not carry the CE Marking.
  2. The EMC Directive should make clear the boundaries between itself and specific vertical Directives such as medical devices and automotive products.

Immunity Requirements of the Directive

The immunity requirements of the Directive (a product"s ability to operate as it should when faced with emissions from another product) are an issue for many manufacturers of all sizes. Across the board immunity requirements even when applied pragmatically still cause confusion, concern and additional financial burden.
The review should question whether all products should the required to meet immunity requirements e.g. is it necessary for toys to meet the immunity requiremenis of the Directive if there is not a safety issue related to their ability to withstand emissions from other products.

We'll keep you posted ....

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