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TÜV Product Service Ltd

Introduction to EMC Directive

Conformity of Defence Equipment

Presented by Pete Dorey Senior Consultant, TÜV SÜD Product Service


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


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


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)

2006-05-10 4

• 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)


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


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‟

2006-05-10 6


Directives for EMC Conformity

• Section 2 Considers:

2006-05-10 7

EMC Directive

2004/108/EC

R&TTE Directive

1999/5/EC

Marine Equipment

Directive

96/98/EC & Amdts

Automotive

Directive

2004/104/EC


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?

2006-05-10 8

Section 3 Application of the EMC Directive to military equipment raises some

questions for the manufacturer


Military Apparatus Compliance Process

9

Annex E


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)

2006-05-10 10


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

2006-05-10 11

• 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


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


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

2006-05-10 13

Annex D discusses environments and selection of standards:


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:


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)


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

2006-05-10 16

Section 3.3 provides guidance on Fixed Installations:


Military Fixed Installation Conformity Process

2006-05-10 17

Annex F


Pete Dorey

Senior Consultant, TÜV SÜD Product Service

Tel: +44(0)1489 558211

[email protected]

ww.tuvps.co.uk

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