Delays in publishing EN standards and listing them in the Official Journal

By J. M. Woodgate B.Sc.(Eng.) C.Eng.  MIET SMIEEE FAES Hon FInstSCE MIOA

Delays in publishing EN standards and listing them in the Official Journal

Manufacturers and test houses are increasingly concerned and confused by the current and on-going delays in publishing EN standards and listing them in the Official Journal. This is not due to any inactivity on the part of the responsible CENELEC committee TC210. Rather it is due to the complexity resulting from certain interventions by the legal arm of the European Commission, and the changes to EMC standards necessitated by the change of applicability between the superseded Radio and Telecommunications Terminal Directive (RTTED) and the Radio Equipment Directive (RED). The issues are quite complex, but may be summarized as:

  • Legal challenge to the '80/80 rule', which uses a statistical process to allow for the impossibility of putting every production item through the full testing procedure required by EMC standards. The issue is that '80/80' means that there is 80% confidence that 80% of a series of production items meet the requirements of the relevant standards, whereas the EMC Directive (EMCD) requires every item to conform. The challenge is legally in order, but it is obvious that it is impossible to accept  the 'every item' requirement, because of the natural variations in performance predictable by the Laws of Physics (which are more fundamental than man-made laws).

    Conformity with the statistical rule is achieved by setting an acceptance limit a few dB lower than the limit in the standard. The number of dB can be calculated from observed values of the variations in emission level from products of the same type, or from similar data from pre-production samples.

    It would be possible to change the rule to '99/99', but not only would that not dispose of the legal issue but it would result in effectively much more stringent requirements that the present standards include, and there is no reason to suppose that such extra stringency is justified. Attempts are being made to find a way of preserving the rule, while satisfying the legal constraints, but this is a very difficult task.
  • The RTTED excluded broadcast receivers from its scope, but they are included in the RED. The RED cannot refer normatively to the EMCD, so the relevant standards (EN 55032 and EN 55035) have to be modified to be acceptable as 'routes' to compliance' under the RED.
  • The European Commission requires explicit statements, in each standard intended to support a Directive, concerning which texts in the standard are relevant to conformity and (thus) which are not. This requires one special Annex for each Directive concerned, and these have to be exceedingly carefully worded.

What is to be done? There is a proposal that CENELEC publishes EMC standards adopted from IEC/CISPR without waiting for text relating to regulatory matters, which are to be added later by amendment.  This procedure is similar to that used by ETSI for its own ENs, and may be approved by the CENELEC Technical Board quite soon (or not!). If this is done, manufacturers should have more time to develop or modify products to ensure conformity.

There was another proposal in CENELEC to produce a 'stand-alone' standard on the 80/80 rule, but this does not seem to be necessary as it already exists in CISPR 16-4-3 (BSI PD CISPR 16-4-3).