Assembling systems? Do you comply with the law?

 

Are you assembling computer systems? If you aren’t complying with the Electromagnetic Compatibility (EMC) Regulations as part of your assembly process then you are breaking the law and you face a potentially large fine.

 

WHAT DOES THE LAW REQUIRE ?

There are two EM conditions that are covered. Products must be so constructed that they do not cause excessive electromagnetic interference and must not be unduly affected by EM interference (known as emission and immunity). Additionally, they must carry the CE mark to show that they comply. The CE mark - a very specific design - can be fixed to the product, its packaging, or its accompanying manual or guarantee. The standards against which products can be measured are published by various bodies, primarily the British Standards Institute. It is important for assemblers to understand that putting components into a CE marked case does not in itself meet the requirements of the law.

 

It is an offence to place on the Community market, which includes the UK, or import into the Community, products that do not comply. It is also an offence to ''take into service'' goods that don't comply.

 

The EMC Directive covers virtually anything electrical. Small components (''an element intended to be integrated into an assembly'') are currently excluded from the directive but third party add in cards and controllers are included ("components which deliver a direct function") and must be certified compliant if they are available on the market. As a rule of thumb, major components and sub assemblies must comply. Components intended to be put on the market, as a single commercial unit must comply, which would by definition include upgrade processors sold as such, motherboards and so on.

 

A System is defined as ''pieces of equipment designed to be associated and function together and fulfil a given task''. Be aware that even if a system is built using compliant components, the complete unit still has to be separately certified. EC documentation gives an example of a "Data Processing System" having: micro computer, keyboard, display unit, mouse, printer, plotter, storage devices, all of which together form a whole unit, which should be certified as such.

 

For the purposes of PC system builders, if they are purchasing complete system units and adding monitors and other peripherals of their own choice, that complete assembly, as marketed, must be separately certified as being compliant. And if you assemble just system units, or build monitors, each of those assemblies must individually comply. Obviously, if you both assemble system units and integrate them with monitors and keyboards, you are responsible for ensuring that the resultant systems comply.

 

The electromagnetic environment is defined as ''the totality of electromagnetic phenomena existing at a given location'', and may be summarised as:

 

EMISSIONS:

·         mains harmonic currents;

·         conducted RF on mains cable;

·         conducted RF on other ports;

·         radiated RF

 

IMMUNITY:

·         electrostatic discharge;

·         fast transients;

·         surges;

·         radiated RF;

·         conducted RF;

·         voltage dips and interruptions;

·         magnetic fields.

 

If you are not a manufacturer, but an importer of components or of completed products say, and if the manufacturer has no authorised representative in the EC, be aware that as the supplier of the apparatus you are responsible for ensuring that the products comply.

 

If you supply a kit of components then you must make sure that the kit, when assembled, complies.

 

Genuine second hand apparatus need not comply provided that it was originally sold prior to the new rules coming into force.

 

If you upgrade, reconfigure, or remanufacture systems, then the resultant upgrade must comply even if the original unit was sold before the regulations came into being - provided that you are claiming that the resultant upgrade brings the product into "as new" condition.

 

The PCA, the predecessor to the Technology Channels Association, has produced comprehensive Guidance Notes to the EMC Regulations and some simple low cost routes to conformity. They are available free of charge to download from the members area of the TCA website, or can be purchased for £30 from the TCA. Phone 0845 634 9245 for further information