CLC/TR 50538:2010
(Main)Guide to EMC Directive conformity of equipment designed for military purposes
Guide to EMC Directive conformity of equipment designed for military purposes
This Technical Report is applicable to any non-exempt military equipment. This Technical Report does not affect the requirements to meet military standards. This Technical Report only covers aspects related to EMC as covered by the EMC Directive 2004/108/EC and other directives that address EMC. In this respect there is no distinction between civilian and defence equipment. For the purpose of this Technical Report the term “military” is equivalent to the term “defence”. Annex B describes Article 346 and Annex C provides the associated EC Council List of items under Article 346 [12]. The definitions in EMC Directive 2004/108/EC of “apparatus” and “fixed installations” as applied to military equipment are considered and guidance is given on applicability with the use of flow diagrams. For apparatus, the use of military standards to demonstrate compliance with the EMC Directive by using various assessment methods that do not use harmonised standards and a “gap” analysis tool for comparison of military standard results with harmonised standards is presented. This Technical Report also covers fixed installations using military equipment, and their impact on neighbouring environments. The conformity assessment procedures of EMC Directive 2004/108/EC have been reviewed and guidance given on the applicability and contents of detailed technical EMC assessment. Annex J includes some case studies to help clarify the extent and use of this Technical Report.
Leitfaden zur Konformität von Geräten, die für militärische Zwecke entwickelt wurden, mit der EMV-Richtlinie
Guide de conformité à la Directive CEM pour les équipements conçus à usages militaires
Vodilo za skladnost opreme za vojaške namene z direktivo EMC
To tehnično poročilo velja za vso neizvzeto vojaško opremo. To tehnično poročilo ne vpliva na zahteve, potrebne za izpolnjevanje vojaških standardov. To tehnično poročilo zajema le vidike, povezane z EMC, kot jih zajemajo Direktiva EMC 2004/108/ES in druge direktive, ki obravnavajo EMC. V tem smislu ni razlike med civilno in obrambno opremo.
Za namen tega tehničnega poročila je izraz »vojaški« enakovreden izrazu »obrambni«.
Dodatek B opisuje člen 346, dodatek C pa navaja povezani seznam postavk Sveta ES v skladu s členom 346 [12].
Obravnavane so definicije izrazov »aparat« in »fiksne inštalacije« v direktivi EMC 2004/108/ES, kot veljajo za vojaško opremo, in podano je vodilo za uporabo z diagrami poteka.
Za aparate je predstavljena uporaba vojaških standardov za prikaz skladnosti z direktivo EMC z različnimi metodami ocenjevanja, ki ne uporabljajo usklajenih standardov, in orodje za analizo »vrzeli« za primerjavo rezultatov vojaških standardov z usklajenimi standardi.
To tehnično poročilo zajema tudi fiksne inštalacije, ki uporabljajo vojaško opremo, in njihov vpliv na sosednja okolja.
Pregledani so postopki ocenjevanja skladnosti Direktive EMC 2004/108/ES in podano je vodilo o uporabnosti in vsebini podrobne tehnične ocene EMC.
Dodatek J vključuje nekaj študij primerov, ki pojasnjujejo obseg in uporabo tega tehničnega poročila.
General Information
Standards Content (Sample)
SLOVENSKI STANDARD
SIST-TP CLC/TR 50538:2011
01-december-2011
1DGRPHãþD
SIST R210-008:2003
Vodilo za skladnost opreme za vojaške namene z direktivo EMC
Guide to EMC Directive conformity of equipment designed for military purposes
Leitfaden zur Konformität von Geräten, die für militärische Zwecke entwickelt wurden, mit
der EMV-Richtlinie
Guide de conformité à la Directive CEM pour les équipements conçus à usages militaires
Ta slovenski standard je istoveten z: CLC/TR 50538:2010
ICS:
33.100.01 Elektromagnetna združljivost Electromagnetic compatibility
na splošno in general
95.020 Vojaška tehnika. Vojaške Military engineering. Military
zadeve. Orožje affairs. Weapons
SIST-TP CLC/TR 50538:2011 en
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
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SIST-TP CLC/TR 50538:2011
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SIST-TP CLC/TR 50538:2011
TECHNICAL REPORT
CLC/TR 50538
RAPPORT TECHNIQUE
October 2010
TECHNISCHER BERICHT
ICS 33.100.01 Supersedes R210-008:2002
English version
Guide to EMC Directive conformity of equipment designed for military
purposes
Guide de conformité à la Directive CEM Leitfaden zur Konformität von Geräten, die
pour les équipements conçus à usages für militärische Zwecke entwickelt wurden,
militaires mit der EMV-Richtlinie
This Technical Report was approved by CENELEC on 2010-09-17.
CENELEC members are the national electrotechnical committees of Austria, Belgium, Bulgaria, Croatia,
Cyprus, the Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland,
Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands, Norway, Poland, Portugal, Romania,
Slovakia, Slovenia, Spain, Sweden, Switzerland and the United Kingdom.
CENELEC
European Committee for Electrotechnical Standardization
Comité Européen de Normalisation Electrotechnique
Europäisches Komitee für Elektrotechnische Normung
Management Centre: Avenue Marnix 17, B - 1000 Brussels
© 2010 CENELEC - All rights of exploitation in any form and by any means reserved worldwide for CENELEC members.
Ref. No. CLC/TR 50538:2010 E
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CLC/TR 50538:2010 – 2 –
Foreword
This Technical Report was prepared by WG 9, EMC of Military Equipment, of Technical Committee
CENELEC TC 210, Electromagnetic Compatibility (EMC).
It was circulated for voting in accordance with the Internal Regulations, Part 2, Subclause 11.4.3.3
(simple majority) and was approved by CENELEC as CLC/TR 50538 on 2010-09-17.
This document supersedes R210-008:2002.
Attention is drawn to the possibility that some of the elements of this document may be the subject of
patent rights. CEN and CENELEC shall not be held responsible for identifying any or all such patent
rights.
__________
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Contents
Introduction . 5
Background . 6
1 Scope . 7
2 Directives for EMC conformity . 7
2.1 EMC Directive . 7
2.2 Radio & Telecommunication Terminal Equipment Directive . 7
2.3 Automotive Directive . 8
2.4 Marine Equipment Directive . 8
3 Application of the EMC Directive to military equipment . 8
3.1 Introduction to apparatus and installations . 8
3.2 Apparatus . 9
3.3 Fixed installations .14
Annex A A précis of the Defence Procurement Directive .17
Annex B Article 346 of the Treaty of Lisbon (TEC) .19
B.1 Legal basis .19
B.2 Security interests and treaty obligations .19
B.3 Conditions of applications of Article 296 TEC (according to interpretative
communication COM(2006) 779 final .20
B.4 How to apply Article 346 TEC .20
Annex C Council Decision 255/58 – EC Council list of items defining the scope of
Article 223 of the Treaty of Rome.22
Annex D Environments .24
D.1 Military standards and environments .24
D.2 Harmonised standards and environments .25
D.3 Selection of environments and standards for the EMC assessment .26
Annex E Flow diagram for apparatus .28
Annex F Flow diagram for fixed installation/specific apparatus .29
Annex G Read across tables between military and harmonised standards (Test method
level) .30
Annex H Comparison of EMC test methods .31
Annex I Examples of gap analysis .40
Annex J Example Case Studies .41
Bibliography .42
Standards .42
Other documents .43
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Figures
Figure E.1 – Flow diagram for apparatus .28
Figure F.1 – Flow diagram for fixed installation/specific apparatus .29
Figure I.1 – Example of Radiated Immunity Gap Analysis between AECTP501 NRS02.1 Ground
and „Industrial‟ Immunity Limit where the Military Standard is more onerous (Industrial limit
modified for comparison) .40
Figure I.2 – Example of Power/Signal Port Conducted Immunity Gap Analysis between
AECTP501 NCS07.1 Ground and „Industrial‟ Immunity Limit where the Military Standard is
less onerous over part of the frequency range (Industrial limit modified for comparison) .40
Tables
Table G.1 – Factors to be considered during an EMC gap analysis .30
Table H.1 – Comparison of EMC test methods .31
Table H.2 – Detailed comparison of EMC test methods .32
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Introduction
CENELEC R210-008:2002 has been updated and revised with regard to the EMC Directive
2004/108/EC to create this new Technical Report, CLC/TR 50538 “Guide to EMC Directive conformity
of equipment designed for military purposes”.
The EMC Directive, 2004/108/EC [1], does not contain any reference to military equipment.
The manufacturer is fully responsible for complying with the EMC Directive, 2004/108/EC [1] and
cannot devolve this responsibility to a third party. Comprehensive guidance is provided in the “Guide
for the EMC Directive 2004/108/EC” [16].
There are a number of recent and emerging documents that have been considered including
Defence Procurement Directive 2009/81/EC [2],
Public Procurement Directive 2004/18/EC [15],
the EU Interpretative Communication COM (2006) 779 final [4] on the application of Article 296
TEC to the procurement of military equipment. (Note that Article 296 of the Treaty of Amsterdam
has now become Article 346 of the Treaty of Lisbon.)
This Technical Report has been prepared by reviewing all currently available relevant documentation
as listed in the Bibliography.
The purpose of this Technical Report is 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.
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Background
A Technical Report was produced by CLC/TC 210 (EMC) in 1998 in order to provide guidance to
manufacturers of military equipment to comply with the EMC Directive 89/336/EEC [5] Under this
Directive 89/336/EEC there were interpretations at Member State level which resulted in a non-
harmonised application of the directive by military equipment manufacturers across the EU.
An interpretative communication concerning the Public Procurement Directive was issued in late 2006.
It states; “According to existing EU law, defence contracts fall under Internal Market rules”. This has
been interpreted as meaning that all military equipment is subject to the rules of the EU regarding the
procurement of equipment, However Member States can exempt defence contracts under Article
296(1)(b) that it considers to fulfil the concept of „essential security interests‟.
The conclusion from the Commission lawyers (validated in a court case between the Commission and
a Member State), in COM (2006) 799 is very specific and concludes that the exemptions are very few
and will have to be assessed on a case-by-case basis by the contracting authority.
More recently the Defence Procurement Directive 2009/81/EC of 13 July 2009 [2] has been published.
This concerns the gradual establishment of a European defence equipment market and as a
prerequisite an appropriate legislative framework. This Directive has profound implications on
Members States procurement of Defence equipment and services. A précis of the Directive is provided
in Annex A.
1)
CEN WS 10 EG7 E3 has reviewed military Electromagnetic standards for inclusion in the “European
Handbook for Defence Procurement” (CWA 15517 [10]). The information contained in their report has
been used and incorporated where applicable.
)
1
CEN: European Committee for Standardisation, Workshop 10: Standardization for Defence Procurement,
EG7: Expert Group 7: Electromagnetic Environment
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1 Scope
This Technical Report is applicable to any non-exempt military equipment.
This Technical Report does not affect the requirements to meet military standards.
This Technical Report only covers aspects related to EMC as covered by the EMC Directive
2004/108/EC and other directives that address EMC. In this respect there is no distinction between
civilian and defence equipment.
For the purpose of this Technical Report the term “military” is equivalent to the term “defence”.
Annex B describes Article 346 and Annex C provides the associated EC Council List of items under
Article 346 [12].
The definitions in EMC Directive 2004/108/EC of “apparatus” and “fixed installations” as applied to
military equipment are considered and guidance is given on applicability with the use of flow diagrams.
For apparatus, the use of military standards to demonstrate compliance with the EMC Directive by
using various assessment methods that do not use harmonised standards and a “gap” analysis tool for
comparison of military standard results with harmonised standards is presented.
This Technical Report also covers fixed installations using military equipment, and their impact on
neighbouring environments.
The conformity assessment procedures of EMC Directive 2004/108/EC have been reviewed and
guidance given on the applicability and contents of detailed technical EMC assessment.
Annex J includes some case studies to help clarify the extent and use of this Technical Report.
2 Directives for EMC conformity
2.1 EMC Directive
The EMC Directive (2004/108/EC) defines the following protection requirements as essential
requirements:
a) the electromagnetic disturbance generated does not exceed the level above which radio and
telecommunications equipment or other equipment cannot operate as intended;
b) it has a level of immunity to the electromagnetic disturbance to be expected in its intended use
which allows it to operate without unacceptable degradation of its intended use.
The conformity procedures are detailed in 3.2.3 and 3.2.4.
The EMC Directive makes specific exemptions for radio equipment and telecommunications terminal
equipment covered by Directive 1999/5/EC [3], civilian aircraft or equipment fitted to civilian aircraft
referred to in Regulation (EC) No. 1592/2002 [14], radio amateur equipment and inherently benign
equipment.
This section contains a summary of other pertinent EU Directives.
2.2 Radio & Telecommunication Terminal Equipment Directive
As noted above, all equipment in the scope of the R&TTE Directive 1999/5/EC [3] is excluded from the
EMC Directive. The EMC aspects of equipment within the scope of the R&TTE Directive are covered
by that Directive. It follows that equipment that falls outside the scope of the R&TTE Directive is
therefore within the scope of the EMC Directive.
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In particular, the R&TTE Directive does not apply to apparatus exclusively used for activities
concerning public security, defence, state security and activities of the state in the area of criminal law.
Accordingly, military radios used solely by state armed forces may be subject to the EMC Directive.
It is important to note that such use must be exclusive. If these radios are also sold to private security
operations for use other than defined in the “security” exclusion, they are regulated under the R&TTE
Directive. For example, TETRA systems that are widely used by public authorities are subject to the
R&TTE Directive because they are not exclusively used for the activities excluded from its scope.
However a Tetra-based system designed only for security use as defined in Article 1.5 is excluded
from the scope of the R&TTE Directive, whether the equipment is used by a Department of a Member
State or by a private or public company undertaking duties on behalf of the Member State.
2.3 Automotive Directive
In the case of vehicles intended for use on public roads, the Automotive EMC Directive
2004/104/EC [6] applies to cars, trailers and their electronic sub-assemblies. It should be noted that
Directive 2007/46/EC (Framework Directive) [7] may also apply to other road going vehicles.
Compliance with Directive 2004/104/EC is demonstrated by affixing „e-marking‟ to the equipment or
vehicle.
2.4 Marine Equipment Directive
In the case of marine equipment, the Directive 96/98/EC [13] amended by Directives 98/85/EC,
2001/53/EC and 2002/75/EC applies International Maritime Organisation (IMO) standards to assess
the compliance of equipment related to safety at sea (navigation and radio communications) and
pollution prevention. This is a type approval process and compliance with the directive is
demonstrated by affixing “wheelmark” to such equipment. All non-safety equipment are assessed
following the EMC Directive 2004/108/EC.
3 Application of the EMC Directive to military equipment
3.1 Introduction to apparatus and installations
In order for military equipment to comply with the EMC Directive it is first important to understand the
different types covered. In essence the EMC Directive covers equipment which is either apparatus or
fixed installations and defines a different regime for these two categories.
The following definitions are extracted from the EMC Directive 2004/108/EC, Article 2, for clarification
on the two types of equipment/system covered by the directive:
a) „apparatus‟ means any finished appliance or combination thereof made commercially available as
a single functional unit, intended for the end user and liable to generate electromagnetic
disturbance, or the performance of which is liable to be affected by such disturbance. Apparatus
is subject to the full provisions of the directive including a Declaration of Conformity (DoC) and
CE marking;
b) „fixed installation‟ means a particular combination of several types of apparatus and, where
applicable, other devices, which are assembled, installed and intended to be used permanently at
a predefined location;
Fixed installations do not require a DoC or CE marking but must meet the protection requirements.
In the special case of apparatus intended for incorporation into a specific fixed installation which is
otherwise not commercially available the provision of Article 13(1) of the EMC Directive may be
applied. This apparatus does not need to be CE marked but must be supplied with installation
instructions that ensure the essential protection requirements. This provision is only for an individual
apparatus intended for a specific fixed installation.
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The protection requirements of the directive are the same for both apparatus and fixed installations
such that
c) the electromagnetic disturbance generated does not exceed the level above which radio and
telecommunications equipment or other equipment cannot operate as intended,
d) it has a level of immunity to the electromagnetic disturbance to be expected in its intended use
which allows it to operate without unacceptable degradation of its intended use.
Mobile installations are defined as a combination of apparatus intended to be moved and operated in
a range of locations. All provisions of the EMC Directive, as defined for apparatus, apply to mobile
installations.
3.2 Apparatus
3.2.1 Conformity assessment procedure
This subclause describes the conformity assessment procedure for military apparatus falling within the
scope of the EMC Directive.
The conformity assessment procedure for apparatus is described in Article 7 of the EMC
Directive 2004/108/EC. Comprehensive guidance is provided in the “Guide for the EMC Directive
2004/108/EC” [16].
This conformity assessment procedure applied to military apparatus is given in Annex E.
The EMC assessment described in Annex II of the EMC Directive 2004/108/EC requires all normal
intended operating conditions and configurations to be taken into account.
3.2.2 Intended operating conditions, interfaces and environment
As highlighted above due consideration must be given to the operating conditions, interfaces and
environment.
The operating conditions relate to the modes of operation. They could include where equipment is
provided with a peacetime mode where certain functions may be disabled. All relevant operating
conditions (peacetime role) need to be considered where these distinct modes will have an impact on
the electromagnetic performance.
The operating environment and interfaces need careful consideration since this will define what and
how close other equipment is located. Equipment located in a controlled EM environment (for
example, below decks ship equipment) is very different to man portable radio equipment. Refer to
Clause D.3.
3.2.3 EMC conformity assessment
3.2.3.1 Introduction
The EMC Directive requires an EMC assessment of the apparatus to determine if the protection
requirements are met. The EMC assessment is described in the conformity assessment procedure for
apparatus given in Article 7 and Annexes I, II and III of the EMC Directive 2004/108/EC.
According to the “Guide for the EMC Directive 2004/108/EC” [16], three methods are possible for the
EMC assessment and their application in the context of military equipment is discussed below:
use of harmonised standards;
mixed EMC assessment;
detailed technical EMC assessment.
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3.2.3.2 Use of harmonised standards
Harmonised standards are published in the Official Journal of the EU. Apparatus that complies with
relevant harmonised standards has a presumption of conformity with the protection requirements of
the EMC Directive. Harmonised standards fall into three categories, basic, product specific and
generic. Basic standards are those that are referred to by Product specific or Generic standards to
simplify the writing of the standards. Product specific standards are those written particularly for a
product type. Generic standards are written to provide harmonised standards where there are no
product specific standards.
If the manufacturer prefers to use harmonised standards and since there are no harmonised standards
dedicated for military equipment, then a suitable civil harmonised standard should be identified.
A description of harmonised standards is given in Clause D.2 with guidance on when they may be
applicable to military equipment.
3.2.3.3 Mixed EMC assessment
A mixed EMC assessment is where parts of a harmonised standard have been applied together with a
technical assessment to demonstrate that all the protection requirements are met. A more detailed
description of the technical EMC assessment is given in 3.2.3.4. The technical assessment may
include a wide range of technical analysis methods to identify or mitigate any disparity between the
military compliance and EMC Directive protection requirements. Analysis methods are described in
3.2.4.
3.2.3.4 Detailed technical EMC assessment
A detailed technical EMC assessment is where no harmonised standard has been applied but a
detailed assessment performed instead.
Annex IV(1) of the EMC Directive 2004/108/EC, states that this includes
steps taken to meet the requirements,
description of the electromagnetic assessment,
results of design calculations (it is suggested by this guide that this could include modelling and
simulation),
examinations carried out,
test reports.
The “Guide for the EMC Directive 2004/108/EC” [16] adds that the assessment required will depend
on several factors, such as
nature of apparatus,
intended use,
location of use,
EMC environment,
types of disturbance created by or affecting the apparatus,
environmental conditions,
performance criteria for immunity.
The technical assessment for military apparatus may include methods such as those shown in
Figure E.1.
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3.2.4 Examples of detailed technical assessment methods
3.2.4.1 Introduction
The aim of an assessment is to provide evidence that the equipment will meet the protection
requirements of the EMC Directive.
The methods include using existing EMC test evidence or in some circumstances additional evidence
such as modelling, engineering tests or experiments, or specific in-situ (special) tests, or by gap
analysis. Other methods of determining compliance may take the form of a review of existing design
evidence, or of particular circumstances that provide mitigation and or control of the products
electromagnetic characteristics. One form might be to use the similarity of the current product to an
earlier version.
These methods can be applied individually or in combination and are further described below.
3.2.4.2 Using existing EMC test evidence (e.g. military standards)
In many circumstances, test results against a military specification can be examined by experienced
personnel who will be able to determine compliance with the protection requirements by inspection.
3.2.4.3 Engineering tests, or experiments, or in-situ (special) tests
There are circumstances where the manufacturer might want to make tests and/or assessments on
part of the equipment, or prototypes, or to implement special in-situ tests and practices.
The manufacturer has to evaluate this risk when he declares conformity to the protection requirements
allowing himself such deviations, and he takes full responsibility of the choice. The technical
documentation should give detailed information on such deviations described hereafter:
a) the nature of the engineering tests or experiments performed, and the rationale for having chosen
these tests;
b) the standards, if any, adopted as reference for performing the tests, and all the precautions
implemented during the tests execution, or the simplified methods (sometimes called pre-
compliance methods) utilized;
c) the test set-up and the deviations from the prescriptions of the standard adopted, and all the other
details useful to understand the performed activities;
d) the results of the tests and of any pre-scan measurement made to quickly obtain information on
the performances (emission and immunity) of the apparatus, in order to decide whether a full
complete measurement is considered necessary;
When applying special tests it is essential to identify
the coupling mechanism with the external environment,
the ports/interfaces where conducted and/or radiated (high or low frequency) disturbances may
be applied from or towards the fixed installation (power supply port, control and
telecommunication ports etc.);
3.2.4.4 Modeling and simulation
In recent years Computational Electromagnetic Modelling (CEM) codes and bespoke simulation tools
such as those based on topological processes have become more readily available. These modelling
and simulation tools can be used for carrying out detailed modelling and analyses of complex
electromagnetic problems such as; induced currents and voltages in wires, conduits, LRU cases, and
various structural components. The development of three-dimensional computer codes that can be run
on machines of increasing speed and efficiency now has made such analyses viable.
Whilst CEM and simulation tools are unable to directly compute the magnitude of emissions or the
immunity of a modelled or simulated apparatus or installation, these tools capable of providing support
to the overall analysis. Some examples where modelling and simulations support has been shown to
be useful are:
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a) defining and selecting the optimum test methodologies (time and cost),
b) assessing the completeness and validity of the test results (i.e., assessing the impact of the
approximations made during testing),
c) assessing how small design changes between equipment variants may impact on compliance,
d) spectrum utilisation assessment.
In this way modelling and simulation methods can be used to produce evidence of compliance. The
use of modelling and simulation methods is well established and used by civil aircraft equipment
manufacturers [ref: ED107]. The rationale for the use and selection of CEM methods depends on
many factors, not least, the maturity and complexity of the project and a cost/benefit assessment.
3.2.4.5 Design evidence
A manufacturer may wish to declare the conformity of his apparatus or installation directly to the
protection requirements, without reference to harmonised standards, by making his own EMC
assessment based on peculiar design techniques, good engineering practices or on specific mitigation
and control measures he may have implemented. This assessment needs to follow a technical
methodology to ensure that the re
...
SLOVENSKI STANDARD
oSIST-TP CLC/prTR 50538:2009
01-julij-2009
Vodilo za skladnost opreme za vojaške namene z direktivo EMC
Guide to EMC Directive conformity of equipment designed for military purposes
Ta slovenski standard je istoveten z: CLC/prTR 50538:2009
ICS:
33.100.01 Elektromagnetna združljivost Electromagnetic compatibility
na splošno in general
95.020 Vojaška tehnika. Vojaške Military engineering. Military
zadeve. Orožje affairs. Weapons
oSIST-TP CLC/prTR 50538:2009 en
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.
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oSIST-TP CLC/prTR 50538:2009
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oSIST-TP CLC/prTR 50538:2009
DRAFT
TECHNICAL REPORT
CLC/prTR 50538
RAPPORT TECHNIQUE
May 2009
TECHNISCHER BERICHT
ICS Will supersede R210-008:2002
English version
Guide to EMC Directive conformity
of equipment designed for military purposes
This draft Technical Report is submitted to CENELEC members for comments prior to the voting meeting.
Deadline for CENELEC: 2009-09-04.
It has been drawn up by CLC/TC 210.
CENELEC members are the national electrotechnical committees of Austria, Belgium, Bulgaria, Cyprus, the
Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Latvia,
Lithuania, Luxembourg, Malta, the Netherlands, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain,
Sweden, Switzerland and the United Kingdom.
Warning : This document is not a Technical Report. It is distributed for review and comments. It is subject to
change without notice and shall not be referred to as a Technical Report.
CENELEC
European Committee for Electrotechnical Standardization
Comité Européen de Normalisation Electrotechnique
Europäisches Komitee für Elektrotechnische Normung
Central Secretariat: Avenue Marnix 17, B - 1000 Brussels
© 2009 CENELEC - All rights of exploitation in any form and by any means reserved worldwide for CENELEC members.
Project: 21471 Ref. No. CLC/prTR 50538:2009 E
Draft for Enquiry
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oSIST-TP CLC/prTR 50538:2009
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1 Foreword
2 This draft Technical Report was prepared by the Technical Committee CENELEC TC 210,
3 Electromagnetic compatibility (EMC).
4 It is circulated for comments prior to the voting meeting foreseen on 2009-12-03 in accordance with
5 the Internal Regulations, Part 2, Subclause 11.4.3.2 (simple majority).
6 This document will supersede R210-008:2002.
7 __________
Draft for Enquiry
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8 Contents
9 Introduction . 5
10 1 Scope . 6
11 2 Directives for EMC conformity . 6
12 2.1 EMC Directive . 6
13 2.2 Automotive Directive . 6
14 2.3 Marine Equipment Directive . 7
15 2.4 Radio & Telecommunication Terminal Equipment Directive . 7
16 3 Introduction to apparatus and installations . 7
17 4 Apparatus . 8
18 4.1 Conformity assessment procedure . 8
19 4.2 EMC assessment . 8
20 4.3 Gap analysis . 9
21 4.4 Operating conditions and configurations .10
22 4.5 Technical documentation.10
23 4.6 Notified body involvement .11
24 4.7 Declaration of conformity .11
25 4.8 CE marking .11
26 5 Fixed installations .11
27 5.1 Conformity assessment procedure .11
28 5.2 Essential requirements for fixed installations .12
29 5.3 Specific apparatus .12
30 5.4 Responsible person .12
31 Annex A Article 296 of the Treaty (TEC) .13
32 A.1 Legal basis .13
33 A.2 Security interests and treaty obligations .13
34 A.3 Conditions of applications of Article 296 TEC (according to interpretative
35 communication COM(2006) 779 final .14
36 A.4 How to apply Article 296 TEC .14
37 Annex B Council Decision 255/58 – EC Council list of items defining the scope of
38 Article 223 of the Treaty of Rome .15
39 Annex C Environments .17
40 C.1 Military standards and environments .17
41 C.2 Harmonised standards and environments .18
42 C.3 Selection of applicable standards for the EMC assessment .19
43 Annex D Flow diagram for apparatus .21
44 Annex E Flow diagram for fixed installation/specific apparatus .22
45 Annex F Read across tables between military and harmonised standards (Test method
46 level) .23
47 Annex G Comparison of EMC test methods .24
48 Annex H Examples of gap analysis .33
49 Annex I Case studies .35
50 Bibliography .36
51 Standards .36
52 Other documents .37
53
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54 Figures
55 Figure D.1 – Flow diagram for apparatus .21
56 Figure E.1 – Flow diagram for fixed installation/specific apparatus .22
57 Figure H.1 – Example of Radiated Emissions Gap Analysis between AECTP501 NRE02.1 Land
58 army and Class A Emissions where the Military Standard is more onerous (Class A limit
59 modified for comparison) .33
60 Figure H.2 – Example Radiated Emissions Gap Analysis between AECTP501 NRE02.1 Sea
61 Below Deck and Class B Emissions where the Military Standard is less onerous (Class B
62 limit modified for comparison) .33
63 Figure H.3 – Example of Radiated Immunity Gap Analysis between AECTP501 NRS02.1 Ground
64 and ‘Industrial’ Immunity Limit where the Military Standard is more onerous (Industrial limit
65 modified for comparison) .34
66 Figure H.4 – Example of Power/Signal Port Conducted Immunity Gap Analysis between
67 AECTP501 NCS07.1 Ground and ‘Industrial’ Immunity Limit where the Military Standard is
68 less onerous over part of the frequency range (Industrial limit modified for comparison) .34
69
70 Tables
71 Table F.1 – Factors to be considered during an EMC gap analysis .23
72 Table G.1 – Comparison of EMC test methods .24
73 Table G.2 – Detailed comparison of EMC test methods .25
74
75
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76 Introduction
77 CENELEC R210-008:2002 has been updated and revised with regard to the EMC Directive
78 2004/108/EC to create this new Technical Report, CLC/TR 50538 “Guide to EMC Directive conformity
79 of equipment designed for military purposes”. The EU Interpretative Communication COM (2006) 779
80 final [5] on the application of Article 296 TEC to military equipment has also been used to clarify the
81 current position regarding possible exemption by derogation.
82 Guidance is provided on EMC Directive conformity to manufacturers, suppliers, importers,
83 procurement authorities, those taking equipment into service and Member States.
84 This Technical Report has been prepared by reviewing all currently available relevant documentation
85 as listed in Bibliography.
86 A Technical Report was produced by CLC/TC 210 (EMC) in 1998 in order to provide guidance to
87 manufacturers of military equipment comply with the EMC Directive 89/336/EEC [6]. Under this
88 Directive 89/336/EEC there were exceptions at Member State level which resulted in a non-
89 harmonised application of the directive by military equipment manufacturers across the EU.
90 The current EMC Directive, 2004/108/EC [13], does not contain any reference to military equipment
91 and therefore the rules of the ‘Treaty’ have to be consulted with respect to application of the EMC
92 Directive.
93 An interpretative communication was issued in late 2006 which addressed the issue above and
94 removed any ambiguity. It concludes that all military equipment is subject to the rules of the EU
95 regarding the procurement of equipment unless the application of a given directive has been
96 derogated on the basis of the ‘essential interests of National security’.
97 The conclusion from the Commission lawyers (validated in a court case between the Commission and
98 a Member State) is very specific and concludes that the exceptions are very few. They will have to be
99 assessed on a case-by-case basis by the contracting authority.
100 Given the Commission interpretation, the vast majority of military equipment requires CE marking and
101 as a consequence CLC/TR 50538 will become an important guide for European defence equipment
102 manufacturers.
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103 1 Scope
104 This Technical Report is applicable to any equipment used for military purposes.
105 It applies only to non-battlefield environments.
106 It considers the situation where derogation has not been granted and covers only aspects related to
107 EMC as covered by the EMC Directive 2004/108/EC and other directives that address EMC. In this
108 respect there is no distinction between civilian and defence equipment.
109 For the purpose of this Technical Report the term “military” is equivalent to the term “defence”.
110 Annex A describes Article 296 and Annex B provides the associated EC Council List of items under
111 Article 296 [6].
112 The definitions in EMC Directive 2004/108/EC of “apparatus” and “fixed installations” as applied to
113 military equipment are considered and guidance is given on applicability with the use of flow diagrams.
114 For apparatus, the use of military standards to demonstrate compliance with the EMC Directive
115 together with a “gap” analysis tool for comparison with harmonised standards is presented. Potential
116 shortfalls are identified.
117 For fixed installations using military equipment, the use of good engineering practices, to comply with
118 the essential protection requirements of EMC Directive 2004/108/EC additionally the impact on
119 neighbouring environments is covered.
1)
120 The CEN WS 10 EG7 E3 has been reviewing the EU Electromagnetic Environment for inclusion in
121 the “European Handbook for Defence Procurement” (CWA 15517 [3]). The information contained in
122 their report has been used and incorporated where applicable.
123 The conformity assessment procedures of EMC Directive 2004/108/EC have been reviewed and
124 guidance given on the applicability and contents of a technical file.
125 Annex I includes some case studies to help clarify the extent and use of this Technical Report.
126 2 Directives for EMC conformity
127 2.1 EMC Directive
128 The EMC Directive applies to the majority of military equipment. The conformity procedures are
129 detailed in 4.1 and 5.1.
130 The EMC Directive makes specific exemptions for radio equipment and telecommunications terminal
131 equipment covered by Directive 1999/5/EC [9], aircraft or equipment fitted to aircraft referred to in
132 Regulation (EC) No. 1592/2002 [10], radio amateur equipment and inherently benign equipment.
133 2.2 Automotive Directive
134 In the case of vehicles intended for use on public roads, the Automotive EMC Directive
135 2004/104/EC [12] applies to cars, trailers and their electronic sub-assemblies, and in time other on-
136 highway vehicles. Compliance with Directive 2004/104/EC is demonstrated by affixing ‘e-marking’ to
137 the equipment or vehicle.
)
1
CEN: European Committee for Standardisation, Workshop 10: Standardization for Defence Procurement,
EG7: Expert Group 7: Electromagnetic Environment
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138 2.3 Marine Equipment Directive
139 In the case of marine equipment, the Directive 96/98/EC [8] amended by Directives 98/85/EC,
140 2001/53/EC and 2002/75/EC applies International Maritime Organisation (IMO) standards to assess
141 the compliance of equipment related to safety at sea (navigation and radio communications) and
142 pollution prevention. This is a type approval process and compliance with the directive is
143 demonstrated by affixing “wheelmark” to such equipment. All non-safety and pollution prevention
144 equipment are assessed following the EMC Directive 2004/108/EC.
145 2.4 Radio & Telecommunication Terminal Equipment Directive
146 As noted above, all equipment in the scope of the R&TTE Directive 1999/5/EC [9] is excluded from the
147 EMC Directive. The EMC aspects of equipment within the scope of the R&TTE Directive are covered
148 by that Directive. It follows that equipment that falls outside the scope of the R&TTE Directive is
149 therefore within the scope of the EMC Directive.
150 In particular, the R&TTE Directive does not apply to apparatus exclusively used for activities
151 concerning public security, defence, state security and activities of the state in the area of criminal law.
152 Accordingly, military radios used solely by state armed forces are subject to the EMC Directive. It is
153 important to note that such use must be exclusive. If these radios are also sold to private security
154 operations or to disposal for public use, they are regulated under the R&TTE Directive and not the
155 EMC Directive. For example, TETRA systems that are widely used by public authorities are subject to
156 the R&TTE Directive because they are not exclusively used for the activities excluded from its scope.
157 3 Introduction to apparatus and installations
158 In order for military equipment to comply with the EMC Directive it is first important to understand the
159 different types of products covered. In essence the EMC Directive covers equipment which is divided
160 in apparatus and fixed installations and defines a different regime for these two categories.
161 The following definitions are extracted from the EMC Directive 2004/108/EC, Article 2, for clarification
162 on the two types of equipment/system covered by the directive:
163 (b) ‘apparatus’ means any finished appliance or combination thereof made commercially available as a single
164 functional unit, intended for the end user and liable to generate electromagnetic disturbance, or the
165 performance of which is liable to be affected by such disturbance. Apparatus is subject to the full
166 provisions of the directive including a Declaration of Conformity (DoC) and CE marking;
167 (c) ‘fixed installation’ means a particular combination of several types of apparatus and, where applicable,
168 other devices, which are assembled, installed and intended to be used permanently at a predefined location;
169 Fixed installations do not require a DoC or CE Marking but must meet the protection requirements.
170 In the special case of apparatus intended for incorporation into a specific fixed installation which is
171 otherwise not commercially available the provision of Article 13(1) of the EMC Directive may be
172 applied. This apparatus does not need to be CE marked but must be supplied with installation
173 instructions that ensure the essential protection requirements. This provision is only for an individual
174 apparatus intended for a specific fixed installation.
175 The protection requirements of the directive are the same for both apparatus and fixed installations
176 such that
177 a) the electromagnetic disturbance generated does not exceed the level above which radio and
178 telecommunications equipment or other equipment cannot operate as intended,
179 b) it has a level of immunity to the electromagnetic disturbance to be expected in its intended use
180 which allows it to operate without unacceptable degradation of its intended use.
181 Mobile installations are defined as a combination of apparatus intended to be moved and operated in
182 a range of locations. All provisions of the EMC Directive, as defined for apparatus, apply to mobile
183 installations.
184 Mobile installations may be interpreted to include demountable rack offload and pickup system
185 (DROPS) containers, portable generators, vehicles, ships, submarines and military aircraft.
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186 4 Apparatus
187 4.1 Conformity assessment procedure
188 This subclause describes the conformity assessment procedure for military apparatus falling within the
189 scope of the EMC Directive.
190 The conformity assessment procedure for apparatus is described in Article 7 of the EMC
191 Directive 2004/108/EC. Comprehensive guidance is provided in the “Guide for the EMC Directive
192 2004/108/EC” [14].
193 This conformity assessment procedure applied to military apparatus is given in Figure D.1.
194 The flowchart illustrates the normal conformity assessment procedure for apparatus including the use
195 of harmonised standards and also highlights the opportunity to perform a gap analysis between
196 military compliance and EMC Directive essential requirements to prevent unnecessary duplication of
197 testing.
198 4.2 EMC assessment
199 The EMC Directive requires an EMC assessment of the apparatus to determine if the protection
200 requirements are met. The EMC assessment is described in the conformity assessment procedure for
201 apparatus given in Article 7 and Annexes I, II and III of the EMC Directive 2004/108/EC.
202 According to the “Guide for the EMC Directive 2004/108/EC” [14], three methods are possible for the
203 EMC assessment and their application in the context of military equipment is discussed below:
204 • use of harmonised standards;
205 • mixed EMC assessment;
206 • detailed technical EMC assessment.
207 4.2.1 Use of harmonised standards
208 Harmonised standards are published in the Official Journal of the EU. Apparatus that complies with
209 harmonised standards has a presumption of conformity with the protection requirements of the EMC
210 Directive. However there are currently no harmonised standards specifically for military equipment. An
211 alternative is to select relevant harmonised standards based on the equipments use. These are
212 discussed in Annex C.
213 4.2.2 Mixed EMC assessment
214 A mixed EMC assessment is where parts of a harmonised standard have been applied together with a
215 technical assessment to demonstrate that all the protection requirements are met. A more detailed
216 description of the technical EMC assessment is given in 4.2.3. The technical assessment may include
217 a gap analysis between the military compliance and EMC Directive protection requirements. Gap
218 analysis is described in 4.3.
219 4.2.3 Detailed technical EMC assessment
220 A detailed technical EMC assessment is where no harmonised standard has been applied but a
221 detailed assessment performed instead.
222 Annex IV(1) of the EMC Directive 2004/108/EC, states that this includes
223 • steps taken to meet the protection requirements,
224 • description of the electromagnetic assessment,
225 • results of design calculations (it is suggested by this guide that this could include modelling and
226 simulation),
227 • examinations carried out,
228 • test reports.
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229 The “Guide for the EMC Directive 2004/108/EC” [14] adds that the assessment required will depend
230 on several factors, such as
231 • nature of apparatus,
232 • intended use,
233 • location of use,
234 • EMC environment,
235 • types of disturbance created by or affecting the apparatus,
236 • environmental conditions,
237 • performance criteria for immunity.
238 The technical assessment may include a gap analysis between the military standards and harmonised
239 standards applicable to meeting the EMC Directive protection requirements. Gap analysis is described
240 in 4.3.
241 4.3 Gap analysis
242 The gap analysis process may be used in the mixed and detailed technical EMC assessment and
243 identifies any shortfalls in the EMC performance of the military equipment against the EMC Directive
244 protection requirements. In order to achieve this, the EMC standards, test methods and limits applied
245 to the military equipment must be identified and compared to the equivalent harmonised standard, test
246 methods and limits that represent the intended environments in which the military equipment is
247 operated. The first stage is therefore to align test methods that address similar EMC phenomena.
248 The “Report of the CEN WS 10 EG7 ‘Electromagnetic environment’” [4] provides such a comparison
249 table in its Appendix C. The table has been updated in this Technical Report and included in Annex G
250 (see Table G.1).
251 The detailed comparison of test methods is complex and guidance on the relevant factors to be
252 considered is given in Annex F (see Table F.1).
253 The comparison factors must be quantified and then used to modify the test methods and limits being
254 compared. Either the military standard or harmonised standard limit is modified to allow both sets of
255 limits to be presented on a single graph or table using common units of frequency/amplitude or
256 time/amplitude.
257 From this comparison the differences in frequency range, time scale or amplitude can be quantified.
258 Examples of gap analysis are shown in Annex H.
259 Where the military test method and limit is more onerous than the harmonised standard equivalent
260 then this demonstrates that the military equipment is in conformity with the harmonised standard test
261 method and limit.
262 Where the military test method and limit is less onerous than the harmonised standard equivalent then
263 this demonstrates a shortfall or gap against the required conformity with the harmonised standard test
264 method and limit.
265 Note that for emission tests a shortfall identified by comparing military and harmonised standard test
266 method and limits may be mitigated by considering the actual military equipment test result and the
267 margin by which it is below the emissions limit. If this margin is greater than the shortfall at the relevant
268 frequencies then this information demonstrates that the harmonised standard test method and limit
269 would have been met.
270 Once the gaps and missing tests have been identified, they can be addressed by application of
271 relevant harmonised standards or basic standards through test or analysis of the military equipment.
272 The gap analysis and any additional test or analysis against harmonised standards should then
273 demonstrate overall that the military equipment is in conformity with the protection requirements of the
274 EMC Directive for all relevant EMC phenomena.
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275 4.4 Operating conditions and configurations
276 The EMC assessment described in Annex II of the EMC Directive 2004/108/EC requires all normal
277 intended operating conditions and configurations to be taken into account.
278 For military equipment, the operating conditions relevant to operation in all non-battlefield
279 environments should be taken into account. Where operating conditions are only intended for a
280 military ‘battlefield’ environment, (i.e. the operating condition intentionally breaches the essential
281 requirements of the EMC Directive), then these operating conditions should be identified and declared
282 not applicable to the conformity assessment.
283 Examples of operating conditions that may not be applicable to the EMC Directive conformity
284 assessment procedure are
285 • electronic counter measures transmission,
286 • radio frequency weapon, high power microwave transmission,
287 • radio frequency weapon, ultra wideband transmission.
288 4.5 Technical documentation
289 The manufacturer draws up technical documentation (a Technical File) as described in Annex IV of the
290 EMC Directive 2004/108/EC, providing evidence of the conformity of the equipment with the essential
291 requirements of the Directive. The purpose of the technical documentation is to enable the conformity
292 of the equipment with the protection requirements to be assessed. The following is an example of the
293 content of a Technical File:
294 • an identification of the equipment covered by the technical documentation. This identification
295 should allow unambiguously linking between the technical document and the equipment;
296 • a general description of the equipment. The amount of information required will depend on the
297 complexity of the equipment, simple apparatus may be fully defined in one line whereas more
298 complex fixed installation may need a complete description (a picture may be included);
299 • consideration of applicable military/non-battlefield operating environments and hence the required
300 standards to represent the environment;
301 • consideration of relevant modes of operation and configurations
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