Report of the Strategic Review Panel

of EMC Harmonised Standards

Management Summary
The Strategic Review Panel (SRP) of EMC harmonised standards had been set up following a request
from the Commission dated 1999-04-19, resulting from Recommendation 16 of the SLIM EMC
exercise.

Its purpose and task were to examine the EMC standardisation system and to prepare recommendations
for its improvement in respect of coherence, consistency, simplification and avoidance of proliferation.

All parties involved in the broad spectrum of standardisation participated to the SRP activities:
Commission, Member States, Industry, Competent Bodies, EMC Consultant and Standardisation
Institutes.

The SRP held five meetings from October 1999 to November 2000 and set up 3 ad hoc groups to
elaborate proposals for specific topics.

The outcome of its work is twofold:

- On the one hand it shows that the standardisation activities, which had to base themselves on an
existing, pretriggered situation of disharmony has made the best out of it in order to ensure
coherence and consistency. The initial apparent proliferation of standards has come to a point of
saturation. The hierarchical structure of standards is consistent.
- On the other hand there is space for improvement. The standardisation system requires transparency
and openness, especially in terms of use of the standards and their link to products. It should also be
envisaged to prepare a future single generic emission standard.

The SRP has translated the result of their activities into the following recommendations:

Recommendation 1 (transparency and openness):

CENELEC Reports R210-001 "Guide on EMC standardisation for Product Committees" and
R210-007 "Report on the use of standards for the implementation of the EMC Directive" should
be made available, free of charge, on the CENELEC Website.

Recommendation 2 (future single generic standard):

It should be envisaged to prepare a future single generic emission standard in accordance with the
framework as set out under clause 5.3 of the SRP report.
This task should have a high priority.

Recommendation 3 (hierarchical structure of standards):

The principle of product (family) standards taking precedence over generic standards is to be
kept.

Recommendation 4 (phenomena):
Phenomena and their selection belong to the standardisation field and should not form part of the
EMC Directive.

Report of the Strategic Review Panel of EMC Harmonised Standards 1

Recommendation 5 (immunity standards):
There is a definite need for immunity standards.

Recommendation 6 (immunity approach):

There is no incentive for modifying the approach towards immunity.

Recommendation 7 (proliferation):
Noting that
• the number of harmonised standards is stabilising
• only a limited number of Product Committees has prepared multiple product standards
• there are at present only 7 basic standards used in the legal framework
the SRP concluded that there is no real proliferation of standards and that hence no specific action
other than possible regrouping of product requirements is to be undertaken.

Recommendation 8 (management and inconsistencies):

The advice as expressed by CLC/TC 210/SOG and by the EMC Consultant on the suitability of
product (family) standards as harmonised standards under the EMC Directive should be more
closely followed.

Recommendation 9 (link product-standard):

The cross-reference list of products and their related harmonised standards is to be kept regularly
updated.

Recommendation 10 ("under consideration" clauses):

CENELEC should apply the principle that "under consideration" clauses in EMC draft standards
can only be allowed up to the CENELEC enquiry stage and should hence be removed before the
voting stage. IEC should be invited to apply the same principle, this in view of parallel procedures
on IEC drafts.

Report of the Strategic Review Panel of EMC Harmonised Standards 2

1 Purpose and task
The Strategic Review Panel (SRP) of EMC harmonised standards had been set up following a request
from the Commission as a result of Recommendation 16 of the SLIM EMC exercise. Its purpose and
task are clearly set out in the letter dated 1999-04-19 from the Commission to the CENELEC President
(see annex A).

2 Participation
All parties identified by Recommendation 16 actively participated to the SRP.

It was chaired by Mr Kaiser (ORGALIME) with Mr Vetsuypens (CENELEC Central Secretariat) as

Secretary.

Its members were:

Mr Anselmann (European Commission), Mr Bartak (CENELEC), Mrs Baumier-Duphil (CENELEC),

Mr Coenraads (Member States), Mr Cumps (CENELEC), Mr De Vré (EMC Consultant), Mr Farrell
(CENELEC), Mr Garvert (Member States), Mr Gemma (ETSI), Mr Groot Boerle (CENELEC),
Mr Gutierrez Iglesias (CENELEC), Mr Imeson (Member States), Mr Isnard (CENELEC), Mr Kerry
(CENELEC), Mr Kohling (CENELEC), Mr Kontolatos (Member States), Mr Lanne (CENELEC),
Mr Leferink (Industry - ORGALIME), Mr Lightfoot (ETSI), Mr Linnert (Competent Bodies),
Mr O'Dwyer (CENELEC), Mr Pandini (CENELEC), Mr Rahmes (Member States), Mr Sanhet
(CENELEC), Mr Scott (Industry - EICTA), Mr Sepka (Member States), Mr Sisolefsky (ETSI), Mr Start
(Industry - EURELECTRIC), Mr Storrs (ETSI), Mr Stratigoulakos (Member States), Mr Ulzurrun
(European Commission), Mr Van der Giessen (Industry - CELMA), Mr Verholt (CENELEC),
Mr Vivero (Member States), Mr Vrolijk (CENELEC) and Mr Wolf (CENELEC).

3 Terms of reference
The SRP Terms of Reference were in line with the objectives as set out by the Commission in their
initial request. The group however decided to delete "To identify needs regarding transitional regimes
and ensuring required changes" as this aspect is already duly covered by the transitional arrangements
linked to the publication method of the harmonised standards in the OJEC (date of cessation of the
superseded harmonised standard).

4 Ad hoc groups
In order to prepare the SRP report, three ad hoc groups were set up, with the following terms of reference
and membership. The outcome of the work of these groups formed the basis for the SRP work.

4.1 SRP AHG 1

"To address the problem of diverging environments and classes of emission, and to prepare a proposal
which will improve the coherence of environments and classes of emission, in particular between
CISPR 11 and 22 and the generic standards. To look at the required number of environments and assess
the pros and cons of foreseeing possibly only 1 environment in the future."

Members: Mr Kerry (Convenor), Mrs Baumier, Mr De Vré, Mr Kohling, Mr O'Dwyer, Mr Sisolefsky

and Mr Vrolijk.

Report of the Strategic Review Panel of EMC Harmonised Standards 3

4.2 SRP AHG 2

"To prepare a paper describing the current status of the generic standards and their relationship to
product standards. This in the context of a situation where it would be up to the manufacturer to decide
to use the generic standards as an alternative to the dedicated product standards (duly noting however
that the generic standards are more or less complete/sufficient but that there is a gap above 1 GHz)."

Members: Mr Linnert (Convenor), Mr Coenraads, Mr De Vré, Mr Leferink, Mr Verholt and Mr Vrolijk.

4.3 SRP AHG 3 (Framework of generic standards)

"To prepare a framework proposal regarding a possible future single generic emission standard, bearing
in mind in particular following principles:
• how can this generic standard be more complete/universal?
• what formalities are necessary to offer more freedom to the user when selecting different options and
related limits from this generic standard?
• what limits are foreseen?
• what (kind of) phenomena are to be included?
and with the understanding that this generic standard contains all emission requirements (radiated and
conducted)."

Members: Mrs Baumier (Convenor), Mr Bartak, Mr Coenraads, Mr De Vré, Mr Farrell, Mr Gemma,

Mr Groot Boerle, Mr Kaiser, Mr Kohling, Mr Leferink, Mr Lightfoot, Mr Ochel, Mr O'Dwyer, Mr Scott,
Mr Sepka and Mr Vrolijk.

5 Recommendations and their rationale

5.1 Transparency and openness

5.1.1 Some criticism had been expressed regarding transparency and openness of the EMC
standardisation system, particularly in respect of the types of electromagnetic disturbance covered by the
standards, in terms of electromagnetic environments and compatibility levels, types of standards, tables
of standards by type, ...

It was confirmed that nearly all of these topics are already covered in different publications:

- R210-001 "Guide on EMC standardisation for Product Committees"

This document explains the EMC standardisation structure i.e. basic, generic and product (family)
standards and the involved precedence over each other.
- R210-007 "Report on the use of standards for the implementation of the EMC Directive".
- EG 201450 "Guidance on the identification of Harmonised Standards and/or other technical
specifications for R&TTE covering requirements under Article 3.1 of Directive 1999/5/EC" which
contains useful information on EMC standardisation.

ETSI offers free access to EG 201450 on their Website.

The SRP made a plea for having both R210-001 and R210-007 on the CENELEC Website with free
access.

5.1.2 The Commission is requested to possibly look into the matter of either introducing a note to the
consolidated list of harmonised standards explaining that these guides are available or putting a hint on
their homepage.

Report of the Strategic Review Panel of EMC Harmonised Standards 4

5.1.3 It was reconfirmed that these guides should not have an EN status.

5.1.4 Further on it was proposed that any deviation in product (family) standards from the future generic
standard(s) will have the justification for the deviation documented in a technical report.

Recommendation 1 (transparency and openness):

CENELEC Reports R210-001 "Guide on EMC standardisation for Product Committees" and
R210-007 "Report on the use of standards for the implementation of the EMC Directive" should
be made available, free of charge, on the CENELEC Website.

5.2 Emission environments and classes

The definitions of classes A and B as referred to in CISPR documents (see CISPR 11/EN 55011 and
CISPR 22/EN 55022) are different from those of the generic standards. Whilst for EN 55011 the
difference is minimal, EN 55022 is deviating in the sense that use of Class A equipment is not forbidden
in a domestic environment.

Whilst, in theory, this situation may cause problems to national authorities for the enforcement of the
EMC Directive, the SRP noted that there are no complaints from the market regarding classes and that
therefore a careful approach when possibly revising the environment/class approach should be borne in
mind.

5.3 Single generic emission standard

5.3.1 History of generic standards

The essential requirements of the EMC directive imply that in a given environment, the emission of
disturbances is limited in order to achieve electromagnetic compatibility in this environment. For this
reason and because of the short delay given to the manufacturers before the application of the EMC
directive, the generic standards were created rapidly to define the levels of disturbances for immunity
and emission, phenomenon by phenomenon, so that manufacturers could use in practically all cases
the conformity assessment according to article 10.1, using only harmonised standards.

Historically the generic emission standards were developed rapidly to fill a gap in the European
standardisation in view of the application of the EMC directive and they have fulfilled and continue to
fulfil successfully this function.

It is time now to review fundamentally these existing generic emission standards, with the aim of
defining a more universal single generic emission standard covering the complete frequency range and
all the concerned ports of equipment.

5.3.2 Are generic emission standards needed?

The essential requirements of the EMC directive imply that in one given environment, the limiting of
emissions for each piece of equipment, having the same type of operating characteristics and intended
for the same environment, is defined equitably. Therefore a generic emission standard should specify
equal limits for all equipment having similar operating characteristics and intended for the same
environment, particularly with respect to its contribution to the cumulative disturbance level in low-
frequencies ( below 9kHz).

Report of the Strategic Review Panel of EMC Harmonised Standards 5

It is the view of the SRP that the availability of a more complete and more universal single generic
emission standard would constitute an important progress for future EMC standardisation, as it would
enhance the role and practical use of this generic standard and help to improve the co-ordination of the
EMC standardisation. It follows that different sets of limits may be defined for equipment according
to the characteristics and operating environment without compromising the essential requirement
necessary to protect the radio spectrum and telecommunications and power networks.

In this fundamental revision, the following important factors of the technical evolution should be taken
into consideration:
• rapid evolution and expansion of radio and telecommunications services and need to protect them,
considering also future spectrum use for radio and telecommunication services,
• increasing use of electronic converter devices to energise equipment from public supply networks,
• evolution of equipment towards multifunction and multimedia, making the use of product oriented
standards sometimes problematic and ambiguous The «sectoral» product family orientated
approach, which needs clear and unambiguous scopes, may be in reality outdated due to the
evolution of these new categories of products,
• evolution towards less differentiation of equipment used in different electromagnetic environments,
due to the extensive use of communication services everywhere.

5.3.3 Relationship of generic emission standards with other EMC standards - Present situation

The following explanation is based on the present procedures used in CENELEC, ETSI and IEC, and
defined in CENELEC report R210-001 and IEC Guide 107. This is completed by proposals of the SRP
for the future given in the next part 5.3.4.

The basic EMC standards describe the measurement methods for each phenomenon or set down
compatibility levels as the reference values for co-ordinating emission and immunity limits. Since
harmonised standards specify the limits corresponding to the protection requirements, the basic standards
are not harmonised standards for the purpose of the EMC directive. Instead, they are considered as
standardisation tools and are used as normative references in the harmonised standards, i.e. in the
generic, product and product family standards.

The generic emission standards are applicable to products not covered by specific product or product
family standards. In addition, they have a horizontal role in defining the necessary protection level for
the given environment, and take into account the cumulative effects of emissions. Therefore they provide
reference levels against which product standards are verified.

The Strategic Review Panel has confirmed (see 5.4) that as long as the generic emission standards are
not revised fundamentally, the precedence principle of product standards over generic standards (see
CLC reports R210-001 and 007) will not be modified.

It is not advisable to propose a framework for a future generic emission standard without carefully
considering the entire structure of EMC standardisation, in particular the relationship between generic
and product (family) EMC standards.
This is the purpose of the following part 5.3.4.

5.3.4 How should the limits defined in a future single generic emission standard be used in the
future EMC Product standards ?

The following considerations will apply after a new generic emission standard is published in
accordance with the proposals and framework presented in the present document.

Report of the Strategic Review Panel of EMC Harmonised Standards 6

5.3.4.1 Generic standard as the reference for the product standards

The future generic standard shall give the emission limits which achieve the minimum protection of
the environment. The general rule is that all product standards for emission shall not include more
relaxed limits, for all phenomena covered by the generic standard, than the limits defined in the
generic standard. However in particular cases, exceptions may exist (see 5.3.4.2) where more relaxed
limits or more stringent limits are necessary. A future generic emission standard will be essential to
guarantee the equity between standards created by Product committees.

Product emission standards should not be developed unless deviating requirements are necessary and/or
specific test conditions are required.

For emission, the EMC product standards (or product family standards) shall normally make reference
to the generic standards for the values of the limits for all phenomena relevant to the product, and shall
describe the operating conditions for the equipment and give references of the test methods.

5.3.4.2 Collection of justification of exceptions

Product Committees may propose more relaxed limits or more stringent limits according to the strict
co-ordination rules for EMC fixed in the various standardisation bodies.

Any deviation from a future generic emission standard should be justified and reported at least for the
purpose of approval and voting by the National Committees. The rationale for the deviation should be
given in an informative annex to inform the users and the National Committees.

To give background information, it will be necessary to create a guide or technical report where all the
exceptions will be referenced with the reasons justifying the exception (CISPR H has an approved
NWIP on this subject, proposing to publish a technical report). This guide will record both types of
exceptions:
• less stringent limits with the justifications
• more stringent limits with the justifications.

Proposed action:
CLC, CEN and ETSI to contribute in IEC to the elaboration of this technical report compiling all the
exceptions and the justifications.

5.3.4.3 Evolution of the product standards

The scope of the EMC product standards shall be clear and without ambiguities.

The product standards should be amended so that they cover, where necessary, the same frequency
ranges as the generic standards.

NOTE For European standards this will avoid the problem of the meaning of the "date of cessation of
presumption of conformity of superseded standards" which would arise if limits in a new frequency range were
to be published in a new standard, which did not supersede any other standard. The generic and product
standards would simply be amended to include the new limits or make reference to the new standard in which
they are specified.

Since only one complete emission standard would need to be applied to any given product, it would
then be very straightforward for the manufacturer to identify the applicable standard according to the
order of precedence: at present, product, product family, generic.

Report of the Strategic Review Panel of EMC Harmonised Standards 7

5.3.5 Proposition of structure for a single generic emission standard

5.3.5.1 Scope

A new generic emission standard should cover all the emission requirements for electromagnetic
disturbances in the whole frequency band (0 to 400 GHz), including low-frequency (0 to 9kHz) and
high frequency (9kHz to 400GHz), conducted as well as radiated. Clicks should also be covered when
appropriate.

The requirements of the generic standard are intended to be used as reference for development and
modification of product family standards or of product standards.

The requirements of the generic standard are applicable to each equipment not covered by a product
family standard, or a product standard.

5.3.5.2 Ports

The standard should be based on a port approach with, for each case, one (or sometimes several)
measurement method and corresponding limits.

All foreseeable ports liable to generate disturbances should be included for conducted emission (mains
supply input and output, DC power supply and output, load terminals, telecommunication terminals,
other signal or terminal ports...) and for radiated emission (enclosure...). The emission from the
antenna port and the radio enclosure of radio equipment are not included, as these are used for radio
frequency spectrum management purposes and are the responsibility of ETSI.

The standard should give information on the applicability of limits/requirements at the ports (for
example on the basis of length of cabling indicated in manufacturer’s instructions and /or on the basis
of type of cables required in the manufacturer’s instructions, etc.).

5.3.5.3 Type and numbers of environments to be considered

The generic standard shall keep the number of classes of limits to a minimum. The relationship
between these classes of limits and the application of equipment in a particular environment shall be
clearly defined with the view of being adopted later in a co-ordinated manner by product-family
standards and product standards in a uniform way.

All EMC product standards should normally refer to this relationship without introducing their own
rules.

Regarding radiated emissions, as the differentiation of environments is becoming less clear with the
evolution of new technologies, the possibility to have only one type of environment and a
corresponding set of limits (with very few exceptions) should be seriously considered in this case.
Industrial applications shall also be seriously considered for the possibility of adapted solutions.

For radiated disturbances at frequencies between 30 MHz and 1 GHz, present inconsistencies arise
from the differences in the ways in which the limits (classes) are associated with different
environments in the various standards. Since the harmonised immunity standards require immunity to
field strengths, which are orders of magnitude higher than the emission limits, the controlling factor is
the proximity of radio-communications receivers.

Report of the Strategic Review Panel of EMC Harmonised Standards 8

For conducted phenomena, the environments should be determined by the network to which the
equipment is connected (electricity supply network, telecommunication network). The definition of
the environment ought to be different whether LF phenomena are concerned or HF phenomena are
concerned.

5.3.5.4 Which phenomena should be covered by a future generic emission standard ?

The phenomena covered should at least be the same as in the present generic emission standards.

With the use of new technologies, «new» disturbances (e.g. in different parts of the spectrum) could
appear. Limits for «new » disturbances should be included only if necessary, when an increasing risk
of interference or disturbance could appear.

5.3.5.5 Factors having an influence on the limits

Limits should cover the required frequency range and take into account the probability of the
disturbances. The limits may vary at higher frequencies depending on the radio service and on the
frequency ranges involved. Depending on the phenomena, the limit may be power dependent and/or
frequency dependent.

The specification of the limits should take into account the type of operating characteristics of the
equipment, especially when the addition of disturbances of equipment influences the electromagnetic
environment. The cumulative effect can be of large importance when considering mass produced
equipment for conducted low frequency phenomena; it should then be taken into account.

In specifying limits (e.g. for conducted low frequency emissions (below 9 kHz) or for digital
telecommunication services), it is necessary to ensure that the restriction applicable to equipment
groups is in proportion to their contribution to the cumulative disturbance level.

For some limits, indications should be given, limiting the application area to certain categories of
products. Therefore equipment groups could be defined and a matrix could indicate which limits apply
to which equipment group.

There is no reason for the emission limits to be different, for equipment having the same type of
operating characteristics and intended for use in the same environment.

5.3.5.6 Test conditions and test report

A new generic emission standard should include also a clause defining the conditions during
measurement (present clause 6 of 61000-6-3). The generic standard should give if necessary additional
information in a general way, such as cable layout, maximising the emission, etc.

The content required in the test report should be described

5.3.5.7 Basic Measurement methods to be used

The measurement and test methods need only be indicated by reference to a basic or another reference
standard when such standards are available.

It is only in the case where such a reference standard would not be available that a detailed normative
annex describing the measurement and test method could be included in the generic standard. The
better way will be to publish a new basic standard for this method.

Report of the Strategic Review Panel of EMC Harmonised Standards 9

The product should be regarded, as far as possible, as a black box where only the external aspects
(such as existence of mains cable, signal cable, telecom port, construction of the enclosure, etc.) are
essentially relevant.

The standard should allow in some cases the choice of alternative measurement methods with
corresponding limits to facilitate the surveillance of their own products by the manufacturers.

Example for radiation measurements above 30MHz:

- standardised open test site,
- semi-anechoic room,
- fully anechoic room (3m distance),
- power clamp,
- mode stirred chambers,
- TEM cells ...

It is not required to have a strict equivalence and correlation between the different methods (including
their corresponding limits), as long as these various methods (and associated limits) are shown to give
satisfactory results in practice.

Restrictions for use of the different alternative methods should be indicated in the standard (for
example size of tested equipment, external cabling used etc.)

5.3.6 Responsibilities for preparing the new generic emission standard

In order to avoid technical barriers to trade, it is not proposed to develop this new generic emission
standard at the European level but to give preference to international standardisation. It is therefore
thought that the recommendations contained in this document should be forwarded by CENELEC to
IEC /CISPR, with the aim that CISPR develops the needed standard with input from TC 77 (SC77A)
for the low-frequency part to be included, for which CISPR is not responsible.

Recommendation 2 (future single generic standard):

It should be envisaged to prepare a future single generic emission standard in accordance with the
framework as set out under clause 5.3 of the SRP report.
This task should have a high priority.

5.4 Precedence of product (family) standards over generic standards

The SRP looked into a proposal for removing the precedence of product (family) standards over generic
standards, leaving the choice of using the generic standards as an alternative to the product (family)
standards.

It was pointed out that the principle of product (family) standards taking precedence over generic
standards should be kept at all cost because this has been one of the fundamental principles relating to
the EMC standardisation structure. Moreover, requirements in product (family) standards are not always
relaxations from the generic standards but may contain more stringent requirements.

It is also to be borne in mind that the importance of product (family) standards is that they facilitate
ensuring compliance with the essential requirements of the EMC Directive for the manufacturers.
Otherwise manufacturers might approach the essential requirements in a different way. On the other
hand it was remarked that for certain equipment the "product approach" will (have to) disappear in the
near future due to convergence of technologies.

Report of the Strategic Review Panel of EMC Harmonised Standards 10

The majority of the SRP members was not in favour of removing the precedence of product (family)
standards over generic standards, at least not for the moment being.

Recommendation 3 (hierarchical structure of standards):

The principle of product (family) standards taking precedence over generic standards is to be
kept.

5.5 EMC and phenomena

5.5.1 Reference was made to the ever growing number of basic standards, addressing continuously new
phenomena. It was stressed that R210-001 identifies 18 phenomena which Product Committees should
consider and from which only those relevant for the product should be translated in the standard (see also
5.6 on this issue).

It was also pointed out that no stable selection of phenomena , which would be indefinitely valid, can be
envisaged. However, the EMC Directive is sufficiently specific with respect to the phenomena to be
covered, since its protection requirements relate to electromagnetic disturbance, which it defines as any
phenomenon that can degrade the performance of equipment.

Recommendation 4 (phenomena):
Phenomena and their selection belong to the standardisation field and should not form part of the
EMC Directive.

5.5.2 The fundamental issue whether immunity standards should continue to be associated with the
EMC Directive was put forward.

The SRP position was clear: as the EMC Directive covers emission and immunity and one of the means
of proving compliance is the application of harmonised standards in which there is a definite need for
immunity standards.

Recommendation 5 (immunity standards):

There is a definite need for immunity standards.

5.5.3 The SRP also discussed the possibility whether a single limit for immunity standards could be
envisaged but since the immunity level should be appropriate to the intended operating environment the
SRP came to the conclusion that this is not possible.

It was reiterated that, in case of a single limit/environment, immunity would refer to the protection of the
consumer and that in all other cases immunity would then be a service and quality factor.

Recommendation 6 (immunity approach):

There is no incentive for modifying the approach towards immunity.

5.6 Proliferation of standards

5.6.1 As a general principle, the SRP stressed that harmonised standards are a tool for the manufacturer
to use as they lead to presumption of conformity to the essential requirements of the EMC Directive.
Therefore, on the one hand , product standards are very useful even if, in the extreme case, they would
only collate the relevant EMC requirements laid down in other standards (e.g. generic standards). On the
other hand it was recognised that there are (too) many harmonised standards for certain products but it
was noted that only a very limited number of Product Committees are involved (CLC/TC 17B,
CLC/TC 72).

Report of the Strategic Review Panel of EMC Harmonised Standards 11

5.6.2 It was stressed that the number of harmonised standards is stabilising, mainly as a result of the
ongoing co-ordination between CENELEC and IEC and the co-ordination activities within IEC (ACEC)
and CENELEC (TC 210), which led to better monitoring and prevention of possible proliferation.

Reference was made to the proposals for regrouping as far as possible product requirements in product
family standards.

5.6.3 It was also stressed that a clear distinction should be made between regular EN's and harmonised
standards. Moreover, out of the considerable quantity of basic standards, only 7 are being referred in the
generic and most product standards (i.e. EN 61000-4-2, -4-3, -4-4, -4-5, -4-6, -4-8 and -4-11).

Recommendation 7 (proliferation):
Noting that
• the number of harmonised standards is stabilising
• only a limited number of Product Committees has prepared multiple product standards
• there are at present only 7 basic standards used in the legal framework
the SRP concluded that there is no real proliferation of standards and that hence no specific action
other than possible regrouping of product requirements is to be undertaken.

5.7 Management and inconsistencies

5.7.1 The SRP recognised that the existing inconsistency between standards was mainly due to the
management of standardisation. As a matter of fact, the situation stems from a horse trading situation
where requirements are set without a real general guideline/policy.

5.7.2 The SRP regretted the lack of authority of CLC/TC 210/SOG (Standards Overview Group) and
the EMC Consultant over product standards: their advice had in different cases been
overlooked/neglected by CLC/BT. On the one hand, it was recognised that it is the ultimate prerogative
of CLC/BT to decide (for what concerns CENELEC standards), on basis of the available positions from
all concerned parties, whether a standard is suitable to be offered to the Commission for listing in the
OJEC. On the other hand the SRP concluded that it would be advisable to address a statement to
CLC/BT, asking that the advice from CLC/TC 210/SOG and the EMC Consultant should be more
closely followed provided that all necessary consultation has been undertaken. If this principle is duly
respected, it should ensure coherent standards.

5.7.3 As the majority of the EMC standards stems from IEC, the possibility of influencing the IEC
standardisation activities was also considered. It was however noted that IEC/ACEC is presently looking
into the system and is making proposals for better monitoring of drafts and CDV's, introducing a new
check list and a short guide for Product Committees.

5.7.4 The SRP also debated a proposal from CLC/TC 210 to grant this Committee the overall
responsibility over EMC standardisation, which would include, in particular, a vote "in CLC/TC 210" on
CDV's and FDIS's or at least an approval vote within CLC/TC 210 on all EMC drafts prior to their
submission to vote within CENELEC.

This suggestion was not followed bearing in mind that the CENELEC principles prescribe that Product
Committees have the responsibility over their standards, that votes within technical bodies as such do not
exist and that the present system (check of drafts by CLC/TC 210/SOG and the EMC Consultant) should
fulfil the need.

Report of the Strategic Review Panel of EMC Harmonised Standards 12

Recommendation 8 (management and inconsistencies):
The advice as expressed by CLC/TC 210/SOG and by the EMC Consultant on the suitability of
product (family) standards as harmonised standards under the EMC Directive should be more
closely followed.
Note: Through D102/174, CLC/BT noted this SRP recommendation.

5.8 Miscellaneous topics

5.8.1 Informative annex

5.8.1.1 The SRP debated a proposal, defended among others by the EMC Consultant, for possible
identification, in an informative annex, of the link between the clauses of the harmonised standards and
the essential requirements of the EMC Directive.
ETSI and CEN have adopted this procedure.
After discussion, in view of the opposition to this procedure in CLC/BT, in order to maintain the
separation between legislation and harmonised standards and considering that standards give a global
solution, this proposal of informative annex was not retained.

5.8.1.2 Many CENELEC standards include safety, EMC and performance requirements. It is
recognised that these "mixed" standards may sometimes be confusing.
The EMC guide R210-001 gives therefore the preference to completely separate EMC product standards,
avoiding the mixture with other requirements. It is however recognised that this preferred option cannot
be imposed strictly to all Product Committees, who may prefer to keep the longstanding principle of
"one product, one standard" especially for traditional products.
In the case of mixed standards, the EMC chapter should be clearly separated and identified; any
confusion with safety requirements should be avoided.

5.8.2 Availability of harmonised standards

A plea was made for the availability, free of charge, of harmonised standards (i.e. a similar system as the
one existing in ETSI). It was also remarked that in order to find requirements for a specific product, it
may occur that different standards have to be bought.
This issue relates to a policy set out by the CENELEC membership and is outside the SRP competence.
The SRP concluded that it would be useful and helpful to have the cross-reference list of products and
their related harmonised standards regularly updated.

Recommendation 9 (link product-standard):

The cross-reference list of products and their related harmonised standards is to be kept regularly
updated.

5.8.3 Items "under consideration"

"Under consideration" means that no consensus could be achieved and that therefore no requirement is
available.
It was pointed out that, in ETSI, items "under consideration" are allowed up to the ETSI Public Enquiry
and are then to be taken out of the draft standard.
The SRP concluded that CENELEC should apply the same principle as ETSI.

Recommendation 10 ("under consideration" clauses):

CENELEC should apply the principle that "under consideration" clauses in EMC draft standards
can only be allowed up to the CENELEC enquiry stage and should hence be removed before the
voting stage. IEC should be invited to apply the same principle, this in view of parallel procedures
on IEC drafts.

Report of the Strategic Review Panel of EMC Harmonised Standards 13