Should a boat be declared to the EMC Directive?


In the past, builders did not declare their boats to the EU ElectroMagenetic Compatibility Directive (EMC) on the basis that they were selling a boat not an electrical product.  Boat builders would also say that they buy and fit only UKCA/CE marked electrical components, so EMC compliance is implicit. Interestingly, however, the manufacturers of PWC have always declared to EMC.  HPi-CEproof’ own research into EMC, which included a visit to an anechoic chamber, shows that components can interact and that every cable is a potential EMC antenna.

The anechoic chamber at Salford University

Thus a circuit of EMC compliant components can fail an EMC test when combined. Indeed, HPi-CEproof saw such a battery charger fail its EMC test in the chamber.  So if the assembly of a boat’s electrical system could potentially lead to an EMC problem, should builders be checking and declaring boats compliant with the EMC Regulations/Directive?  At the RSG meeting in Stockholm on 4th February 2013, attended by HPi-CEproof’ CEO Alasdair Reay, the EU Commission representative said “yes”. It would appear that the EU Commission is concerned that a range of products incorporating electrical components are not paying due attention to the risks of EMC. To maintain easy export of UK products to EU, the UK Government is expected to take thee same view as the Commission.

That is all very well but how does a boat builder test a 78ft boat?  There are only a couple of chambers in the world that could accommodate such a boat and if each conductor’s length and route could influence the EMC signal, should every possible option be tested?  It is possible to do EMC testing in the field and HPi-CEproof has also taken part in some of these.   This requires an environment free of EMC signals which will certainly not be the case at any boat yard. As the EMC immunity test throws out strong pulses, it also must be done where the neighbours don’t have any sensitive equipment.

This is all unworkable but on 28th January 2013, ICOMIA came to the rescue of the industry by publishing their RECOMMENDATIONS ON ASSESSMENT FOR EMC COMPLIANCE OF SMALL CRAFT UNDER UK Regulation 2004/108/EC. ICOMIA says:

This document outlines step-by-step assessment recommendations on compliance for the Electromagnetic Compatibility (EMC) Directive for boats and is expected to guide boatbuilders through this process.

This is a “guideline” and not a “standard” and it is certainly not a designated/harmonised standard Standards which have been especially written to support the regulations/directive and which have been adopted as national standards by UK and all EU member states. but it is all we have in the boating industry on the subject of EMC.  As it is not designated/harmonised, no Government can insist upon the use of this document and conversely, neither can they guarantee that it meets the requirements of the EMC Regulations/Directive.  But if the industry uses it, it is a de facto “industry standard” and in the absence of any alternative, how could a court find against a boat builder for following it.  So, ICOMIA’s document provides the only useful basis on which to declare compliance with EMC for a boat.

Sample RCD-EMC-Declaration

Click to see a sample RCD-EMC Declaration

The guideline is not onerous. It lays out flow charts for selecting compatible components, checking assembly follows good practice and how to document it all.  HPi-CEproof welcomes the document and recommends its application to all its clients, though, as it is not a Approved Body for EMC, HPi-CEproof has no right to withhold a RCR certificate on the grounds of EMC. (It should be noted that certification by Approved Body is never mandatory for EMC).

The existing RCR template for the Declaration of Conformity has space to refer to EMC.  See HPi-CEproof’ Sample RCR EMC Declaration.

For further details, contact HPi-CEproof.

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