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

Status
Published
Publication Date
28-Oct-2010
Current Stage
6060 - Document made available - Publishing
Due Date
29-Oct-2010
Completion Date
29-Oct-2010

Overview

CLC/TR 50538:2010 - "Guide to EMC Directive conformity of equipment designed for military purposes" is a CENELEC technical report providing practical guidance on applying the EU EMC Directive (2004/108/EC) to non‑exempt military (defence) equipment. It clarifies how the Directive’s concepts of apparatus and fixed installations apply to military systems, reviews conformity assessment routes, and offers tools (flow diagrams, gap analysis and case studies) to reconcile military standards with harmonised civilian EMC requirements.

Key topics and requirements

  • Scope: Applicable to any non‑exempt military/defence equipment; does not replace or relax military standards but addresses EMC aspects as covered by the EMC Directive and related EU directives.
  • Apparatus vs Fixed Installations: Definitions from the EMC Directive are explained with decision flow diagrams to classify equipment and determine whether CE marking/Declaration of Conformity applies.
  • Conformity assessment: Guidance on which conformity procedures under 2004/108/EC apply and when detailed technical EMC assessments are needed.
  • Use of military standards: Methods for demonstrating EMC compliance when harmonised standards are not used; includes a gap analysis tool and read‑across tables to compare military test results with harmonised civilian limits.
  • Fixed installations: Guidance on installations using military equipment and their electromagnetic impact on neighbouring environments.
  • Legal & procurement context: Annexes summarise Article 346 (previously Article 296) exemptions, the Defence Procurement Directive (2009/81/EC) and related directives (R&TTE, Automotive, Marine Equipment).
  • Supporting material: Flow diagrams (Annexes E & F), test method comparisons (Annex H), gap analysis examples (Annex I) and practical case studies (Annex J).

Applications and who uses it

This guide is aimed at:

  • Manufacturers and integrators of military equipment seeking EU EMC conformity routes.
  • Suppliers, importers, procurement authorities and defence acquisition teams clarifying regulatory obligations.
  • Test laboratories and compliance engineers performing EMC assessments and interpreting military versus harmonised test results.
  • Contracting authorities evaluating whether equipment/installation is exempt under Article 346 or requires full EMC compliance.

Practical uses include classifying products as apparatus or fixed installations, preparing Declarations of Conformity or installation instructions, performing EMC gap analyses, and documenting conformity in defence procurement.

Related standards and references

  • EMC Directive 2004/108/EC (essential requirements and conformity procedures)
  • Defence Procurement Directive 2009/81/EC
  • R&TTE Directive 1999/5/EC (radio equipment exclusions)
  • Automotive EMC Directive 2004/104/EC; Marine Equipment Directive 96/98/EC
  • CENELEC TC 210 guidance and harmonised EMC standards

This Technical Report is a practical compliance resource bridging military EMC practices and EU regulatory requirements for electromagnetic compatibility.

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Frequently Asked Questions

CLC/TR 50538:2010 is a technical report published by CLC. Its full title is "Guide to EMC Directive conformity of equipment designed for military purposes". This standard covers: 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.

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.

CLC/TR 50538:2010 is classified under the following ICS (International Classification for Standards) categories: 33.100.01 - Electromagnetic compatibility in general. The ICS classification helps identify the subject area and facilitates finding related standards.

You can purchase CLC/TR 50538:2010 directly from iTeh Standards. The document is available in PDF format and is delivered instantly after payment. Add the standard to your cart and complete the secure checkout process. iTeh Standards is an authorized distributor of CLC standards.

Standards Content (Sample)


SLOVENSKI STANDARD
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
2003-01.Slovenski inštitut za standardizacijo. Razmnoževanje celote ali delov tega standarda ni dovoljeno.

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
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.
__________
– 3 – CLC/TR 50538:2010
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

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

– 5 – CLC/TR 50538:2010
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.

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.

)
CEN: European Committee for Standardisation, Workshop 10: Standardization for Defence Procurement,
EG7: Expert Group 7: Electromagnetic Environment

– 7 – CLC/TR 50538:2010
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.

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.

– 9 – CLC/TR 50538:2010
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.

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.
– 11 – CLC/TR 50538:2010
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:
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 requirements of the EMC Directive are met, as the manufacturer
needs to provide clear evidence of compliance.
This option is of particular importance as it allows a high flexibility for those technical developments
that are crucial in case of manufacturing new or innovative apparatus for which standards do not exist,
or cannot be used.
Further guidance on „good engineering practices‟ can be found in the “Guide for the EMC Directive
2004/108/EC” [16] (section 4).
3.2.4.6 Similarity
Similarity in product designs may be considered to exhibit similar electromagnetic performance where
the changes are insignificant. The “Guide for the EMC Directive 2004/108/EC” [16] (section 3.2.1.1)
provides details on „worst case‟ assessment and should also be applied.
3.2.4.7 Mitigation and control (limitations of use)
Consideration of the operating conditions identified in 3.2.2 may identify conformity with the EMC
Directive is subject to placing restriction on use to ensure that the protection requirements are met.
Examples may include
restricting modes of operation,
ensuring separation between the product and other equipment.
3.2.4.8 Gap analysis
The gap analysis process may be used in the “mixed” or detailed technical EMC assessment. Its
purpose is to identify any shortfalls in the EMC performance of the military equipment against the EMC
Directive protection requirements. In order to achieve this, the EMC standards, test methods and limits
applied to the military equipment must be identified and compared to the equivalent harmonised
standard, test methods and limits that represent the product specific requirement or generic
environment standard applicable to the product. The first stage is therefore to align test methods that
address similar EMC phenomena.
The “Report of the CEN WS 10 EG7 ‘Electromagnetic environment’” [11] provides a comparison table
in its Appendix C that might be used to locate an equivalent standard that may be used in the
assessment. This may prove useful in the cross referencing of military standards. The table has been
updated in this Technical Report and included in Annex H.
The detailed comparison of test methods is complex and guidance on the relevant factors to be
considered is given in Annex G.

– 13 – CLC/TR 50538:2010
The comparison factors must be quantified and then used to modify the test methods and limits being
compared. Either the military standard or harmonised standard limit is modified to allow both sets of
limits to be presented on a single graph or table using common units of frequency/amplitude or
time/amplitude.
From this comparison the differences in frequency range, time scale or amplitude can be quantified.
Examples of gap analysis are shown in Annex I.
Where the military test method and limit is more onerous than the harmonised standard equivalent
then this demonstrates that the military equipment is in conformity with the harmonised standard test
method and limit.
Where the military test method and limit is less onerous than the harmonised standard equivalent then
this demonstrates a shortfall or gap against the required conformity with the harmonised standard test
method and limit.
Note that for emission tests a shortfall identified by comparing military and harmonised standard test
method and limits may be mitigated by considering the actual military equipment test result and the
margin by which it is below the emissions limit. If this margin is greater than the shortfall at the relevant
frequencies then this information demonstrates that the harmonised standard test method and limit
would have been met.
In some instances, a harmonised standard might indicate a test method and limit for an
electromagnetic phenomena that has not been examined by the military standard. Before entering into
lengthy simulations or expensive testing, the assessor should consider the suitability of including this
aspect in the assessment. E.g. in the case of electrostatic discharge, does the military processes used
when handling the equipment mitigate this risk? If this is the case, the assessor need only document
that this “gap” is mitigated by the military process. This may be the case in other situations for other
products.
Once the gaps and missing tests, that are not otherwise mitigated, have been identified, they may be
addressed by application of relevant harmonised standards or basic standards through test or analysis
of the military equipment. Alternatively they may be assessed by any suitable method noted in the
previous paragraphs where such is thought applicable
The gap analysis and any additional test or analysis against harmonised standards should then
demonstrate overall that the military equipment is in conformity with the protection requirements of the
EMC Directive for all relevant EMC phenomena.
3.2.5 Technical documentation
The manufacturer draws up technical documentation (a technical file) as described in Annex IV of the
EMC Directive 2004/108/EC, providing evidence of the conformity of the equipment with the essential
requirements of the Directive. The purpose of the technical documentation is to enable the conformity
of the equipment with the protection requirements to be assessed. The following is an example of the
content of a technical file:
an identification of the equipment covered by the technical documentation. This identification
should allow unambiguously linking between the technical document and the equipment;
a general description of the equipment. The amount of information required will depend on the
complexity of the equipment, simple apparatus may be fully defined in one line whereas more
complex fixed installation may need a complete description (a picture may be included);
consideration of applicable military/non-battlefield operating environments and hence the required
standards to represent the environment;
consideration of relevant modes of operation and configurations that may impact neighbouring
environments;
if European harmonised standards have been applied, then evidence of compliance is required.
at a minimum this will be a dated list of the European harmonised standards applied and the
results obtained on their application;

if European harmonised standards have not been applied or have been applied only in part then
a description of the steps taken to meet the essential requirements as discussed in 3.2.4.
If a manufacturer is using the procedure of Annex III of the EMC Directive 2004/108/EC, then the
Notified Body statement shall be included.
The level and type of documentation needed to show due diligence and hence compliance with
the relevant directive requirements will depend upon the type of system being developed and its
target operational use, as military systems cover all the deployment options covered within all the
regulatory legal enforcement framework.
3.2.6 Notified Body involvement
A Notified Body can be used on a voluntary basis to provide an opinion regarding the suitability of the
EMC assessment with regard to all or specified EM phenomena within the essential requirements.
The Notified Body issues a statement if satisfied that the apparatus is compliant with the essential
requirements.
3.2.7 Declaration of conformity
The manufacturer or supplier issues a declaration of conformity as described in Annex IV of the EMC
Directive 2004/108/EC.
The declaration requires a dated reference to the specifications under which conformity is declared.
For military equipment the specifications may include military standards and harmonised standards.
Any operating conditions or configurations that are excluded from the declaration of conformity should
be listed.
3.2.8 CE marking
If the military apparatus complies with all applicable directives, CE marking is applied in accordance
with Annex V of the EMC Directive 2004/108/EC to the apparatus or data plate or if this is not
possible, to the packaging and accompanying documents. Because there are implications involved in
changing the markings on military hardware, due consideration should be given to this when deciding
whether to mark the hardware, the packaging etc. It may be appropriate to only mark the paperwork
associated with the product or the accompanying Declaration of Design Performance (DDP) or
equivalent when such is appropriate.
3.3 Fixed installations
3.3.1 General
Whilst the definition of fixed installation is detailed in 3.1, it should be noted that the scope of this
covers both the installation as a whole and also certain specific apparatus used within it, if it has been
specifically designed to be used permanently at a pre-defined location (i.e. was designed for a specific
location and customer).
Fixed installations are by definition „fixed in a location‟ and hence do not move across EU Member
State boundaries and since the purpose of the EMC Directive is to permit free trade then CE marking
is not relevant and hence fixed installation enjoy what the EU Commission describe as a relaxed
regime. There is neither a requirement for a Declaration of Conformity nor a CE mark but they must
meet the protection requirements.
EXAMPLES OF TYPES OF FIXED INSTALLATION
In a military environment there are many types of fixed installation. For example an army camp or barracks could be considered
as a fixed installation – the individual buildings or electrical systems within the building could also be considered.
A dockyard might be considered as a fixed installation as it has many different types of apparatus contained within it ranging
from mobile machinery to radio controlled cranes.
Conversely, a ship is not a fixed installation since by its very nature it is mobile. Like a ship, a military aircraft is mobile and
hence is apparatus. However, ground support equipment, e.g. radar, might be considered as a fixed installation.

– 15 – CLC/TR 50538:2010
The common requirement and objective in all of the above examples is that whether a fixed installation
or apparatus, the protection requirements are complied with.
Subclause 3.3.2 describes the conformity assessment procedure for military fixed installations falling
within the scope of the EMC Directive.
The conformity assessment procedure for fixed installations is described in Article 13(1) 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 fixed installations is given in Annex F.
3.3.2 Essential requirements for fixed installations
Fixed installations have to meet Annex I of the EMC Directive 2004/108/EC protection requirements
and also a set of specific requirements for fixed installations. These state that a fixed installation shall
be installed applying good engineering practices and respecting the information on the intended use of
its components, with a view to meeting the protection requirements. The good engineering practices
applied to EMC shall be documented and held by the responsible person.
For a military fixed installation the EMC engineering practices employed to meet military standards
should be analysed to determine if they satisfy the EMC Directive specific requirements for fixed
installations. If they do, this analysis can be documented. If not, additional protection measures may
be required. The analysis needs to consider how the protection requirements, such as controlling
emissions, will be met at the installation boundary.
Examples of the EMC engineering practices include
earthing & bonding,
cable management,
apparatus location and separation,
shielding,
EMI filtering,
surge suppression and use of uninterruptable power supplies.
3.3.3 Specific apparatus
Apparatus intended for incorporation into a given fixed installation that is otherwise not commercially
available can either follow the conformity procedure for apparatus presented in 3.2.3 or the conformity
procedure contained within Article 13(1) second paragraph for fixed installations. If Article 13(1) is
followed, the declaration of conformity and CE marking are not required. The following documentation
is required and must be held by the responsible person:
type, batch and serial number of the specific apparatus;
name and address of manufacturer or representative;
identity and electromagnetic characteristics of fixed installation;
any special installation precautions required.

3.3.4 Responsible person
A responsible person must be identified for the fixed installation who is required to provide to the
authorities, by request, the EMC fixed installation documentation. The responsible person determines
the extent or boundaries of the fixed installation for which they are responsible. The fixed installation
EMC documentation includes the good EMC engineering practices, apparatus manufacturer‟s
installation and maintenance instructions and details of any specific apparatus without CE marking
used within the fixed installation.

– 17 – CLC/TR 50538:2010
Annex A
(informative)
A précis of the Defence Procurement Directive
The Defence Procurement Directive 2009/81/EC of 13 July 2009 [2] concerns the gradual
establishment of a European defence equipment market and as a prerequisite an appropriate
legislative framework. The directive supports a strategy for a stronger and more competitive European
defence industry. The directive references the Commission‟s Interpretative Communication of
7 December 2006 and Article 296 TEC.
This Directive allows member states to use Community rules that they can apply to complex and
sensitive Defence and Security transactions without putting at risk their legitimate security interests.
The directive applies to military equipment (as specified in the 1958 list), civil equipment that is
adapted for military use, and equipment specifically designed for non-military security.
Member States have two years to transpose the Directive into their national legislation.
Section 3 provides details of excluded contracts and the use of exclusions. This lists 11 excluded
areas including; ‘contracts for which the application of the rules of this Directive would oblige a
Member State to supply information the disclosure of which it considers contrary to the essential
interests of its security.’
Article 18 on the application of Technical specifications states
...

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