Technical Guidance Note 34

TOPIC: Battery Operated Devices in the home

ISSUE: 2

REVISION DATE: 27.1.98

PREVIOUS REVISION DATE: 13.8.96

BACKGROUND: A battery operated device for use in the home declares to 89/336 using EN50081-1. It has no microprocessor and only internal batteries hence neither EN55014 nor EN55022 would appear to apply but it significantly interferes with a domestic TV receiver.

PROBLEM: What standard may be used to test? Is the CE mark valid?

GUIDELINES: The apparatus falls within the scope of EN55014 therefore this is the appropriate standard to apply. In this case however, no limits are applicable therefore no tests would be performed. This is a shortcoming in the standard.

Without undertaking any testing then there is no evidence showing compliance with the protection requirements of the Directive. As a result, the most appropriate tests to apply would be the radiated emissions requirement of the generic emissions standard EN50081-1:1992 (in spite of the restrictions on apparatus with no processing devices operating at frequencies greater than 9kHz). If the device complies with the radiated emissions requirements of EN50081-1 then the CE marking is valid and the product can benefit from a presumption of conformity.

Attention is drawn to the fact that the Class B radiated emissions limits specified in EN50081-1 allow for a 10 m protection distance. Therefore devices complying with these limits may still interfere with TV receivers closer than 10m.

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2. Parties should take specific advice when dealing with specific situations and consult their own professional advisors in this regard.
3. Members are free to deviate from the above guidelines where they think it appropriate, unworkable, or not commercially viable. Under these circumstances, the EMCTLA Secretariat should be informed of the reasons for the deviation so that the matter can be reviewed.