EU EMC Directive FAQ custom installations

Start by classifying the thing being delivered. Under Directive 2014/30/EU, equipment means apparatus or a fixed installation. Apparatus is a finished appliance, or a combination made available on the market as a single functional unit for an end-user, that may cause electromagnetic disturbance or be affected by it. A fixed installation is a particular combination of apparatus and, where relevant, other devices, assembled and intended for permanent use at a predefined location.

If the custom work is apparatus, the manufacturer remains responsible for the apparatus route: EMC assessment, technical documentation, EU declaration of conformity, CE marking, identification, traceability, and installation or use information. If the custom work is a fixed installation, the installation itself is not subject to CE marking or an EU declaration of conformity, but the responsible person must be able to show that the installation follows good engineering practices and respects component intended-use instructions.

A narrow Article 19 route exists for apparatus intended only for incorporation into a particular fixed installation and not otherwise made available on the market. In that case, the usual apparatus provisions listed in Article 19 do not have to be applied to that specific apparatus, but the accompanying documentation must identify the fixed installation, its EMC characteristics, the apparatus identifying information, and the precautions needed so the installation's conformity is not compromised.

For a fixed installation, keep the evidence with the person or persons responsible for establishing compliance of the installation. Directive 2014/30/EU requires the good engineering practice documentation to be held at the disposal of national authorities for inspection for as long as the fixed installation is in operation.

The evidence should show how the site was configured and why the EMC result is reasonable for that site. For a simple installation made only from CE-marked apparatus, the Commission guide says the responsible person may satisfy the documentation requirement by being able to provide the supplier instructions for installation, use, and maintenance. Complex installations should retain more detailed evidence because the local EMC environment, cables, earthing, screening, filters, interfaces, and external coupling paths may matter.

When the custom item is apparatus, keep the apparatus evidence separate from the installation file. The manufacturer must perform an EMC assessment based on relevant phenomena and normal intended operating conditions, including representative configurations for apparatus capable of different configurations.

The apparatus technical documentation must make it possible to assess conformity and include an adequate analysis and assessment of risks. Directive 2014/30/EU lists a general description, design and manufacturing drawings, explanations needed to understand the apparatus, the harmonised standards applied in full or in part or other technical solutions used, design calculations or examinations, and test reports where applicable.

Use the Article 19 route only when the facts are narrow enough: the apparatus is for a particular fixed installation and is not otherwise made available on the market. The record should not merely say 'custom' or 'site-built'. It should identify the fixed installation, describe the EMC characteristics that matter, and explain why ordinary apparatus availability is not the fact pattern.

The accompanying documentation should travel with the specific apparatus and be available to the installation owner, installer, operator, or responsible person. It should give enough information to install the apparatus without compromising the fixed installation's conformity.