RadCom April 2024, Vol. 100, No. 4

April 2024 31 electrical installations such as 400kV substations and HVDC converter stations. The CIGRE limit is defined in 9kHz bandwidth from 150kHz-30MHz and 120kHz bandwidth above 30MHz. A Quasi- Peak (QP) detector is used. The RMS equivalent may be about 0-5dB lower depending on the waveform. An approximate value of -2.7dB has been assumed. Bandwidth has then been scaled from 9kHz or 120kHz to 1Hz. It is measured at 200m distance and it is approximately 35dB higher than the ITU-R rural curve. This means that, if the emissions from the substation are close to the limit, on 1.8MHz for example, then an amateur station 2km away may see emissions approximately 15dB higher than the ITU-R rural curve, although this would depend on the ground conductivity. To get down to the ITU-R rural noise level it may be necessary to go out to 6km or more. We have read a report where measurements were made that claimed to represent the noise floor at a location but the measuring loop was the type shown in curve (H). It was not measuring man-made or atmospheric noise, it was measuring the much higher noise floor of the pre-amplifier in the active antenna! EU Directives in UK Three years after the UK left the EU, it is worth reviewing the history of European Directives and harmonised standards for electronic products from 1976-2020. Directives and harmonised standards that came into effect up to 31 December 2020 are still in force in the UK but there has been some divergence between UK and EU since then particularly in market surveillance. This item is written in the context of EMC but it has much wider implications for many other types of products covered by ‘New Approach’ Directives, including product safety of Lithium batteries, see below. This item is the author’s opinion and it should not be taken as an authoritative guide to any standards or legislation. Radio communication requires regulations that protect the radio frequency spectrum from interference. There is also a need to ensure that electronic products have sufficient immunity to unwanted operation in the presence of signals from radio transmitters and other sources of disturbance. In the 1980s, the RSGB EMC Committee, and its predecessors, mainly dealt with RF immunity issues such as breakthrough of amateur radio transmissions into TV, radio and audio systems and occasionally electronic telephones and PIR sensors for security lights and alarm systems. There were some sources of interference to amateur reception including household appliances but these and others were regulated by European Council Directive 76/889/EEC of 4 November 1976 on ‘the approximation of the laws of the Member States relating to radio interference caused by electrical household appliances, portable tools and similar equipment’. It covered a wide range of mains-powered machines with electric motors and also regulating controls incorporating semi- conductors. These include dimmer switches using triacs that generate RF interference and require suppression components. The 1976 Directive contained the full text of the EMC standard as an annex and this was similar to British Standard BS 800. It was replaced by 87/308/EEC. An important milestone was the EMC Directive, Council Directive 89/336/EEC of 3 May 1989 on ‘the approximation of the laws of the Member States relating to electromagnetic compatibility’. The was based on the ‘new approach’ to technical harmonisation and standards where the design and manufacture of equipment is subject to Essential Requirements. The EMC Directive limits electromagnetic emissions from equipment so that it does not disturb radio, telecommunication and other equipment. It also governs the immunity of such equipment so that it is not disturbed by emissions from radio transmitters. Immunity requirements were introduced for the first time by the 1989 Directive. The relevant Harmonised Standards were listed separately in the OJ. It was due to come into effect in 1992 but this was postponed until 1996. It was subsequently replaced by newer EMC Directives, 2004/108/EC and 2014/30/EU. One objective of the ‘New Approach’ Directives was the removal of technical barriers to trade. For example, computers sold in Germany before 1996 had to comply with the German EMC standard VDE0871 whereas for computers sold in the UK, compliance with the equivalent UK EMC standard BS6527 was optional. Another objective was to ensure equal conditions of competition for all economic operators and to protect against unfair competition, ie to create a ‘level playing field’ . Market surveillance Further to the items in December 2023 and February 2024 EMC Columns, Market Surveillance means ensuring that products conform to relevant legislation. With the increasing popularity of online auction websites and online market places, more and more online transactions in the UK are ‘direct sales’, where the product is supplied directly to the end user by suppliers outside the UK or EU. For example, car battery chargers that have been featured in the EMC Column in June 2020 and December 2021 are CE marked but have no radio interference suppression components. Tests show that the level of RF interference is far in excess of the relevant Harmonised standard, and they are reported to cause widespread interference on amateur radio bands. The problemwith direct sales is that they bypass economic operators responsible for compliance in the EU or UK. This can result in unfair competition, and it can also allow non-compliant products to be sold. Although products sold by direct sales are not placed on the market in the UK or EU, they are taken into service. The Essential Requirements still apply but it is very difficult for market surveillance authorities to regulate direct sales. Regulation (EU) 2019/1020 of the European Parliament, and of the Council of 20 June 2019 on market surveillance and compliance of products, regulates direct sales by introducing the concept of a ‘Fulfilment service provider’ based in the EU that can be responsible for certain compliance activities. This applies in EU Member states and at the time of writing (Feb 2024) also in Northern Ireland. Although the UK Government was not obliged to implement it in England, Wales and Scotland, there appears to be no reason why a UK version of Regulation (EU) 2019/1020 could not be implemented voluntarily if the UK Government chooses to do so. Product safety A member, who is also a keen cyclist, points out that EU Regulation on Market Surveillance and Compliance of Products (2019/1020) has far wider implications beyond compliance with the EMC Directive. Its scope includes compliance with various other EU Directives for many other products including the machinery Directive which covers electric bicycles, among other things. There are concerns in the UK about house fires caused by unsafe lithium battery/charger combinations used in some electric bicycles, electric bike conversion kits and electric scooters. These are available via direct sale in England, Wales and Scotland. Our cycling Member comments that if a UK version of the EU Regulation on Market Surveillance and Compliance of Products (2019/1020) were introduced in England, Wales and Scotland, this would not only regulate non-compliant products that cause radio interference, but it could also improve consumer safety for Light Means of Transport batteries (LMT batteries), ie electric bicycles etc. Fire safety issues with unsafe lithium batteries/chargers for electric bicycles, etc could be tackled by means of a UK version of a recent EU Regulation. This is Regulation (EU) 2023/1542 of the European Parliament and of the Council of 12 July 2023 concerning batteries and waste batteries. This covers a wide range of environmental and sustainability issues and also includes important regulations on battery safety. References [1] ITU-R Recommendation P.372-16: https://www.itu.int/rec/R-REC-P.372/en [2] Dr. Andreas Lock, DG8AL, ENAMS - System des DARC e.V. Überlegungen zur Mess-Toleranz CQ DL 9-2020 Dr David Lauder, G0SNO emc.radcom@rsgb.org.uk Technical