EMC Directive, Inherently benign equipment

[though]

Hello,

I've got another question. This time regarding EMC directive. I've checked it and some components are excluded from the scope of EMC directive, like induction motors, cables, etc. I am trying to find out if our machines are exempt from EMC directive.

Our machines are hydraulic scrap processing machines with induction motors and they have a automatic wye-delta starter circuit or direct on line starter which both have components like contactors, timers, circuit breakers, overload breakers, limit switches and manual switches. We don't have any other sensors or any electronic components.

Reading the supplementary documents I understand that, induction motors, circuit brakers and overload protection devices are not in the scope of the directive. The only remaining component we have in our machines are contactors. I don't know if we have to look into this component by component or as a whole system. If it is component by component my question is, are contactors also regarded as inherently benign?

If we have to think it as a whole system, my question is; can our machines be considered as inherently benign?

[hazu]

It seems to me that these machines fall within the scope of the Machinery Directive and thus requires CE.

[though]

Hello,

Yes our machines definetely fall into scope of MD (and LVD) and we are already finished with that part of CE assessment. But now I have to find out if our machines fall into scope of EMC directive too.

After reading the directive and the guide to the directive, I think our machines might be exempt, but I also hear that contactors can contribute to electromagnetic interference during opening and closing. So I'm not very sure about it.

[Kelvinthm]

I would suggest you revert to your supplier of the breakers and ascertain whether or not they have carried out EMC testing on the product and if so what results they obtained, ask for a copy of the test certificate to include in your Technical file.

[though]

Actually I think circuit breakers are considered inherently bening. Here I quote from the Guide to EMC Directive:

The application of the above enables the exclusion of the following equipment (not exclusive) from the application of the EMC directive, provided that they include no active electronic part(s):
...

Protection equipment which only produces transitory disturbances of short duration during the clearing of a short-circuit fault or an abnormal situation in a circuit and which do not include active electronic components, such as fuses and circuit breakers without active electronic parts or active components;

...

But still there is no reference to contactors, I don't know if contactors are considered bening too. And I don't know if timer relay is considered inherently bening (it has a 555 timer IC in it). And lastly I am not sure wheather the inherently bening nature of all these components that we use in our machines guaranties that our machine is inherently bening as a whole system.