Internal Market: Orgalim Comments to EMC Directive Roadmap

Published: 21 February 2020

Policies & Issues: Internal Market - Product Safety Legislation

Orgalim believes that the Electromagnetic Compatibility (EMC) Directive: 

- is generally fit for purpose and we see no need for modification or revision at this stage 

- is not a “safety directive”, meaning that the Directive is not supposed to deal with the safety of equipment 

- should be kept technology neutral 

- should not be merged with other NLF Directives (eg RED). 

Moreover, Orgalim opposes any change to the scope of the Directive, such as the inclusion of cables, as well as any change to the essential requirements. We strongly believe that harmonised standards are the best means for addressing existing, as well as emerging technologies, such as AI, 5G etc. The directive should continue to specify only the high-level essential requirements. Our industry values the EMCD for its legal stability and predictability. We firmly believe that any lack of clarity can be addressed in guidance documents without revising the EMC Directive. 

To read our position in full, please download the document above.

Authors

Luykx
Christoph Luykx
Policy Director
Le Goff-Jedrzejowicz
Helena Le Goff-Jedrzejowicz
Adviser - Internal Market

Related Position Papers

Internal Market: Common understanding of the term “Internet-connected radio equipment” [13 September 2022]

Internal Market: Orgalim position paper on the transition period for Delegated Regulation on Outdoor Noise Directive 2000/14/EC [15 July 2022]

Internal Market: Position and recommendations from Europe’s technology industries on the proposed new Construction Products Regulation [12 July 2022]

Internal Market: Orgalim review of options for PED Guideline C-13 [15 December 2021]

Internal Market: Orgalim position on the proposal for a General Product Safety Regulation [3 December 2021]

Internal Market: Machinery Proposal - Mandatory third party certification is a step backwards [11 October 2021]

Internal Market: Joint industry statement on priorities for the Machinery Products Regulation [4 October 2021]

Internal Market: Orgalim input to the European Commission Consultation on the proposal for a new Machinery Products Regulation “Machinery Directive Revision” [16 August 2021]

Internal market: Orgalim comments on the draft delegated act for internet-connected radio equipment and wearables [10 March 2021]