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
Junior Adviser - Technical Regulation

Related Position Papers

Internal Market: Orgalim comments on the final report of the impact assessment study on internet-connected radio equipment and wearable radio equipment [31 July 2020]

Internal Market: Orgalim Comments to EMC Directive Roadmap [21 February 2020]

Internal Market: Orgalim reaction - Commission Staff Working Document on the CPR Evaluation study [7 February 2020]

Internal Market: Orgalim comments to proposals tabled for revision of the Machinery Directive 2006/42/EC [3 February 2020]

Machinery Directive: Orgalim Contribution to the Guide of Interpretation to the Machinery Directive [26 September 2019]

Machinery Directive: Orgalim's response to the Open Public Consultation on the revision of the Directive 2006/42/EC on machinery [30 August 2019]

Construction Products Regulation: Orgalim views on shaping a Regulation on Construction Products that strengthens the Internal Market [14 May 2019]

Radio Equipment Directive: Orgalim views on the EC Roadmap for a delegated Act on upload of software to radio equipment [7 May 2019]

Orgalim’s answer to the European Commission Inception Impact Assessment on the Revision of the Machinery Directive 2006/42/EC [8 February 2019]