Table of contents 1Introduction 1.1Purpose of the evaluation 1.2Scope of the evaluation 2Background of the Intervention 3Implementation / state of Play 3.1Relevant Bodies 3.2Guidelines 3.3European standardisation 4Methodology 4.1Data collection and consultation strategy 4.2Data analysis methodology 4.3Statistical data on products in the scope of the EMCD 4.4Cost-benefit analysis 5Analysis and Answers to the Evaluation Questions 5.1Findings in relation to the Effectiveness of the Directive 5.2Findings in relation to the Efficiency of the Directive 5.3Findings in relation to relevance of the EMCD

5.4Findings in relation to the Coherence of the EMCD 5.5Findings in relation to the EU Added Value of the EMCD 6CONCLUSIONS 7ANNEXES ANNEX 1 - PROCEDURAL INFORMATION ANNEX 2 - SYNOPSIS REPORT OF STAKEHOLDER CONSULTATIONS ANNEX 3 - METHODS AND ANALYTICAL MODELS ANNEX 4 - ANALYSIS OF THE EMCD MARKET ANNEX 5 - CASE STUDIES ANNEX 6 - DESK RESEARCHS ANNEX 7 - EVALUATION QUESTIONS



Glossary Term or acronym Meaning or definition AC Alternating current AdCo Administrative Cooperation (Group) ANSI American National Standards Institute - has a role in developing EMC standards. Benign equipment Benign equipment is excluded from the scope of the EMC Directive – Article 2(2)(d). It is incapable of generating or contributing to electromagnetic emissions, or being disturbed... (from EDCD 2(2)(d) (ii)). CABs Conformity Assessment Bodies CBA Cost-benefit assessment CISPR Comité International Spécial des Perturbations Radioélectriques (International Special Committee on Radio Interference) CEN European Committee for Standardization CENELEC The European Organisation for Electrotechnical Standardisation is the European standards making body which has been mandated by the Commission of the EU to produce EMC standards for use with the European EMC Directive. CENELEC TC210 The horizontal committee working on standards development of the Generic and Product Family Standards. CISPR The Comité International Spécial des Perturbations Radioélectriques (CISPR; English: International Special Committee on Radio Interference) Commission European Commission DG GROW Directorate General for Internal Market, Industry, Entrepreneurship and SMEs of the European Commission DoC Declaration of Conformity EEA European Economic Area EFTA European Free Trade Association EMC ADCO Electromagnetic Compatibility Administrative Cooperation Group EMC WP Electromagnetic Compatibility Working Party EMC Electromagnetic Compatibility EMCD Electromagnetic Compatibility Directive (2014/30/EU) EMI Electromagnetic interference EO(s) Economic operator(s) ESOs European Standardisation Organizations ETSI European Telecommunications Standards Institute EU European Union EUANB Group of Notified Bodies notified under the EMCD to the European Commission FCC Federal Communications Commission FTE Full-Time Equivalent GHz Gigahertz - unit of measurement for electromagnetic wave frequencies equal to 1,000,000,000 (one billion) Hz (hertz). DG GROW Directorate-General for Growth - Internal Market, Industry, Entrepreneurship and SMEs Harmonics Digital signals and circuits generate noise sources known as harmonics, which are unwanted higher frequencies superimposed on the fundamental waveform. These may create distorted wave patterns and create EM interference. HS Harmonised Standards IARU International Amateur Radio Union IEC International Electrotechnical Commission is the international standards and conformity assessment body for all fields of electrotechnology. IoT Internet of Things ISO International Organization for Standardization. The ISO, along with the IEC has technical committees working on the development of emission and immunity requirements for devices and products. LED Light-Emitting Diode LVs Limit Values LVD Low Voltage Directive (2014/35/EU) MD Machinery Directive (2006/42/EC) MHz Megahertz unit of measurement for EM wave frequency MRA Mutual Recognition Agreement (several exist between the EU and other third country jurisdictions in the area of EMC, e.g. with the US). MS EU Member State MSAs Market Surveillance Authorities NBs Notified Bodies NIST National Institute of Standards and Technology, United States NLF New Legislative Framework OJEU Official Journal of the European Union (where harmonised standards adopted under the EMCD are published in the legal section of the OJ) PLC Power Line Communications RED Radio Equipment Directive (2014/53/EU) RMCD Ready-Made Connecting Devices RF Radio functionality R&TTE Radio equipment and telecommunications terminal equipment Directive (1999/5/EC). Directive was the predecessor to the RED SDoC Supplier’s Declaration of Conformity (allowed under Module A as one of the permissible conformity assessment procedures under the EMCD). This is a self-declaration of conformity. WPT for EVs Wireless-charging Power Transfer for Electric Vehicles 1Introduction The Electromagnetic Compatibility Directive 2014/30/EU (hereafter the EMCD) regulates electromagnetic compatibility aspects of a wide range of electrical and electronic products. The EMCD has the objectives of facilitating the free movement of electrical equipment across the Union and avoiding any electromagnetic disturbance between equipment, which could in turn generate dysfunctions and prevent correct operation of the equipment. More specifically, the Directive ensures that electromagnetic disturbances/emissions produced by electrical equipment do not affect the functioning of other such equipment and that electrical equipment has an appropriate level of immunity to electromagnetic disturbances so that it can function as intended. The first Electromagnetic Compatibility Directive 89/336/EEC was adopted in 1989. It was repealed and replaced by Directive 2004/108/EC. The current Electromagnetic Compatibility Directive 2014/30/EU was adopted in 2014, became applicable as of 20 April 2016 and repealed and replaced Directive 2004/108/EC. After more than 30 years without any major modifications, it was necessary to assess, in the context of a regular evaluation of the acquis, if the Directive has achieved its objectives in an efficient, effective, coherent and relevant way and still has EU added value. Therefore in line with the Commission's Regulatory Fitness and Performance (REFIT) programme, the Directive was subject to an evaluation. The evaluation was supported by an external study (hereafter evaluation study), commissioned by DG GROW and conducted from January 2020 to May 2021.

1.1Purpose of the evaluation The purpose of the evaluation is to analyse the performance of the EMCD towards its objectives of facilitating the free movement of electrical equipment across the Union and avoiding any disturbance between equipment. The evaluation assesses the extent to which the Directive is still fit for purpose in terms of effectiveness, efficiency, relevance, coherence and EU added value. The evaluation provides evidence and conclusions that will form the basis for possible future improvements in order to keep the EMCD up to date so that it can achieve its objectives and produce the desired results. 1.2Scope of the evaluation The evaluation considers changes to the Directive over time through successive iterations. It covers the period since 1989 to 2020 and focuses on the period since the applicability of the current Electromagnetic Compatibility Directive 2014/30/EU. The first Electromagnetic Compatibility Directive 89/336/EEC adopted in 1989 was repealed and replaced by Directive 2004/108/EC. A notable difference in the 2004 Directive compared with 1989 is that mandatory use of a notified body was no longer required. The current Directive was adopted in 2014, became applicable as of 20 April 2016 and repealed and replaced the previous Directive 2004/108/EC. The 2014 revision of the EMCD was part of the alignment process with the New Legislative Framework (NLF), a horizontal piece of legislation, which includes common requirements in respect of placing goods (equipment) on the market, common arrangements for market surveillance and common accreditation rules to ensure the quality of the services of conformity assessment bodies. The essential requirements in the current Directive have not been modified and the scope remains essentially the same compared to 2004, except for the introduction of an exception for custom built kits and kits of components to be assembled by radio amateur and equipment made available on the market. The current EMCD has in the meantime been modified by Article 137 of the Regulation on common rules in the field of civil aviation (EU) 2018/1139. This article modified Annex I (3) of the EMCD. As a result, equipment within the scope of Regulation (EU) 2018/1139 is excluded from the EMCD, except for some specific categories of drones. Given the large scope of the EMCD, the evaluation limits the analysis to 14 selected products, with a balance between apparatus and installations. The selection was done in collaboration with the EMC market surveillance authorities (see section 4 on Methodology for more details). Additionally, five product based case studies were used for the analysis. The geographic scope of the evaluation focuses on the EU-27, the UK (it was a Member State for much of the time period within scope andis considered as a third country in the analysis), and the EFTA countries. EEFTA allows products complying with the EMCD to benefit from free movement in Iceland, Liechtenstein and Norway by virtue of the European Economic Area (EEA) Agreement. 2Background of the Intervention The scope of the EMCD covers a wide range of electrical equipment placed on the internal market, both for consumers and industrial use, classified in apparatus and fixed installations. Apparatus are defined in the EMCD as “any finished appliance, or combination thereof made available (i.e. making available) on the market as a single functional unit, intended for the end-user, and liable to generate electromagnetic disturbance, or the performance of which is liable to be affected by such a disturbance’ (Article 3). Apparatus also includes mobile installations and components or sub-assemblies that are incorporated into the apparatus by an end-user. Typical example of apparatus are, but not limited to, household appliances such as refrigerator, oven, microwave, vacuum cleaners, toaster, blender, but also other type of equipment such as measuring devices, chargers, computers, printers, equipment for transmitting sound, images or other information by telecommunication, equipment for the purpose of recording or reproducing sound or images, powered tools for different activities (e.g. gardening), etc.; but also power supply units; electric motor systems, powered tools, etc. Fixed installations are defined in the Directive as a ‘particular combination of several types of apparatus and, where applicable, other devices, which are assembled, installed and intended to be used permanently at a predefined location’ (Article 3). Fixed installations are, for example, industrial plants, telecommunication networks, airport luggage handling installations, wind turbine stations or air conditioning installations. However, if the products within the scope of the EMCD include a radio functionality (communicate wirelessly), the Radio Equipment Directive (RED) applies instead of the EMCD. Furthermore, the EMCD shall not apply if electromagnetic compatibility requirements for equipment are wholly or partly laid down by other more specific EU legislation. For example, this is the case of medical equipment, motor vehicle equipment, marine equipment, agricultural and forestry tractors and two or three-wheel motor vehicles. The EMCD is not a health and safety or environment related Directive. For functional safety or environmental aspects of the products within the scope of the EMCD, other legislation applies in parallel with the EMCD. The Directive has some exclusions for certain categories of equipment, such as equipment for radio amateurs (unless made available on the market) or benign equipment and custom-built evaluation kits. The other exclusions are for equipment falling under specific legislation that also covers electromagnetic compatibility as specified above. The EMCD provides a stable regulatory framework with rules concerning the essential requirements, conformity assessment procedures and CE marking. The EMCD is a New Approach harmonised legislation meaning that it establishes mandatory essential requirements, but does not translate them into detailed specifications or processes. The use of European harmonised standards is voluntary, but a product manufactured in conformity with a European harmonised standard published in the Official Journal of the EU is presumed to comply with the Essential Health and Safety Requirements (EHSR) of the Directive that are covered by that standard. The EMCD also prevents non-compliant apparatus from being placed on the EU market and the national Market Surveillance Authorities are responsible for the enforcement of the Directive. 3Implementation / state of Play

All Member States have communicated to the Commission the texts of the main provisions of national law which they adopted in the fields covered by the EMCD. Currently, there are no infringement procedures in relation to the EMCD. Member States are responsible for appointing competent authorities responsible for the implementation of the Directive at national level and for ensuring that the Directive is effectively enforced within their territories. As such, they are also responsible for market surveillance, including penalties. 3.1Relevant Bodies Several specific bodies assist the Commission in managing, monitoring and enforcing the implementation of the EMCD: The Committee on Electromagnetic Compatibility was established under Article 41 of the EMCD. It consists of representatives from the EU Member States as members, as well as EFTA countries and Turkey, as observers. The European Commission is required to consult the committee when implementing acts that are prepared under the EMCD and on any questions where the opinion of sectoral experts is required by EU legislation (notably Regulation (EU) No 1025/2012 on European standardisation). The EMC Working Party (EMC WP) provides a forum to discuss specific issues related to the implementation of the EMCD between the Commission and relevant stakeholders. It consists of representatives from the Member States, who are members, as well as EEA/ EFTA countries and Turkey, who participate as observers and it is chaired by the Commission. Non-state stakeholders, such as standardisation organisation, industry representatives, consumers associations, etc., are also invited to participate as observers. The EMC Administrative Cooperation Group’s (EMC ADCO) purpose is to discuss market surveillance issues relating to the EMCD at EU level. It is composed of the national market surveillance authorities responsible for the enforcement of the Directive and it is chaired by the Member States’ Market Surveillance Authorities (MSAs). The role of the EUANB Group of Notified Bodies (NBs) is to discuss key issues relating to the role of notified bodies in supporting the conformity assessment of products within the EMCD’s scope. Economic operators may use the services of a notified body, the only recognised third-party approved to do so, but their use is voluntary. 3.2Guidelines Additionally to the above groups, the Guide on the application of the EMCD developed in cooperation with all stakeholders represented in the EMCD Working Group, is a widely used tool that is highly appreciated for facilitating the effective and efficient application of the Directive. 3.3European standardisation The European harmonised standards (hENs) give presumption of conformity with the Directive when published in the Official Journal of the EU (OJEU). They underpin the implementation of the EMCD but their use is voluntary. These harmonised standards are developed by the European standardisation organisations (CEN, CENELEC and ETSI) with an active participation of the industry, consumers and workers representatives. Harmonised standard translate the Essential Requirements into detailed technical specifications for certain types of product. The functioning of the European Standardisation System has an impact on the implementation of the EMCD. Stakeholders signal issues with inter alia timely publication of hENs and the inclusiveness of the system. However, evaluation of the European standardisation is out of the scope of this evaluation. The Commission plans as regards the European standardisation are presented in the Standardisation Strategy of February 2022. 4Methodology 4.1Data collection and consultation strategy The evaluation study was conducted from January 2020 to May 2021, with data collection activities running until February 2021, as presented in detail in Annex 3. The findings of the study are based on a programme of research and analysis, which included the following: -Desk research Desk research was a constant activity during the whole study. Relevant documentation was analysed, including the EMCD and its predecessors, and other relevant safety legislation impacted by EMCD (e.g. the Machinery Directive and Low Voltage Directive, Radio Equipment Directive), along with the horizontal legal framework provided for by the New Legislative Framework (NLF). A review of the EMC ADCO Joint Market Surveillance Campaigns on specific products was undertaken, as well as other previous studies. Academic research focusing on electromagnetic disturbance related issues relevant to five product-based case studies was also reviewed. In addition, as part of an analysis of the electrical equipment market and its evolution, three sets of Eurostat databases were considered, namely Prodcom, Comext and the Structural Business Statistics datasets and some market research data were also analysed. -Interviews A total of 112 interviews were carried out as part of the consultation activities. The consultations were as wide as possible, with an effort to ensure an appropriate balance across different types of stakeholders and in terms of broad representativeness. Stakeholders from third countries were also interviewed with the aim of completing the understanding of legislative systems for EMCD products in other regions of the world (presented in Annex 5), and possibly spot ‘best practices’.

-Consultations Two online consultations were carried out: oTargeted stakeholder survey The stakeholder survey was launched on 20 July 2020, addressed to the sector’s relevant stakeholders and closed the 20 of October (total of 14 weeks). In total, 458 respondents answered the survey. A good balance was achieved in the survey responses between the different types of stakeholders involved. Overall, industry represented 56.1% of the total responses (industry associations + economic operators) to the targeted consultation. The other types of survey respondents were mainly laboratories (14.2%), MSAs (5.5%), national authorities (7.2%), notified bodies (3.5%) and standardisation organisations (2.8%). There were challenges in obtaining responses however from SMEs and consumer associations. The latter was because the EMCD is quite technical and few consumer associations follow the Directive, but instead responses were received from users and radio amateurs. It can be assumed that to some extent these could represent the consumer perspective. oPublic Consultation A public consultation was launched on 9 October 2020 for 16 weeks (extended from 12 weeks due to Covid-19). The questionnaire was addressed to all EU citizens and stakeholders, and gathered 854 replies across 15 Member States and 7 other countries. The most common country of origin of respondents was Germany with 59.4% of responses (507). Respondents from EU Member States (836) accounted for 98% of the total. The largest group of respondents by type were ‘users of electric equipment/apparatus/fixed installation (individual citizen or other types of organisations)’. This group represented 60% of all consultation responses. The next largest group was the ‘radio amateur organisation or other citizen-based organisation’, accounting for 29% of responses (248). The answers for these two groups tend to follow a similar pattern, suggesting coordinated replies and that the ‘user’ group mainly includes radio amateurs. Few SMEs replied to either of the two consultations. -Workshops Four separate webinars were organised in October 2020. These involved the participation of a wide range of stakeholders from among members of the EMC Working Party (WP) and EMC ADCO. In addition, various presentations were made to engage with relevant stakeholders, including the EUANB (notified bodies). 4.2Data analysis methodology The data analysis was based on an assessment of the data gathered through desk research and stakeholder consultations. This consisted of a review of the results of the stakeholder consultations (interview and both consultation on line), analysing the results to the evaluation roadmap consultations (25 respondents), analysing the data on market size and structure and the data on costs and benefits. Mitigation measures have been taken to ensure impartiality of responses to the consultation activities, for example by tackling the under representation of certain stakeholders groups (as explained in section 4.1 on Methodology). Given the very wide range of the products across different sectors covered by the Directive, in agreement with the Market Surveillance authorities, 14 products were selected for the market analysis. From these, 5 were selected for case studies (presented in Annex 5). 4.3Statistical data on products in the scope of the EMCD The EMCD covers the great majority of the electrical products. For this reason the market analysis was streamlined to 14 products, (including both apparatus and fixed installations) selected in collaboration with the EMCD ADCO members. While the 14 products represent a relatively small share of the entire European electrical equipment market, their choice was intended to strike a balance between products identified as being problematic from an electromagnetic disturbance perspective, and other products under the EMCD scope that do not necessarily cause emissions concerns or present immunity problems. See Annex 3 for a detailed list and choice. While for 9 products it was possible to identify the corresponding NACE Prodcom and CN categories (microwaves ovens, washing machines, vacuum cleaners, power tools, solar inverters, screens signage, air conditioning installations, wind turbines, and cable TV networks), for other 5 (LED lights, induction hob, switching power supply, Powerline Communications, and computer networks) the matching of products to available statistical sources was more challenging. This is because the available product codes are not specific to these product types, but encompass a broader range of products. For instance, LED lights comprise a share of the Electric lamps and lighting fittings covered by a Prodcom code which also includes fluorescent, HID, incandescent lamps and lighting fittings. The collection of specific market data for some fixed installations was more challenging than for individual apparatus. One installation may embed several apparatus (for example, an air conditioning system is made of an outside condenser, an inside vent, and connectors) thus making the identification of the specific units of the statistical analysis more challenging. Nevertheless, for most of the fixed installations selected (air conditioning installations, computer networks, screens signage, wind turbines and cable TV networks), it was possible to identify the product codes of the components which make up the major part of the installation and which most likely act as source of the disturbance, or raise other EMCD related issues under the study scope.

From the available market data, it is not possible to measure the impact of the EMCD on the market. This data is therefore only sufficient to paint a background picture. Hence, the evaluations findings are more based on other sources of information, such as the consultations, than the market data which was summarised in Annex 4. 4.4Estimation of Cost and benefits for EMCD A list of possible costs and benefits generated by the EMCD was composed and used to collect feedback from relevant stakeholders through the targeted consultation and in-depth interviews. It should be noted however that stakeholders consulted provided very limited quantitative data on the costs and the benefits of the EMCD. Detailed information on statistical data used for products within the scope of the EMCD and cost and benefits data is provided in Annex 3 (Table 1-1 Costs generated by the EMCD and Table 1-2 Benefits generated by the EMCD) 5Analysis and Answers to the Evaluation Questions 5.1Findings in relation to the Effectiveness of the Directive This section presents the findings on the EMCD's effectiveness at the level of its core objectives: facilitating the free movement of electrical equipment across the Union and avoiding any electromagnetic disturbance between equipment. The majority of respondents to the targeted stakeholder survey (e.g. industry associations, economic operators and market surveillance authorities) agreed that the Directive is effective in achieving its general objectives (Figure 5-1). The most notable exception is that radio amateur associations and their members were less positive regarding the perceived electromagnetic disturbance generated by certain types of equipment. It should be noted that a low number of responses from SMEs and consumer associations were provided. For instance, only three national consumer associations responded to the questionnaire and there was no qualitative open feedback from these to justify their responses. The general perception of the effectiveness of the EMCD among targeted respondents seems to be more positive than the perceptions occurring from the public consultation. Source: Targeted consultation for the European Commission Free movement of goods Regarding the Directive’s contribution to the internal market, it is difficult to disentangle the role of the EMCD from other factors in the growth of intra- and extra-EU trade. The analysis of data presented in Annex 4 – Analysis of the EMCD market, indicate clearly that the production and trade have been growing. It can be assumed that this was the case partly due to the existence of EU-level legislation setting EMC-relevant requirements for products, however the exact magnitude of this impact is not possible to obtain. The above assumption seems to be confirmed with stakeholder views. The majority of the targeted consultation respondents (78.3% out of 299 who replied to this question) perceived the EMCD as having been either very effective (159 respondents, 53.2%) or somewhat effective (75 respondents, 25.1%) in ensuring the free movement of electrical and electronic apparatus in the internal market. Only 3.0% perceived that the EMCD had been either very ineffective, or somewhat ineffective.

Industry associations were most favourable about the EMCD having fostered the uptake of electrical/electronic goods by ensuring that apparatus placed on the market complied with an adequate level of electromagnetic compatibility (EMC). Manufacturers were also positive, but less than industry associations. Notified bodies were also positive about the Directive’s role in fostering the single market’. Laboratories and MSAs also commonly either perceived the EMCD as ‘highly effective’ or ‘somewhat effective’. Source: Targeted consultation for the European Commission When it comes to the size of stakeholders’ groups, medium and large organisations strongly agreed that the EMCD has either been ‘highly effective’ or ‘somewhat effective’ in fostering the free movement of electrical/electronic goods in the internal market (Figure 5-3). Unfortunately, there were quite limited responses from micro (2 firms) and small firms (10 firms) to the consultation, and 7 of the small firms were also consultancies providing advice to manufacturers regarding EMCD compliance rather than being producers themselves. Their appreciation is also “highly effective”. From a trade flow perspective, intra-EU27 trade for the 14 products within the scope has consistently been larger than extra-EU27 trade in the period between 2002 and 2018 (the period data was available for). More specifically, in the past two decades, the value of trade among the current EU Member States has fluctuated around 55% of total trade in the products concerned. Furthermore, in the past 5 years, intra-EU27 exports have grown more rapidly than extra-EU27 exports (Table 5-1), pointing to the importance of the internal market for the selected products. Despite the significant growth in intra-EU trade for products falling under EMCD scope, it is difficult to establish attribution, in that changes in market size and trade over time are not solely due to the EMCD but also to other factors. Table 5-1 - Intra and extra-EU27 export of the 14 selected products, compound annual growth rate (CAGR). 2002-2018. EU27 Figure 5-3 – Fostering the free movement of electrical and electronic apparatus in an internal market context – answers by size of economic operator (N=109) Reducing electromagnetic disturbances EMCD aims to create an acceptable electromagnetic environment whilst ensuring that equipment will function as intended in that environment. Most electrical and electronic equipment generates electromagnetic fields that are perceptible in their environment; all of these fields create pollution that sometimes disturbs the operation of other equipment. Regarding the Directive’s contribution towards reducing the level of EM disturbance, the analysis was mainly supported by consultations given that there is not systemic measurement of EM disturbances other than surveillance campaigns on targeted products. This said, 78% of respondents to the targeted consultation who replied to this question perceived that the Directive had been either highly effective (44%, 133) or somewhat effective (34%, 101). These findings were broadly corroborated through interviews, with almost all categories of stakeholders stating that in their view, the Directive had been effective overall. However, some respondents to the public consultation were less positive regarding the Directive’s effectiveness in this respect, namely radio amateurs and their representative associations (see later for more details). According to interviews results, the EMCD has reduced disturbance overall for instance through the setting of Limit Values in products, which have encouraged manufacturers to take issues around EM disturbance and immunity more seriously and to invest in some measures, such as fostering interest in good EMC design, the use of shielding and filtering. This in turn has helped to foster the free movement of electrical equipment. However, radio amateurs and some MSAs noted that some problematic products continue to generate disturbance (e.g. Powerline Communications, some low-quality LED lights, solar panel inverters). The reasons for this are that some products are poorly designed from an EMC-perspective (e.g. PLCs as they frequently do not contain filters), others are of varying quality and fail to include appropriate immunity measures, such as filters and shielding. Case study findings indicated that even though there may be some products where disturbance remains a problem, this does not suggest that the Directive is ineffective, as it is more a question of strengthening the effectiveness of harmonised standards and of standards development processes to ensure that problematic products with high levels of disturbance are addressed. Harmonised standards are however voluntary. Also, the functioning of the European Standardisation System is however not in the scope of this evaluation (please see the Standardisation Strategy). There was an agreement among the respondents to the targeted consultation that the EMCD has made an important contribution in reducing the incidence of EM disturbance leading to the incorrect functioning of equipment (44.5% responded ‘highly effective’ and 33.8% ‘somewhat effective’), with a combined total of 78.3% of the 299 respondents who replied to this question. This was also confirmed through the interviews. Many stakeholders (especially industry associations, manufacturers, MSAs) commented that the Directive has played an important role in drawing attention to the issue of electromagnetic compatibility and of the importance of designing products that design-in EMC from the outset. This was viewed as having improved the situation by ensuring that electromagnetic emissions produced by apparatus are within acceptable levels and in strengthening the inclusion of EMC immunity measures in products (such as shielding, casing, etc.). Promotion of good engineering practices, in particular as regards fixed installations, were also credited to the EMCD, particularly by development of practices in terms of how to follow suppliers’ instructions and documenting EMC compliance. In the respect, adding fixed installations to the scope of the Directive in 2004 is considered to have been a substantial improvement. The good practices that have been fostered by the EMCD in turn brought reputational benefits to the EU, which may encourage other geographies decide to adopt EU approaches to the regulation of EMC.

Among the 14 products on which the evaluation focused, 5 products were chosen for more in-depth case studies. These 5 products are well known for having EMC disturbance problems, such as some types of LED lights, powerline communications, RMCD cables (presently outside the EMCD’s scope) etc. Some of these products (e.g. powerline communications) were found to interfere with other equipment in some cases and although harmonised standards have played a role in addressing the problem, challenges remain in the views of radio amateurs and MSAs. In particular, the case studies showed that there are concerns regarding the cumulative impacts of disturbance. Feedback through the interview programme and targeted consultation stated that immunity to electromagnetic disturbances should remain part of the EMC Directive. In third countries, immunity is often not an EMC requirement, and therefore not regulated. This issue is explored in Annex 3. Source: Targeted consultation for the European Commission Many industry associations and individual firms pointed out that despite the huge increase in the volume of electrical equipment on the market (see Section 5, Analyses of the EMCD Market), the incidence of complaints and problems regarding equipment not working does not appear to have increased. During the public consultation, 40% of respondents (339 of 848 respondents) found the Directive ineffective in reducing electromagnetic disturbance and the incorrect functioning of electric equipment placed on the European single market. It should be noted that this reflects the fact that many radio amateurs responded to the public consultation, many of whom were part of a coordinated response organised by radio amateur associations (129 out of 245 ) or answered as a user of electric equipment (184 out of 514). Their main concern was that despite the Directive having been in existence for more than 30 years, there continues to be a problem around EM disturbance. Indeed, many radio amateurs perceived the situation as having progressively worsened in the past decade in particular. They attributed this to the growing ubiquity of electrical equipment, and to the cumulative effects on disturbance. This may prevent amateur radio equipment from working correctly. The increase of electrical devices on the market related to IoT concerns mainly wireless devices which fall under the scope of the RED rather than the EMCD. Nonetheless, in parallel there has been a corresponding growth of the market of the electrical equipment in general with new products for new uses. This means that the scope of products falling under the EMCD remains very large. Moreover the EMCD’s relevance has increased because the large amount of electrical devices falling under its scope now operate in a changed environment, for which they might not have been initially intended. This might warrant considering more stringent limit values in some cases and also reviewing limit values in harmonised standards more regularly. New Legislative Framework Within the New Legislative Framework (NLF), legislation only sets out high-level essential requirements. The EMCD was converted to the NLF with the last revision. Its essential requirements simply state that (a) the electromagnetic disturbance generated does not exceed the level above which radio and telecommunications equipment or other equipment cannot operate as intended; and that (b) it has a level of immunity to the electromagnetic disturbance to be expected in its intended use which allows it to operate without unacceptable degradation of its intended use. For any NLF legislation, the Commission can ask the European Standardisation Organisations to develop standards that give the technical details to fulfil the essential requirements. If a manufacturer then uses one of those Harmonised Standards for its products, that have been cited in the Official Journal, it is presumed that the product is compliant with the EU legislation, in this case the EMCD. However, the use of Harmonised Standards to demonstrate compliance is voluntary. Respondents to the targeted survey had a positive perception. They attributed the effectiveness of the Directive mainly to a high-level essential requirements which are formulated in such a way that they cover all EMC phenomena and all technologies including new technological developments at a high-level, but also with voluntary harmonised standards as an appropriate means of addressing the detailed technical requirements (the directive should remain technology neutral). The targeted survey shows that the impact of the NLF alignment was quite positive. Thanks to the alignment to the NLF, the current EMCD clarifies the definitions and obligations of economic operators, regulates the conformity assessment, clarifies the meaning of CE marking and improves the procedures on market surveillance. The main improvement identified by industry was the clarification of responsibilities among different economic operators (EOs) in the supply chain for ensuring compliance with the EMCD’s essential requirements, and strengthening the traceability of products. The integration of common arrangements for market surveillance and common accreditation rules to ensure the quality of the services of conformity assessment bodies was also viewed positively. Regarding the use of Harmonised Standards (HS), stakeholders were positive about the role played by harmonised standards as a mechanism for implementing the EMCD in a technology-neutral manner. The Economic Operators view them as being an essential part of the overall implementation regime to support the Directive’s implementation, even if non-obligatory. As European Harmonised Standards are not mandatory under the EMCD, they are outside the scope of this evaluation, but feedback was received regarding their effectiveness in supporting the implementation of the EMCD through the stakeholder consultations (See Annex 2) Others believe that the requirements for EMC emissions of products set in the harmonised standards are too low and that setting more demanding standards would be more likely to drive innovation (or, at least, less likely to stifle it). While all targeted stakeholders recognised the positive role played by the NLF in strengthening coordination within the EU-27, they expressed concerns about the effectiveness of market surveillance. The respondents to the targeted consultation and interviews reported enforcement divergences among market surveillance authorities in terms of the number of inspections or the type of enforcement activities (e.g. with limited checks of the technical characteristics of products physically in some countries and a perceived over-dependence on checking product technical documentation). Furthermore, the e-commerce with online platforms and the related use of fulfilment centres caused some concerns for stakeholders. While they have potential to ease the distribution of various electrical equipment from third countries into the EU, they also ease the entry on the market of potentially sub-standard or non-compliant products. Such products cannot be distinguished by consumers. Moreover, non-EMCD compliance was not perceived as being a sufficient reason that would deter consumers from purchasing the product, as they are mainly influenced by the price. This situation points to the necessity of an effective market surveillance. This being said, some steps are being taken by the Commission to clarify e-commerce rules but challenges remain in particular related to market surveillance. Market surveillance authorities have – to various degrees - started developing capacities and tools to help market surveillance for products sold online, but have not yet caught up with this fast-evolving sector.

Barriers to innovation Electromagnetic disturbances could, for example, slow down the development of connected radio equipment, because it would be in a disturbing electromagnetic environment (surrounded by other emitting equipment), which would prevent their correct operation. This is relevant as a lot of new innovative equipment is based on wireless communication. This problem can also apply to non-radio equipment which can also be impacted by these disturbances and thus risk having a brake on their development and therefore on innovation. Regarding the extent to which the EMCD has prevented barriers to innovation in the development of electrical equipment, there are high levels of perceived effectiveness. Just over half of the 299 respondents to the targeted survey considered that the EMCD had been highly effective (33.4%, 100 respondents) or somewhat effective (21.7%, 65 respondents) in this respect, in particular due to essential requirements’ technological neutrality that can be met though the voluntary use of harmonised standards, which are developed by the industry. Only 9% of the targeted survey respondents considered that the Directive had been somewhat ineffective at preventing barriers to innovation and 2% very ineffective. Among the 119 firms which provided data on their size, 5 out of the 89 large firms found the EMCD to be somewhat ineffective in this respect. Among the 30 SMEs that responded, only 7 found the EMCD somewhat ineffective. As neither larger nor smaller firms further substantiated their views, it is unknown why SMEs take a more optimistic view than larger firms. Of the 119 firms which provided data on their size expressed the view that the EMCD was highly ineffective, nor did any of the responding manufacturers. Figure 5-4 presents general replies to this question. Stakeholders consider that the essential requirements have been formulated in a way that they are able to cover all EMC phenomena and all technologies, including new technological developments. More generally, one of the ways in which EMCD has prevented barriers to innovation, is that without a legally binding text (EMCD) requiring manufacturers to take charge of the electromagnetic effect of their equipment, there would potentially be lower-quality equipment on the market without appropriate mitigation measures to address disturbance and to ensure immunity (e.g. filters, shielding) leading to an increased risk of electromagnetic disturbance. In addition, some industry stakeholders pointed to requirements in the EMCD and in harmonised standards as driving innovation in terms of good practices in electromagnetic compatibility by encouraging manufacturers to design-in good EMC from the outset and to strive to achieve reductions in disturbance that go beyond the Limit Values specified in harmonised standards. Source: Targeted consultation for the European Commission Many stakeholders, across all stakeholder groups, expressed the view that harmonised standards are the best instrument to keep pace with technological ‘state of the art’. Among stakeholders who considered the EMCD to have been effective in preventing barriers to innovation, a commonly held view was that harmonised standards are the best means of addressing the technical requirements for existing and emerging technologies. The essential requirements were seen as being technology-neutral and sufficiently generic to be open to innovative products (even to the extent of promoting innovation in the view of some stakeholders), while still being sufficiently precise to achieve the EMCD’s other regulatory objectives. Some consider that a lack of standards for new and emerging technology has an adverse impact on product innovation with electromagnetic interference cases emerging until new standards are issued. 5.2Findings in relation to the Efficiency of the Directive This section maps the costs and benefits generated by the EMCD and examine the extent to which its objectives were achieved in an efficient manner. Overall appreciation of costs and benefits The results of both the targeted consultation and the interviews, despite the limitations in terms of representativeness, indicate that benefits generated by the EMCD are considerably higher than its costs. According to information collected through interviews with small and micro enterprises and EMC experts, cost drivers for small businesses are largely similar to those identified through the consultation of large enterprises, with a stronger emphasis on the burden for small businesses of familiarisation with obligations included in the EMCD. Maintaining the expertise in the field of EMCD is reported to be harder for a small firm than it is for a large one, since it requires special knowledge and understanding but hardly any small business can afford to have employees dealing with it full time. In turn, this difficulty in developing EMCD expertise within small businesses can lead to more misinterpretation and misunderstanding of the requirements. Also product testing tends to be more costly for smaller businesses, because they usually do not have their own testing facilities.

Source: Targeted consultation for the European Commission The public consultation indicated as well that EMCD’s benefits outweighs the costs. Almost half of the respondents (19 out of 41 respondents) considered that benefits greatly outweigh costs and 12 respondents that benefits somewhat outweigh costs (see figure 5-7). Source: Public consultation for the European Commission The analysis of stakeholders’ replies concerning costs and benefits also indicates that benefits generated by the EMCD outweigh costs, and the affordability of costs has not been put in question by the different respondent types: benefits have thus been achieved at a reasonable cost. However, this is difficult to quantify precisely in monetary terms due to the lack of data, especially on benefits. Nonetheless, the structured analysis of costs and benefits sheds light on a crucial difference in their nature: the benefits of the EMCD are predominantly of a strategic nature, while the costs pertain to enforcement and implementation. Figure 5‑8 – Targeted consultation – Share of replies to question on benefit-cost ratio by stakeholder type (N = 212) Source: Targeted consultation for the European Commission In the overall opinion of the stakeholders consulted, the EMCD is currently working well in terms of its efficiency. No significant scope for cost reduction has in fact been identified by the stakeholders consulted. Analysis of costs for the economic operators Manufacturers see the costs of complying with the EMCD as an integral part of the product development. Therefore, they are difficult to specify. For 23 out of 38 respondents, the EMCD-compliance costs indicated the range between 5 and 15% of the total production costs (Figure 5-9). The interviews confirmed that the costs have that order of magnitude. Figure 5‑9 – Targeted consultation – Replies to question on compliance with the EMCD as a percentage of the total cost of production (N = 38)

Source: Targeted consultation for the European Commission As we can see in the figure (5-10) below, EMC-relevant costs of product development and costs related to the conformity assessment to produce the technical file are the types of costs most frequently identified as being costly. Considering the costs of product development, 80% of N=83 respondents (means 66 respondents) perceived these costs as “quite costly” for 49% (means 41 respondents) or “very costly” for 31% (means 26 respondents). Similarly, 79% of respondents (66) considered the conformity assessment-related costs to be either “quite costly” (46% means 38) or “very costly” (33% means 27). The costs of keeping technical documentation updated for 10 years and the costs of familiarisation with the legal obligations of costs are perceived as relatively costly (“quite costly”). The cost of an authorised representative has been pointed out as costly by 25% (21) of respondents, with just a marginal share (5% means 4 respondents) highlighting it as “very costly”. While other costs have in some cases been signalled by stakeholders, no evidence has been found of a wide perception of additional burdensome costs. Source: Targeted consultation for the European Commission However, even though manufacturers do incur costs that are EMC-related, only a small percentage of these costs can be attributed to the EMCD, as it is strongly in manufacturers’ interest to ensure the correct functioning of the products they manufacture and to prevent disturbance. According to the interviews and experts, it was estimated that business-as-usual costs account for a least 80% of the identified costs. EMC-relevant costs of product development for an EMCD-compliant product can be split into cost of purchasing the relevant standards, the related engineering costs, the cost of pre-testing; and the cost of risk assessment. Given that a considerable percentage consultation respondents considers the costs to be quite high, ways to lower the costs should be investigated, in particular whether there is any potential for simplification. Operators can purchase the relevant standards in order to satisfy the EMCD essential requirements. The cost for standard varies depending on the product. The interview feedback provided evidence that there are many long-established EMC-related product family standards that are generic and used across many different product categories that have common characteristics and may operate in the same environment (e.g. low-voltage household equipment). There are also product-specific standards, which are typically costlier. Evidence collected through the targeted consultation points to a cost ranging from €1,000 (for products such as personal computers, servers, notebooks, telecommunications equipment and frequency converters of 7,5kW) up to €15,000 for elevators and escalators. In total, 7 responses were received to the open-ended question on the costs of purchasing relevant standards. These estimates all are provided by individual respondents in relation to different product types. EMC-related engineering costs (i.e. EMC costs as part of product development) are the key driver among development costs and the most significant EMC-related cost for operators, according to evidence collected from the interview programme. Frequently, the solution to overcoming challenges in designing products in a way that ensures good EMC lies in the overall product layout (which requires sound and state of the art engineering practices), and not necessarily primarily measures to strengthen immunity. Notwithstanding, immunity measures such as shielding, filtering or casing are sometimes incorporated into product design and there are associated costs. According to EMC experts interviewed, the cost of pre-testing for EMC purposes, as part of product development, is extremely variable depending on the frequency of testing, the needs and the tools used. Tools can cost between €2,000 and €30,000 – only as far as testing electromagnetic emissions are concerned. For the immunity part, tools for pre-testing cost between €7,000 and €30,000. It should be stressed that the pre-testing phase may require that products’ EMC performance is tested more than once, as there are commonly several stages in product development. Some economic operators interviewed explained that products can be tested up to several times as part of product development processes, initially at the prototyping stage, and then subsequently, as the product is developed. The costs of ensuring compliance during the production process is considered as being either quite costly or very costly by 65% of stakeholders, while 23% of respondents considered it not costly. The costs of conformity assessment, which is borne by economic operators (mainly manufacturers), is overall considered to be either quite costly or very costly by 80% of EMC experts (eight of ten respondents) and 80% of manufacturers (56 of 70 respondents) (80% among both large and medium manufacturers). However, while 40% of medium-sized manufacturers view this item as very costly, the share decreases to 27% when it comes to large manufacturers . There are three types of conformity assessment costs, namely: the cost of preparing technical documentation; the cost of laboratory tests; and the cost of a notified body should the manufacturer wish to use their services (the use of NBs is not mandatory under the EMCD). According to replies to the targeted consultation, the costs of technical documentation as part of the conformity assessment procedure ranges between €1,000 and €10,000 per product. The costs of performing laboratory tests as part of conformity assessment procedures can refer to testing in either third-party laboratories or internal laboratories. De facto, only large companies generally have internal laboratories, due to the high costs associated with EMC testing. According to an industry association, the cost of setting up an EMC testing laboratory is approximately €1 million minimum (one-off cost of a 3-meter EMC testing chamber). Costs of a 10-meter testing chamber are significantly higher (even 4-5 times higher) In addition to the significant initial capital investment for setting up a laboratory, there are annual maintenance costs, related to the need for the recalibration and repair of equipment, staffing costs, and the costs of testing products’ compliance with the essential requirements when new harmonised standards are adopted, and/or existing standards are updated. Different stakeholders reported that external laboratories have a fee per day of €800- €1,500 in the EU. Testing a product requires several days, and is estimated to cost about €15,000 on average, irrespective of the product type. Other estimates distinguish between lower testing costs for less complex products (about €5,000) and higher costs for more complex ones (up to €20,000) The involvement of a notified body, according to evidence gathered through the interview programme, is generally less favoured than internal production control. According to EMC consultants, involving a notified body is considered useful for new market participants, who have less experience. Some interviewees stated that using a notified body could typically add €5,000 – €20,000 in costs, depending how complex the product is. Several individual firms commented that they were reluctant to use a notified body, as they already use third-party external testing laboratories during the conformity assessment process and therefore, using a notified body provides an additional layer of costs that, as it is non-mandatory, they would prefer to avoid Testing costs were seen as higher than for product safety directives due to the specialist nature of laboratory equipment (e.g. EMC testing chamber). However, the self-certification approach made possible by the EMCD significantly contributes to keeping costs relatively low and grants a certain level of flexibility to economic operators.

The cost of familiarisation with the legal framework (e.g. familiarisation with applicable obligations; identification of relevant standards; training of staff) is considered as quite costly by more than 50% of respondents (45 out of 83) and 11% perceive such costs as being very costly. During the interview programme, familiarisation costs were not considered to be one of the main drivers of compliance costs by large firms. While some effort and resources are necessary to familiarise with the EMCD regulatory framework (as suggested by the targeted consultation at an anecdotal level), stakeholders underlined that thanks to the harmonised regulatory framework, economic operators do not face 27 different national legal regimes and therefore can avoid a significantly higher cost of familiarisation with legal rules. In other words, there are cost savings compared with a counterfactual scenario in which there were no EU rules. According to interviewed small and micro enterprises, however, costs of familiarising with legal obligations are relevant for them, especially in cases where no specialised full-time position is present within the firm to deal with compliance. The costs of keeping technical documentation updated for 10 years, as required by the EMCD, is not considered as a major cost driver by respondents to the targeted consultation. It remained unclear why respondents considered these administrative compliance costs as disproportional. The costs of using an authorised representatives is mainly applicable to manufacturers in third countries that do not have a legal presence in the EU. Accordingly, it is not surprising that 40% of respondents chose the option “Not applicable” and 20% “Don’t know”. Of the remaining manufacturers, 17 considered authorised representatives to be “Quite costly” (16 respondents) or “Very costly” (1 respondent). Analysis of benefits The assessment of benefits has considered the extent to which the existence of the EMCD has brought about benefits and whether any of these can be monetised. The results of the targeted consultation indicate that different benefits have been strongly associated with the EMCD’s implementation (see Figure 5-11 below). Source: Targeted consultation for the European Commission Overall, the reduction of the incidence of electromagnetic disturbance leading to the incorrect functioning of electrical equipment is a benefit accrued to overall society. A broad consensus was found among respondents to the targeted consultation: 82% of respondents (178 out of 216) stated that this reduction generates “strong benefits” (56%) or “some benefits” (26%). This opinion is shared across countries and across all different stakeholder types participating in the survey . In particular, 68% of manufacturers (42 out of 62) and 75% of industry associations (33 out of 44) considered the reduction as a strong benefit. The EMCD brings about benefits for businesses in terms of market efficiency as it reduces market barriers and costs for economic operators. First and foremost, by setting up an EU-wide framework, the EMCD prevents fragmentation into different national regulatory systems, which would entail significantly higher costs for industry in accessing different national markets. Thanks to the single market, the manufacturers’ burden in terms of familiarisation with legal obligations is reduced and, most importantly, costs associated with exporting goods are reduced as well. In addition, whereas when the EMCD was first adopted in 1989, internal production control using self-assessment wasn’t possible. This was changed in 2004. The EMCD’s alignment with the NLF in 2014 with its modular approach improved the conformity assessment with the explicit possibility of self-assessment. This was viewed by stakeholders interviewed (e.g. industry associations, individual economic operators) as having helped to reduce the costs of compliance for businesses, as it allows scope for a self-declaration of conformity based on internal production control. Based on the opinions gathered from a variety of manufacturers and EMC experts interviewed, it is clear that the EU regulatory regime (the EMCD and CE marking in particular) has strong international standing: the EMCD has de facto near-global relevance. Several interviewees highlighted that economic operators in markets such as Australia, China and Singapore frequently refer to EU legislation in their EMC-related requests, even in cases where different local regulatory requirements are also applicable. As a result, companies that are EMCD-compliant are well-positioned to compete globally, as their products generally do not have to undergo further modifications to enter numerous other markets worldwide. Accordingly, a clear benefit of the EMCD is that it has strengthened industrial competitiveness as the Directive is regarded as being robust, in that it covers both EM disturbance and immunity, flexible in that manufacturers determine how they comply with the essential requirements and easing access to other markets. Due to the strong reputation of the EMCD (and more generally of the EU product legislation), EMCD-compliant economic operators have an advantage when expanding to other markets. During the interview programme, a broad consensus was also reached about the benefit of preventing the incorrect functioning of electrical equipment being of crucial importance. Even though, economic operators may invest in good engineering practices even in the absence of a dedicated Directive, the EMCD has had a crucial role in raising awareness about EMC-related issues among manufacturers and industry more broadly. The reduction of the incidence of electromagnetic disturbance was perceived as being associated with the Directive. This has also been confirmed through interviews that identified examples of increased interest and awareness about the EMC of apparatus after the 2014 revision of the Directive, which increased economic operators’ attention to the topic (especially among manufacturers in Member States that gained EU accession more recently). The application of good engineering practices for fixed installations was considered as generating “some benefits” by about one-third of respondents (66 out of 216), followed by “strong benefits” (60). A high number of respondents stated they were not familiar with the issue (47 “Don’t know” replies). This was likely because they only deal with apparatus. Finally, the responses were analysed regarding how far the EMCD has increased electromagnetic immunity. 78% of targeted consultation respondents (169 out of 216) were of the opinion that “strong benefits” (102) or “some benefits” (67) were achieved as a result of EMCD implementation. Positive opinions remain prevalent across different stakeholder types and countries (to be noted, no notable differences by country). According to an EMC expert interviewed working at a large multinational based in a third country, the EMCD’s focus on electromagnetic immunity has proved to be a crucial benefit: even if initially faced with a certain scepticism (as third country legislation only focuses on emissions), this has ensured certainty for users and across the industry.

5.3Findings in relation to relevance of the EMCD There is a general consensus among stakeholders that the general objectives of Directive 2014/30/EU remain relevant today. As can be seen in the figure (5-12) below, the vast majority of respondents to the targeted consultation perceived the EMCD to be either ‘highly’ or ‘quite’ relevant today (N=237) in terms of achieving its two main objectives: creating free movement of goods and preventing electromagnetic disturbances. Source: Targeted consultation for the European Commission The results from the public consultation were strongly aligned to the findings of the targeted consultation. More specifically, 80% of public consultation respondents (N=844) considered the EMCD to still have a ‘high level of relevance’ (73%) or to have ‘some relevance’ (9%). However, radio amateurs responding to the public consultation thought that the EMCD is less relevant, as it wasn’t sufficiently effective in reducing electromagnetic disturbances, whereas other stakeholders responding to the public consultation, the targeted consultation and the interviews perceived the EMCD overall was relevant, despite the ongoing challenges associated with problematic products. There has been a significant evolution in the electrical equipment market in the last 5-10 years. This includes the advent of the Internet of Things (IoT), i.e. the trend towards more equipment being internet connected, and the emergence of new market players, including online platforms. The changes on electrical product market can be subdivided into two broad categories or themes, one of which relates to the changes affecting the distribution of products, while the other relates to the introduction of new products and functionalities. Distribution of products The EMCD has gained in relevance due to three main market changes: new economic operators entering the value chain; the development of e-commerce; and new distribution channels for putting products on the European market. Source: Targeted consultation for the European Commission A majority of respondents (combined 61% ‘to some extent’ corresponding to 61 respondents or ‘to a great extent’ corresponding to 82 respondents) perceive the presence of new economic operators entering the market to be a key change that is impacting the relevance of the EMCD. Those new types of operators (e.g., online platforms) are not defined in the EMCD. There is an ongoing horizontal discussion across NLF legislations on how to include such new operators. The development of e-commerce was considered as a change impacting the relevance of the EMCD by 139 out of 237 of the stakeholders surveyed (targeted survey). In particular, e-commerce trends were described by stakeholders as having the potential to facilitate the distribution of various electrical equipment from third countries into the EU. From a market surveillance perspective, products from non-EU countries sold in online marketplaces or online shops bear a higher risk of non-EMCD compliance. New distribution channels for placing products on the European market refers to the increase in sales directly to consumers from online platforms and the related use of fulfilment centres. 152 out of 237 stakeholders thought it affected the relevance of the EMCD. For example, when ordered on foreign online platforms and arriving in Europe in small postal packages rather than as large lots in containers, it is much more difficult for market surveillance authorities to verify the products’ compliance. Stakeholders perceived that one of the main changes in the last 10 years is the presence of more connected products that integrate new technologies with radio functionality (IoT, but also beyond). 50% of survey respondents (119 respondents) stated that this change impacted the relevance of the EMCD ‘to a great extent’, and 26% (62 respondents) ‘to some extent’, due to the integration of radio functionality in those products and thus convergence/overlap with the RED. The emergence of new types of electric equipment was also seen by the majority of stakeholders as affecting the EMCD’s relevance, with a combined 72% of respondents (171) agreeing with this statement ‘to a great extent’ (34% meaning 81 respondents), or ‘to some extent’ (38% meaning 90 respondents). Feedback gathered through the interviews and evaluation webinars conducted also indicated that these changes have had an impact on the EMCD’s ongoing relevance, particularly in terms of product scope. The scope of the EMCD Under the EMCD’s scope, certain categories of equipment are covered by a few exclusions, of which benign equipment is the most prominent.

The majority of respondents to the targeted consultation (173 of 233 respondents, 74%) perceive that the exclusion of benign equipment from the EMCD remains appropriate. However, qualitative feedback from the targeted consultation and the interviews, particularly with MSAs highlighted challenges as to the continued relevance of this exclusion. For example, unconnected cables are considered inherently benign. They are only falling under the EMCD if they are connected to devices falling within the EMCD’s scope. More specifically, it was noted that the wording of Article 2(2)(d), which defines which devices fall outside the EMCD’s scope, could be better specified in the Guide of the EMCD to provide greater clarity. Additionally, it was suggested that the EMCD’s relevance for ready-made connecting devices, including cables, could be reconsidered. MSAs were of the opinion that “ready-made connecting devices (and other cables)” should clearly be addressed by the EMCD. They contribute significantly to EM disturbance”. The degradation of old equipment and concept of reasonably expected lifetime of a product Old equipment can potentially become non-compliant and create high levels of disturbance which leads to the question of the relevance of introducing a product lifetime concept. Stakeholders (all types with prominent industry voice) highlighted a range of reasons why it is difficult to legislate old equipment which can potentially become non-compliant. There was a concern that introducing maximum product lifetime requirements could duplicate what is already in the Directive, as the degradation of equipment already needs to be considered by economic operators before equipment is placed on the market. As such, industry representatives noted that new provisions related to maximum product lifetime requirements could result in duplication of these existing requirements. The EMCD is presently concerned with placing on the market and not end-of-life disposal timeframes. As monitoring and surveillance activities are concerned with the period post placement on the market, the question was also raised whether there would be resources for surveillance authorities to monitor additional requirements. 5.4Findings in relation to the Coherence of the EMCD Overall, there was a strong positive consensus regarding the internal coherence of the text of the EMCD and its ease of application, in both the targeted consultation and interviews. None of the consulted people identified any major incoherence. In response to the targeted consultation 75% of the respondents (174 of 232 respondents) considered the EMCD to be coherent: 56% (131 respondents) considered it to be fully coherent and 19% (means 43 respondents) considered it to be partially coherent. Only 1% of the sample of respondents deemed the EMCD to be non-coherent, while 24% stated they do not know. As illustrated in the below figure, the EMCD is generally seen as a coherent directive, and the legal text is viewed as being clear. Source: Targeted consultation, CSES for the European Commission The internal coherence and definitions used in the EMCD The definitions used in the EMCD were generally seen as being clear and coherent, with only limited evidence emerging regarding any problems, challenges and gaps. Figure 5‑15 – Overall, to what extent is the EMCD clear and easy to apply? (N=237) Source: Targeted consultation for the European Commission

The definition of a fixed installation was regarded as being unclear by some stakeholders, and participants to the webinars with EMC ADCO raised the issue of the definition of a ‘fixed installation’, with some products having an uncertain delineation between equipment and fixed installations e.g. solar panels, air conditioners. Likewise, there was feedback regarding the need to clarify the definition of the “placing on the market of apparatus intended for fixed installations”. Some stakeholders perceived that there are somewhat divergent interpretations across different Member States, in particular among MSAs that carry out inspections of such installations. Stakeholder feedback was mixed about the exclusion of benign equipment. Clearer definitions could be included in the Directive as to when benign equipment should no longer be considered to be benign. In particular, cables may be benign but once plugged in and connected to apparatus, the cables may themselves generate emissions even if falling outside the EMCD’s scope. Whilst there was no consensus that cables should be included, and industry was against this idea, there were alternative suggestions made as to how to address the problem of passive equipment generating emissions in certain circumstances e.g. low-quality cables, incorrect cables not used with the correct device. Regarding the external coherence of the Directive, the evaluation analysed the coherence between the EMCD and other relevant legislation that the EMCD interplays with. For the external coherence of the Directive, there are two possibilities of application of the EMC requirements: One possibility is that the EMC requirements apply to products which fall under EMCD in conjunction with other applicable legislation (e.g. safety Directives such as the Low Voltage Directive (LVD), Machinery Directive (MD)). The second possibility is that the EMC requirements for products categories that fall exclusively under other EU legislation, such as for electrical equipment integrating radio functionality falling under the Radio Equipment Directive (RED) or for medical equipment falling under Regulation 2017/745, are already included in those pieces of legislation. Then, the EMCD does not have to be applied. Generally speaking, many interviewed respondents consider that the New Legislative Framework (NLF) has facilitated coherence between the different Directives, enhanced the coherence of the EMCD, has clarified definitions and has strengthened the coherence across legislation of the obligations for economic operators. For interviewed stakeholders, the common horizontal provisions introduced meant that the EMCD, the LVD (when the LVD is applied in conjunction with the EMCD) and the Radio Equipment Directive (RED), became more coherent with one another. Some industry associations would like to see electronic labelling introduced within the NLF, as it is the case in other jurisdictions, and also to have the same formal requirements in all legislation, including the EMCD. However, particular concern was raised when considering the relationship between the EMCD and the RED. 45.0% of the respondents in the targeted consultations experiencing some problems due to a perceived overlap and inconsistencies between the two pieces of legislation, as illustrated in Figure 6 - 1 6 ‑ below. Please see the section below dedicated to RED for further details. Source: Targeted consultation Concerns were less strong with regard to the safety directives being applied in parallel with the EMCD requirements (i.e. the MD and the LVD). Indeed, only 6.6% of respondents stated that there was an issue in applying the MD together with the EMCD, and 11.4% the LVD and EMCD. Coherence between the EMCD and the RED Despite the fact that the two Directives, EMCD and RED, are mutually exclusive, a relatively high percentage of respondents perceived incoherence between the EMCD and the RED and difficulty in determining which directive they should follow. For instance, during the interviews it turned out that the delineation between certain products falling under the EMCD and RED was not always clear for manufacturers. Some respondents, such as industry associations, stated that their members had experienced some confusion as to which directive to follow for specialised equipment. This was mostly due to a perceived lack of adequate coherence in the RED itself, rather than the EMCD. Additionally, the fact that there is a wider range of harmonised standards available under the EMCD than EMC standards under the RED, led to confusion among some manufacturers. Whilst it is clear that the two Directives are mutually exclusive, the same product might still have to comply with harmonised standards supporting different pieces of legislation. It was perceived as being challenging for products to follow different EMC-related harmonised standards (HS) for radio functionality and electromagnetic functionality respectively, mostly because of the lacking coordination of their publication. However, this lack of synchronisation is extraneous to the Directive and can be addressed through an improved coordination in the adoption of these standards by the ESOs. Coherence between the EMCD and other relevant sectoral legislation As shown in the targeted survey findings, it was not generally perceived that there was a coherence problem between the EMCD and safety directives, notably the Low Voltage Directive (LVD) and the Machinery Directive (MD). The Directives were rather seen by stakeholders as being complementary. Respondents also emphasised that the EMCD is “phenomenon-related” rather than a safety directive. According to a large enterprise interviewed, the distinction is considered important and should be maintained. The EMCD requires that manufacturers ‘shall include an adequate analysis of the risk(s) (e.g., perturbation). However, this does not include any assessment of safety risks. The general consensus across the majority of stakeholders interviewed (including MSAs, notified bodies and industry) is that the EMCD should remain concerned with electromagnetic compatibility only, and not with safety. Interviewees stated that the Low Voltage Directive (LVD) already deals with electrical safety and other Directives such as the Machinery Directive with product safety. The majority of stakeholders responded that there weren’t any problems related to overlaps and inconsistencies between the EMCD and the Machinery Directive (58%), and between the EMCD and Low Voltage Directive (69%). Additional legislation identified as a potential source of incoherence with the EMCD includes the Car Vehicle Regulation (mentioned by a testing laboratory), the Medical Device Regulation (EU) 2017/745 (mentioned by a notified body), the National Grid Regulation (mentioned by a manufacturer) and the Lifts Directive (mentioned by a testing laboratory). Such legislation is applicable in place of the EMCD for the types of equipment falling under these Directives. For instance, manufacturers reported challenges determining which types of electronics integrated within cars should follow the Car Vehicles Regulation and which should follow the EMCD but this issue has been clarified through the issuance of a guidance note on the topic.

5.5Findings in relation to the EU Added Value of the EMCD The main areas of added value of the EMC Directive, according to stakeholders as a whole, were: -The internal market benefits of having a stable regulatory framework in place with harmonised legislation and standards EU-wide; -Avoiding the situation which would exist in a counterfactual scenario (where the EMCD did not exist) of different national laws regulating electromagnetic compatibility in each of the 27 EU Member States. The perception that the EMCD adds value was echoed in the public consultation responses: nearly three out of four respondents (74%, 623 respondents) agreed that having rules for electromagnetic compatibility at EU level (as opposed to national level) continued to have a high level of relevance. Source: European Commission public consultation Stakeholders as a whole consider that the EMCD adds value to the internal market – and the economic operators who depend on it - by providing a stable regulatory framework with harmonised legislation and standards EU-wide. The existence of EU legislation is substantially preferable to the most likely alternative situation: a fragmented regulatory landscape where different national laws on electromagnetic compatibility apply in each of the 27 EU Member States. That the EMCD addresses both emissions and immunity is seen as an advantage compared to equivalent regimes in third countries that only regulate electromagnetic emissions. On the whole, stakeholders interviewed were positive about the EMCD’s ability to prevent the emergence of different national laws. In both the interviews and the targeted questionnaire, they were asked about the extent to which the Directive and its preceding versions has been beneficial since 1989. Many of these stakeholders acknowledged that the EMCD has prevented the emergence of national divergent regulations on EMC. Stakeholders across categories and of different sizes acknowledge that the EMCD has prevented the emergence of national divergent regulations on EMC. In particular, industry associations and large manufacturers operating in multiple jurisdictions value the EMCD as providing a solution to a complex problem that cannot be handled at national level without confusion. The EMCD’s common legal framework and harmonised standards has led to some cost savings for economic operators who would otherwise have to comply with multiple, and potentially diverging, national regulatory regimes for EMC. Additional value of the EMCD for stakeholders, compared to what could have been achieved at national level Stakeholders tended to agree that, by providing uniform EMC requirements across the EU, the EMCD has facilitated the internal market and prevented the fragmentation of EMC rules across the Member States. This provides the basis for growth within the European market and has paved the way for European manufacturers to expand into global markets (as the EMCD’s standards have become an accepted reference worldwide). A common set of EMC rules applying across the EU was considered preferable to the most likely alternative of mutual recognition by the Member States of each other’s EMC standards. Some economic operators and industry associations claimed that the benefits of the EMCD’s regulatory regime also provided added value for consumers, as manufacturers passed on cost savings in the form of lower prices for electronic goods.

6CONCLUSIONS Concerning the Directive’s effectiveness for the internal market, most stakeholders (e.g. industry associations, economic operators and market surveillance authorities) agree that overall the Directive has successfully contributed towards its objectives of firstly ensuring the effective functioning of the internal market for electrical equipment, (encompassing electrical and electronic appliances, systems and installations) and secondly, avoiding any electromagnetic disturbances between equipment. The Directive’s essential requirements are seen as fit-for-purpose, according to industry stakeholders (e.g. industry associations and economic operators). The alignment with the NLF’s horizontal provisions is considered to have been positive by all stakeholders, by improving the clarity and ease of application, through the use of common terminology and definitions to describe the responsibilities of economic operators in the value chain. EMCD was perceived by stakeholder as adopting a technology-neutral approach, with essential requirements laid down in the legislation and harmonised standards providing voluntarily the means of addressing the essential requirements for new technologies. The option to choose between self-assessment and notified bodies for conformity assessment, first introduced in 2004 and strengthened by the alignment with the New Legislative Framework in 2014, was seen as positively contributing to Directive’s effectiveness. Additionally, the inclusion of references to good engineering practices, in particular for fixed installations, in the EMCD in 2004 has also had a positive impact. Market surveillance is seen as not effective in implementing and enforcing the EMCD. E-commerce adds additional challenges to EMCD enforcement as it leaves room for uncompliant products not being intercepted, therefore affecting the level playing field on the internal market. However, enforcement activities are outside the scope of the Directive, being dealt with by specific legislation on market surveillance. With the implementation of the Regulation (EU) 2019/1020 on market surveillance, the issues related to enforcement, identified by the evaluation, including with e-commerce will be addressed. Regarding the Directive’s effectiveness for requiring equipment to comply with an adequate level of electromagnetic compatibility, the EMCD has prevented apparatus causing electromagnetic disturbances from being placed on the EU market and has provided an impetus to encouraging industry to prevent electromagnetic disturbance and interference. Electromagnetic compatibility is now designed into the devices. However, a minority of stakeholders indicate that some problematic products continue to generate disturbances. The evaluation’s findings indicate that even though there may be some products where disturbance remains a problem, this does not suggest that the Directive is ineffective, as it is more a question of strengthening the effectiveness of harmonised standards and of standards development processes to ensure that problematic products with high levels of disturbance are addressed. Many stakeholders, across all stakeholder groups, expressed the view that harmonised standards are the best instrument to keep pace with technological ‘state of the art’ and therefore the quality and availability of standards system may indirectly affect the effectiveness of the Directive Concerning the efficiency of the Directive, the benefits generated by the EMCD outweigh its costs for each type of stakeholders and the affordability of costs has not been put in question by the different stakeholders. Cost to ensure electromagnetic compatibility were seen as an integral part of the product development costs. The cost of complying with the EMCD were estimated to correspond to 5-15% of the total costs of production, including administrative compliance cost as well as compliance costs of designing low-EMC emission products, i.e. building in shielding and immunity measures to address sources of electrical noise. In particular, costs to keep the technical documentation updated for 10 years were considered to be relatively high. Some costs such as familiarising themselves with the legal obligations are relatively higher for SMEs. The self-certification approach significantly contributes to keeping conformity assessment costs relatively low and grants a certain level of flexibility to economic operators. In terms of benefits, both technical and strategic economic benefits of the EMCD have been identified. The main technical benefits include the reduced incidence of electromagnetic disturbance (leading to incorrect functioning of electrical equipment) and the strengthening of electromagnetic immunity. In terms of strategic benefits, the avoided fragmentation into national regulatory systems prevents higher costs for industry in accessing markets and reduces costs related to exporting goods and familiarising with legislation, and fosters the free movement of products in the internal market. Strategic economic benefits for businesses are generated in terms of international industrial competitiveness, as well: the EMCD’s high reputation at international level puts compliant businesses in a favourable position to compete on the global scene. The objectives of the EMCD are still relevant today. This is true for both objectives ensuring the effective functioning of the internal market for electrical equipment (encompassing electrical and electronic appliances, systems and installations) and secondly, requiring equipment to comply with an adequate level of electromagnetic compatibility. The market for electronic equipment has changed and is changing rapidly. This development affects the relevance of the EMCD in two ways. First, it draws attention to the scope of the Directive, i.e. whether the provisions of which products are included have sufficient clarity. For example, some “benign” products, such as cables, currently only become relevant for the Directive after they have been integrated into other products. Second, e-commerce has increased significantly. In this respect, products from overseas have more relatively compliance issues than products produced in the EU. This poses a horizontal challenge (beyond the EMCD) for market surveillance authorities to verify the compliance of the products ordered online from abroad, especially those arriving in small packages rather than as large lots in containers. The internal and external coherence of the EMCD is generally positive. The clarity of the legal text and ease of use was seen positively by the majority of respondents in both the interviews and targeted consultation. However, two issues have been indicated by the respondents to the consultation activities, such as the lack of clarity regarding the definitions of a ‘fixed installation’ and the exclusion of ‘benign equipment’. Regarding the external coherence of the Directive, the alignment to the New Legislative Framework ensures to a certain extent Directive’s coherence with the rest of the internal market legislation for products. The EMCD was perceived as being complementary to Union product safety legislation, such as the Machinery Directive and the Low Voltage Directive, given the potential impact of ensuring adequate levels of electromagnetic compatibility on enhancing functional safety. The main issue identified in the targeted consultation and interviews in respect of the external coherence was the interplay between the EMCD and the RED, and between the EMCD and other legislation. Stakeholders may find it difficult to determine whether particular products fall within the scope of the EMCD, or other specific sectoral legislation, such as the Car Vehicle Regulation. However, this issue has already been clarified by the Commission in a guidance note, so it is more a matter of raising awareness about which types of products fall under which sectoral legislation, and not an incoherence in the EMCD itself. There was a broad consensus among stakeholders, especially from an industry perspective, that the EMCD has added significant value at EU level since the adoption of the first Directive in 1989. It brought regulatory stability and prevented divergent legislation at national level which could potentially emerge to regulate electromagnetic compatibility and immunity. The overall conclusion is that the Directive is relevant, effective, efficient, coherent, and has EU added value. Some stakeholders would find a more precise definition of “fixed installations” helpful, and some proposed integrating “benign equipment” into the Directive. However, those opinions were not shared widely among the different stakeholders. A clarification in the guidelines, after discussion in the expert group, would be sufficient to address these issues. The EMCD’s benefits are obvious to stakeholders. There wasn’t any discussion whether the EMCD is necessary, regardless the costs. Without it, much electronic equipment would function badly or not at all. The main potential for cost savings would be regarding administrative compliance costs. Other two issues were identified but fall outside the remit of the Directive. In particular, the quality and availability of harmonised standards that may need further improvement. Some stakeholders believe that the requirements for products set in the harmonised standards for electromagnetic emissions are too low and that setting more demanding requirements would be more likely to drive innovation, or, at least, less likely to stifle it. Also, the growth of e-commerce leaves room for uncompliant products to be sold in the internal market by extra-EU traders. In this respect, some steps are taken for increased clarity of e-commerce rules but challenges remain in particular related to market surveillance. The new market surveillance Regulation (EU) 2019/1020 should address these concerns.





7ANNEXES ANNEX 1 PROCEDURAL INFORMATION 1. Lead DG, Decide Planning/CWP references Lead DG: Directorate-General for Growth - Internal Market, Industry, Entrepreneurship and SMEs (DG GROW); Unit H2: Machinery & Equipment. Agenda planning/work programme reference: PLAN/2019/5623 2. Organisation and timing Organisation and timing: the inter-service Steering Group consisted of SG, DG JUST, DG EMPL, DG ENER, and DG CNECT. After the kick-off meeting on 31 January 2020, it met two times in 2020 (12th February and 30th of November), two times in 2021 (19th April and 8 of October). 3. Exceptions to the better regulation guidelines Not applicable. 4. Consultation of the RSB (if applicable) Not applicable. 5. Evidence, sources and quality The “Study on the Evaluation of the Electromagnetic Compatibility Directive 2014/30/EU - Final Report” was outsourced to a consultant (CSES) and was one of the main sources of information for this Evaluation of EMCD. The study aimed to obtain a better understanding of the market, to monitor the implementation of the EMCD in EU Member States, and to assess the effectiveness, efficiency, coherence, relevance, and EU added-value. Each phase contains several tasks which take into account the data collection tools, timetables and deliverables. These tasks are aligned with the objectives of the study and with the requirements of the Better Regulations Guidelines for evaluations.



ANNEX 2 SYNOPSIS REPORT OF STAKEHOLDER CONSULTATIONS

The present synopsis resumes the main inputs received from all consulted stakeholders during the evaluation through a roadmap, an interview programme, webinars, targeted and public online stakeholder consultations. The Stakeholder consultations’ objective was to gather information on understanding, implementation and enforcement of the EMCD from economic operators, standardisation bodies, national authorities and consumers. The interviews and the Targeted and Public Consultation were aimed at gathering factual information, data, knowledge and perception by final users of the Directive across the EU about relevance of the scope and the objectives of the EMCD compared to the requirements and needs of the market; and also about effectiveness of the Directive in ensuring fulfilment of essential requirements. 1.Introduction and overview of stakeholder consultation activities • 458 responses to the targeted stakeholder consultation, conducted through an online survey (from July to October 2020). 37% of these responses (170/458) came from economic operators, 71.7% (132/184) of which were large enterprises, 13.6% (25/184) from medium enterprises and 14.7% (27/184) from small or micro enterprises. The remainder of responses were from industry associations (15% means 70/458), laboratories (14% means 65/458), national authorities (7% means 33/458), MSAs (5% means 25/458), notified bodies (3% means 16/458), consumer associations (1% means 5/458) and other stakeholders (13% means 61/458). Although there was a balance of responses across the EU Member States, German respondents comprised a high proportion of respondents (21% means 97/458), 12 percent above the next most responsive country (France – 9% means 41/458). • 854 responses to the public consultation (open from October 2020 to January 2021). A very high percentage of the total responses were from users of electrical equipment/apparatus/fixed installations, radio amateurs and their representative associations (a combined 89.4%), with a more limited number of responses from industry associations (1.4%), economic operators (3%) and other types of organisations. German respondents were the most active in the public consultation, comprising 59.4% of responses, followed by the Netherlands, EU-level stakeholders (both 13%) and Finland (6.3%). Together, respondents from these four countries made up more than 92% of all responses. Analysis of both public consultations responses is developed with detailed answers to the questions and figures in the Annex 9 of the “Study on the evaluation of the electromagnetic compatibility directive 2014/30/EU (EMCD)”. • 109 in-depth interviews with stakeholders representing economic operators, EU and national level industry associations, market surveillance authorities (MSAs) and national competent authorities, notified bodies and testing laboratories, technical standards bodies, academics/RTOs/consultants, radio amateur associations and radio amateurs, and select third countries. Although an effort was made to interview EU and national consumer associations, those approached declined to participate as they do not follow the EMCD. • Four evaluation webinars were held in October 2020. A total of 52 stakeholders from the EMCD Working Party and the EMCD Administrative Cooperation Group (ADCO) participated across the four webinars. These webinars replaced the planned evaluation workshop, which could not take place due to COVID-19. • In addition, 25 responses to the Evaluation Roadmap Consultation conducted by the European Commission were analysed and the findings were triangulated with the above stakeholder consultation activities. The replies to the roadmap can be distinguished in two groups: The first group, businesses operating in the field of apparatus, electrical equipment and/ or installations and their representative associations (17 responses), thought that the EMCD was mostly fit for purpose with no need for modification or revision. It should be kept technology-neutral and should not be merged with other NLF Directives (e.g. RED). The second group, citizens and organisations representing radio amateurs (6 responses), do not consider the EMCD fit for purpose. Three citizen respondents with an interest in amateur radio also point to a lack of enforcement, citing their own experiences as examples, pointing to the fact that, since the introduction of power line communications, energy-efficient switched mode power supplies and solar photovoltaic systems, (amateur) radio services have experienced an increase in radio spectrum pollution. 2. Stakeholder Perceptions by Evaluation Criterion 2.1 Effectiveness Targeted consultation The respondents to the targeted consultation were generally positive regarding the EMCD’s perceived effectiveness in making progress towards its general objectives. Regarding the EMCD’s role in providing a stable legal framework for the electrical equipment industry in the EU, overall, among 299 respondents, 39.5% (118) of respondents found that the EMCD has been ‘highly effective’ and 28.8% (86) of stakeholders ‘somewhat effective’ (as supported by the interviews). The majority of respondents (78.3%/ 234) perceived the EMCD as having been either very effective (53.2%/ 159) or somewhat effective (25.1%/ 75) in ensuring the free movement of electric and electronic apparatus in the internal market. Regarding the related objective of ensuring an adequate level of electromagnetic compatibility, there was also strong agreement among stakeholders that the EMCD has made an important contribution. For instance, a significant percentage of respondents agreed that the EMCD has helped to reduce the incidence of EM disturbance leading to the incorrect functioning of equipment (44.5% / 133) responded