COMMISSION STAFF WORKING DOCUMENT EVALUATION of Electromagnetic Compatibility Directive 2014/30/EC
Date: 2023-01-16
Institutions: Directorate-General for Internal Market, Industry, Entrepreneurship and SMEs, European Commission
Subjects: EC conformity marking, electrical equipment, electro-magnetic equipment, electromagnetic interference, free movement of goods, harmonisation of standards, market approval, market supervision, single market

EN 

  EN 

   EUROPEAN COMMISSION  Brussels, 12.1.2023 SWD(2022) 7 draft  COMMISSION STAFF WORKING DOCUMENT  EVALUATION   of Electromagnetic Compatibility Directive 2014/30/EC {SWD(2022) 8 final}  
 
 
Table of contents 

1 

INTRODUCTION .................................................................................................................. 5 

1.1  PURPOSE OF THE EVALUATION...................................................................................... 5 

1.2  SCOPE OF THE EVALUATION ........................................................................................... 5 

2 

3 

BACKGROUND OF THE INTERVENTION ....................................................................... 6 

IMPLEMENTATION / STATE OF PLAY ............................................................................ 8 

3.1  RELEVANT BODIES ............................................................................................................ 8 

3.2  GUIDELINES ......................................................................................................................... 9 

3.3  EUROPEAN STANDARDISATION ..................................................................................... 9 

4  METHODOLOGY .................................................................................................................. 9 

4.1  DATA COLLECTION AND CONSULTATION STRATEGY ............................................. 9 

4.2  DATA ANALYSIS METHODOLOGY ............................................................................... 11 

4.3  STATISTICAL DATA ON PRODUCTS IN THE SCOPE OF THE EMCD ...................... 11 

4.4  COST-BENEFIT ANALYSIS .............................................................................................. 11 

5 

ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS ............................ 12 

5.1  FINDINGS IN RELATION TO THE EFFECTIVENESS OF THE DIRECTIVE ............... 12 

5.2  FINDINGS IN RELATION TO THE EFFICIENCY OF THE DIRECTIVE ...................... 20 

5.3  FINDINGS IN RELATION TO RELEVANCE OF THE EMCD ........................................ 28 

5.4  FINDINGS IN RELATION TO THE COHERENCE OF THE EMCD ............................... 30 

5.5  FINDINGS IN RELATION TO THE EU ADDED VALUE OF THE EMCD .................... 34 

6 

7 

CONCLUSIONS ................................................................................................................... 35 

ANNEXES ............................................................................................................................ 39 

ANNEX 1 - PROCEDURAL INFORMATION ........................................................... 39 

ANNEX 2 - SYNOPSIS REPORT OF STAKEHOLDER CONSULTATIONS ......... 40 

ANNEX 3 - METHODS AND ANALYTICAL MODELS .......................................... 48 

ANNEX 4 - ANALYSIS OF THE EMCD MARKET .................................................. 57 

ANNEX 5 - CASE STUDIES ....................................................................................... 68 

ANNEX 6 - DESK RESEARCHS ................................................................................ 74 

ANNEX 7 - EVALUATION QUESTIONS.................................................................. 79 

1 

 
 
 
 
Glossary 

Term or acronym 

Meaning or definition 

AC 

AdCo 

ANSI 

Benign equipment 

CABs 

CBA 

CISPR 

CEN 

CENELEC 

Alternating current 

Administrative Cooperation (Group) 

American National Standards Institute - has a role in developing EMC 
standards. 

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)). 

Conformity Assessment Bodies  

Cost-benefit assessment 

Comité  International  Spécial  des  Perturbations  Radioélectriques 
(International Special Committee on Radio Interference) 

European Committee for Standardization 

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 

EEA 

EFTA 

Declaration of Conformity 

European Economic Area 

European Free Trade Association 

EMC ADCO 

Electromagnetic Compatibility Administrative Cooperation Group 

EMC WP 

Electromagnetic Compatibility Working Party 

EMC 

EMCD 

Electromagnetic Compatibility 

Electromagnetic Compatibility Directive (2014/30/EU) 

2 

 
EMI 

EO(s) 

ESOs 

ETSI 

EU 

EUANB 

FCC 

FTE 

GHz 

DG GROW 

Harmonics 

HS 

IARU  

IEC 

IoT 

ISO 

LED 

LVs 

LVD 

MD 

MHz 

MRA 

Electromagnetic interference 

Economic operator(s) 

European Standardisation Organizations 

European Telecommunications Standards Institute 

European Union 

Group of Notified Bodies notified under the EMCD to the European 
Commission 

Federal Communications Commission  

Full-Time Equivalent 

Gigahertz  -  unit  of  measurement  for  electromagnetic  wave 
frequencies equal to 1,000,000,000 (one billion) Hz (hertz). 

Directorate-General 
Entrepreneurship and SMEs 

for  Growth 

- 

Internal  Market, 

Industry, 

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.   

Harmonised Standards  

International Amateur Radio Union 

International  Electrotechnical  Commission  is  the  international 
standards  and  conformity  assessment  body  for  all  fields  of 
electrotechnology. 

Internet of Things  

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. 

Light-Emitting Diode 

Limit Values 

Low Voltage Directive (2014/35/EU) 

Machinery Directive (2006/42/EC) 

Megahertz unit of measurement for EM wave frequency 

Mutual  Recognition  Agreement  (several  exist  between  the  EU  and 
other third country jurisdictions in the area of EMC, e.g. with the US). 

3 

 
MS 

MSAs 

NBs 

NIST 

NLF 

OJEU 

PLC 

RED 

RMCD 

RF 

R&TTE 

SDoC 

EU Member State 

Market Surveillance Authorities 

Notified Bodies 

National Institute of Standards and Technology, United States 

New Legislative Framework 

Official Journal of the European Union (where harmonised standards 
adopted under the EMCD are published in the legal section of the OJ) 

Power Line Communications 

Radio Equipment Directive (2014/53/EU) 

Ready-Made Connecting Devices 

Radio functionality  

Radio  equipment  and  telecommunications  terminal  equipment 
Directive (1999/5/EC). Directive was the predecessor to the RED 

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 

4 

 
1 

INTRODUCTION 

The Electromagnetic Compatibility Directive 2014/30/EU1 (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/EEC2 was adopted in 1989. It was repealed and 
replaced by Directive 2004/108/EC3. 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)4,  commissioned  by  DG 
GROW and conducted from January 2020 to May 2021.  

1.1  PURPOSE 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. 

1.2  SCOPE 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.    

1 Directive 2014/30/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation of the laws of the 

Member States relating to electromagnetic compatibility (OJ L 96, 29.3.2014, p. 79). 

2 Council Directive 89/336/EEC of 3 May 1989 on the approximation of the laws of the Member States relating to 
electromagnetic compatibility (OJ L 139, 23.5.1989, p. 19–26). 

3 Directive 2004/108/EC of the European Parliament and of the Council of 15 December 2004 on the approximation of the laws of 

the Member States relating to electromagnetic compatibility (OJEU L 390, 31.12.2004, p. 24–37). 

4  “Study  on  the  Evaluation  of  the  Electromagnetic  Compatibility  Directive  2014/30/EU”  by  CSES,  Center  for  Strategy  and 
Evaluation Services. 

5 

 
 
 
 
 
 
 
 
                                                      
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  products5,  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-276, the UK (it was a Member State for much of 
the time period within scope and is 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.  

2  BACKGROUND 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  appliances7  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, 

5  Apparatus:  1.  Induction  hobs  2.  Microwave  ovens  3.  Washing  machines  4.  Vacuum  cleaners  5.  Power  tools  6.  Powerline 
Communications  (PLC)  7.  LED  lights  8.  Switching  power  supply  9.  Solar  panels  (inverters  and  optimisers  and  Fixed 
Installation : 10. TV screens and signage 11. Computer networks (only those covered by EMCD i.e. unless falling under the 
RED) 12. Wind turbines 13. Air conditioning systems 14. Cable TV Networks. 

6 Since the UK has left the European Union (EU), the UK is considered as a third country in the analysis. However, as the UK was 
a Member State for much of the time period within scope, the survey results for the UK are presented separately from those for 
other third countries.  

7 The EMCD applies only to equipment having no communication wireless (by radio) function. 

6 

 
 
 
 
  
                                                      
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)8  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 legislation9. For example, this is the 
case  of  medical  equipment10,  motor  vehicle  equipment11,  marine  equipment12,  agricultural  and  forestry 
tractors13 and two or three-wheel motor vehicles14. 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 EMCD15.  

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. 

8 Radio Equipment Directive 2014/53/EU  
9 According to Article 2(3) of the EMCD 

10 Regulation (EU) 2017/745 of the European Parliament and of the Council of 5 April 2017 on medical devices 

11 REGULATION (EC) No 661/2009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 13 July 2009 
concerning type-approval requirements for the general safety of motor vehicles, their trailers and systems, components and 
separate technical units intended therefor 

12  DIRECTIVE  2014/90/EU  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL  of  23  July  2014  on  marine 

equipment and repealing Council Directive 96/98/EC 

13 Regulation (EU) No 167/2013 of the European Parliament and of the Council of 5 February 2013 on the approval and market 

surveillance of agricultural and forestry vehicles 

14 Regulation (EU) No 168/2013 of the European Parliament and of the Council of 15 January 2013 on the approval and market 

surveillance of two- or three-wheel vehicles and quadricycles 

15 Functional safety:  the Machinery Directive 2006/42/EC, the Low Voltage Directive 2014/35/EU and the General Product Safety 
Directive  2001/95/EC;  Environment:  RoHS  (Restrictions  of  Hazardous  Substances)  Directive  2011/65/EU,  WEEE  (Waste 
Electrical  and  Electronic  Equipment)  Directive  2012/19/EU,  Ecodesign  Directive  2009/125/EC  and  Energy  Labelling 
Regulation (EU) 2017/1369. Any future EU legislation strengthening environmental requirements within products could also 
be applicable in parallel with the EMCD (ex: Sustainable Product Policy Initiative - SPI). 

7 

 
 
 
 
                                                      
Figure 2-1 – The figure below provides an overview of the intervention logic of the EMCD.  

3 

IMPLEMENTATION / 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 procedures16 
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. 

3.1  RELEVANT 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 1025/201217 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, 

16 

online 

See 
proceedings/infringement_decisions/?lang_code=en  

infringement 

database 

of 

decisions: 

http://ec.europa.eu/atwork/applying-eu-law/infringements-

17 Regulation (EU) No 1025/2012 of the European Parliament and of the Council of 25 October 2012 on European standardisation, 
amending Council Directives 89/686/EEC and 93/15/EEC and Directives 94/9/EC, 94/25/EC, 95/16/EC, 97/23/EC, 98/34/EC, 
2004/22/EC, 2007/23/EC, 2009/23/EC and 2009/105/EC of the European Parliament and of the Council and repealing Council 
Decision  87/95/EEC  and  Decision  No  1673/2006/EC  of  the  European  Parliament  and  of  the  Council,  available  at: 
http://data.europa.eu/eli/reg/2012/1025/oj 

8 

 
 
 
 
 
 
                                                      
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.   

3.2  GUIDELINES 

Additionally to the above groups, the Guide on the application of the EMCD18 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. 

3.3  EUROPEAN 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 2022.19 

4  METHODOLOGY 

4.1  DATA 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 

18  Guide for the EMCD (Directive 2014/30/EU)- 19 December 2018 
19 https://ec.europa.eu/info/law/better-regulation/have-your-say/initiatives/13099-Standardisation-strategy_en 

9 

 
 
 
 
 
                                                      
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:  

o  Targeted 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.   

o  Public 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).  

10 

 
 
 
 
 
4.2  DATA 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).  

4.3  STATISTICAL 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.  

4.4  ESTIMATION 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 

11 

 
 
 
 
 
  
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) 

5  ANALYSIS AND ANSWERS TO THE EVALUATION QUESTIONS 

5.1  FINDINGS 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. 

Figure 5-1 – Overall, to what extent has the EMC Directive been effective in achieving its general objectives? (N = 299) 

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. 

12 

 
 
 
 
 
 
 
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’. 

Figure  5-2  –  Fostering  the  free  movement  of  electrical  and  electronic  apparatus  in  an  internal  market  context  –  answers  by 
stakeholder group (N=299) 

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 

13 

 
 
 
 
 
 
 
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 

14 

 
 
 
 
 
 
 
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. 

15 

 
 
 
 
Among the 14 products on which the evaluation focused, 5 products were chosen for more in-depth case 
studies. These 5 products20 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. 

Figure  5-4  –  Effectiveness  of  the  EMCD  in  reducing  the  incidence  of  electromagnetic  disturbances  leading  to  the  incorrect 
functioning of electrical equipment – answers by stakeholder group (N=299) 

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).  

20 Cases studies on: Powerline Communications (PLC), ready-made connecting devices (RMCD), Solar photovoltaic inverters and 

optimisers, LED lights; and Wireless EV chargers. 

16 

 
 
 
 
 
 
                                                      
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) 

17 

 
 
 
 
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 rules21 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, 

21 A Commission Notice on the market surveillance of products sold online (2017/C 250/01) was published: 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52017XC0801%2801%29 

18 

 
 
 
 
                                                      
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.  

Figure 5-5 – How effective is the role played by the Directive in terms of preventing barriers to innovation in the development of 
electrical equipment? (N=299) 

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.  

19 

 
 
 
 
 
 
 
5.2  FINDINGS 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. 

Figure 5-6–––Overall, to what extent do you think the benefits outweigh the costs (or vice versa) deriving from the EMCD? (N = 
212) 

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). 

20 

 
 
 
 
 
 
Figure 5‑7– Public consultation – Shares of replies to question on benefit-cost ratio (N = 41) 

To what extent do the benefits of the EMC Directive outweigh 
the costs (or vice versa) in your view? (n-41)

19 respondents

12

3

3

1

3

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

The benefits greatly outweigh the costs

The benefits somewhat outweigh the costs

The benefits and costs are about even

The costs somewhat outweigh the benefits

The costs greatly outweigh the benefits

Don't know

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) 

21 

 
 
 
 
 
 
 
 
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) 

23

12

25

20

15

10

5

0

<5%

5-15%

Source: Targeted consultation for the European Commission  

22 

3

>15%

 
 
 
 
 
 
 
 
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. 

 Figure 5-10 – Targeted consultation – Shares of replies to question on cost types (N = 83) 

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 costs22 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. 

22 Business as Usual: the costs that would be required anyway due to the normal business practices 

23 

 
 
 
 
 
 
                                                      
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 costly23. 

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 manufacturers24. 

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 product25. 

23 In 12% of cases, respondents chose the replies “not applicable” (5 replies) or “don’t know” (5). 

24 See full data on targeted consultation replies split by stakeholder type in Annex 5 of the Study on the evaluation of the EMCD - 

Impact fiches 

25 Product types covered by the replies: defence electronics; control devices; multifunction remote product, handheld with radio and 

cable communication; Personal Computers, servers, notebooks; telecommunication equipment (radio and non). 

24 

 
 
 
 
                                                      
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). 

25 

 
 
 
 
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). 

Figure -5-11 – Targeted consultation – Shares of replies to question on benefit types (N = 216) 

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 survey26. 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 

26 See detailed results of the survey in the impact fiches dedicated to technical benefits in the Annex. 

26 

 
 
 
 
 
 
 
                                                      
its modular approach27 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.  

27 The modular approach was introduced by the NLF alignment to provide a flexibility to the manufacturers to demonstrate their 
equipment is fulfilling the essential requirements. The manufacturer can chose among different modules, i.e. possibilities for 
conformity assessment, listed  in the annex of the Directive. 

27 

 
 
 
 
 
                                                      
5.3  FINDINGS 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. 

Figure 5-12 – To what extent do the following needs in relation to regulating electromagnetic compatibility remain relevant today? 
(N=237) 

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.  

28 

 
 
 
 
 
Figure -5-13 – During the last 10 years, the electrical equipment market has changed dramatically. To what extent have each of 
the following changes affected the relevance of the EMCD? (In terms of Distribution) (N=237) 

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. 

29 

 
 
 
 
 
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 concept28. 

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.  

5.4  FINDINGS 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 

28 Product lifetime concept: introduce a date which limit time of life for a product (sort of expiration date). 

30 

 
 
 
 
 
                                                      
 
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. 

Figure 5-14 – In your view, to what extent is the legal text of the EMC Directive (2014/30/EU) internally coherent (e.g. consistency 
of the different provisions in the legislation)? (N=232) 

60%

50%

40%

30%

20%

10%

0%

56% - 131repondents

19% - 43 respondents

24%- 55 respondents

Yes, the legal text is fully
coherent

The legal text is partially
coherent

The legal text is not that
coherent

Don't know

1% - 3 respondents

 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’29, 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. 

29 Art. 3(3) ‘fixed installation’ means 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. 

31 

 
 
 
 
 
 
 
 
                                                      
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 device30.    

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  2017/7451,  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 6-16- below. Please 
see the section below dedicated to RED for further details.  

Figure 5-16 – Have you experienced any problems due to overlaps, inconsistencies or a general lack of coherence between the 
EMCD requirements and other applicable legislation? (N=229 respondents) 

 Machinery Directive (2006/42/EC)

7%

58%

35%

Low Voltage Directive (2014/35/EU)

11%

69%

Radio Equipment Directive (2014/53/EU)

45%

34%

20%

20%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90% 100%

Yes

No

Don't know

30 Alternatives to regulating cables could be considered, such as encouraging industry-driven standards organisations (e.g. CEN-
CENELEC) to develop more voluntary industry standards for ready-made connecting devices and/ or to develop a marking 
scheme. Whilst marking would be voluntary, this could help over time to improve the quality of cables and raise awareness about 
the need to test emissions and immunity when cables are connected to equipment. 

32 

 
 
 
 
 
 
                                                      
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 risks31. 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%). 

31  EMCD  is  about  the  functionality  of  equipment,  it  does  not  include  any  assessment  of  safety  risks  even  though  some 

electromagnetic phenomena can lead to equipment malfunctions that can have a dangerous consequence for people. 

33 

 
 
 
 
 
 
                                                      
Additional  legislation  identified  as  a  potential  source  of  incoherence  with  the  EMCD  includes  the  Car 
Vehicle Regulation32 (mentioned by a testing laboratory), the Medical Device Regulation (EU) 2017/74533 
(mentioned by a notified body), the National Grid Regulation (mentioned by a manufacturer) and the Lifts 
Directive34 (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 topic35. 

5.5  FINDINGS 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. 

Figure 5-17 – Relevance of having EMC rules at EU level (N=845 respondents) 

74%

13%

10%

2% 2%

0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

High level of relevance

Some relevance

Limited relevance

No relevance at all

Don’t know

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. 

32 REGULATION (EC) No 661/2009 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 13 July 2009 concerning 
type-approval  requirements  for  the  general  safety  of  motor  vehicles,  their  trailers  and  systems,  components  and  separate 
technical units intended therefor - https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32009R0661&rid=5 

33 Regulation (EU) 2017/745 of the European Parliament and of the Council of 5 April 2017 on medical devices 

34 Directive 2014/33/EU of the European Parliament and of the Council of 26 February 2014 on the harmonisation of the laws of 

the Member States relating to lifts and safety components for lifts 

35 APPLICATION OF EMC DIRECTIVE AND/OR VEHICLE REGULATION TO AFTER-MARKET EQUIPMENT, January 

2016 : https://ec.europa.eu/docsroom/documents/ 16513/attachments/1/translations 

34 

 
 
 
 
 
 
                                                      
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. 

6  CONCLUSIONS 

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, 

35 

 
 
 
 
 
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 

36 

 
 
 
 
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 note36, 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 

36 Guidance note on the Application of EMC directive and/or EMC vehicle directive to after-market equipment (15 January 2016) : 

https://ec.europa.eu/docsroom/documents/16513/attachments/1/translations 

37 

 
 
 
 
                                                      
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 rules37 
but challenges remain in particular related to market surveillance. The new market surveillance Regulation 
(EU) 2019/1020 should address these concerns. 

37  A  Commission  Notice  on 
https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52017XC0801%2801%29 

the  market  surveillance  of  products  sold  online  (2017/C  250/01)  was  published: 

38 

 
 
 
 
 
 
 
                                                      
 
7  ANNEXES 

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”38  
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 Guidelines39 for evaluations.  

38 Link to be provide 

39 https://ec.europa.eu/info/better-regulation-guidelines-and-toolbox_en  

39 

 
 
 
 
 
 
 
                                                      
 
SYNOPSIS REPORT OF STAKEHOLDER CONSULTATIONS 

ANNEX 2  

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 

40 

 
 
 
 
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 ‘highly effective’ and 33.8% / 101‘somewhat 
effective’), or a combined total of 78.3% (i.e. 234 out of 299 respondents).  

Public consultation  

In contrast with the targeted consultation, the public consultation results were less positive regarding the 
perceived effectiveness of the EMCD in achieving its general objectives. 40% of respondents to the public 
consultation found the Directive to have been ineffective in reducing electromagnetic disturbance and the 
incorrect functioning of electrical equipment placed on the European single market. This reflects the fact 
that a significant number of radio amateurs responded to the public consultation. It was identified by the 
consultants that many of the responses from radio amateurs were part of a coordinated response organised 
by radio amateur associations.  

41 

 
 
 
 
COORDINATED RESPONSES 

While analysing the consultation responses, it came to the attention of the evaluation team that a large number of 
responses are likely to have been coordinated by radio amateurs and their organisations. 210 responses, almost 
all from German users or amateur radio organisations, used the same or very similar wording in their answers to 
the consultation’s open questions. This wording followed, in many cases to the letter, a model answer found on 
the website of a local chapter of the German amateur radio club, DARC40. A message on the website encouraged 
DARC’s  members  to  submit  responses  to  the  public  consultation41.  A  further  11  responses  from  Finnish 
respondents are almost identical to each other. Together, these coordinated responses make up over a quarter of 
the total. 

Those answers were not discarded, as radio amateurs provided their names and contact details42 and are entitled 
to  their  views.  Instead,  the  disaggregated  responses  to  all  questions  were  analysed  by  stakeholder  group  and, 
where necessary, reported these disaggregated results here. In addition, responses suspected to be coordinated by 
DARC constitute almost 40% of all ‘user’ responses43. To take account of this in the analysis, where appropriate 
the coordinated responses have been compared against those of other ‘users’ to see whether these coordinated 
responses are impacting the general perceptions and inputs of the wider user / radio amateur population. 

The EMCD was seen as effective by most stakeholders, but ineffective by radio amateurs on the basis that 
the perceived level of EM disturbance remains high, and that even if the EMCD requirements are complied 
with by economic operators, some product categories remain problematic in terms of the level and frequency 
of disturbance to other users of equipment, especially for equipment used by radio amateurs. The case study 
analysis supports this finding that whilst the EMCD has been positive in addressing disturbance overall, 
there  are  some  products  where  electro-magnetic  disturbance  remains  a  problem.  Whilst  this  especially 
affects radio amateurs, it could potentially affect other types of electrical equipment. Similar patterns were 
observed in the public consultation regarding the ECMD’s effectiveness in strengthening the immunity of 
new apparatus: users, radio amateur organisations and ‘others’ were far more likely than economic operators 
and industry associations to consider the Directive ‘ineffective’ in achieving that objective.  

In-depth interviews  

Interviewees  commented  that the  EMCD  has  contributed to fostering  an effectively  functioning  internal 
market by ensuring that apparatus placed on the market complies with an adequate level of electromagnetic 
compatibility  (EMC).  The  majority  of  interviewees  from  industry  associations  and  individual  economic 
operators confirmed that, as the essential requirements have not changed fundamentally for 32 years since 
the Directive’s adoption, the EMCD has provided a high degree of regulatory stability.  

40 https://www.x26.de/wp-content/uploads/2021/01/EU-Fragebogen.pdf 

41 “It is very important and indispensable for frequency protection to take part”. They also say that the information in their model 
“can  be  modified  and  changed  according  to  personal  experience”  and  they  asked  members  to  adjust  the  personal  details 
accordingly. 

42 Although we note that many of the DARC email addresses seem to be automated (potentially just for this purpose) as they follow 

a strict format that does not seem to reflect the names of respondents. 

43 Responses suspected to be coordinated by DARC make up 5% of all radio amateur organisation responses, while suspected 
coordinated responses from Finland represent a further 4%. 

42 

 
 
 
 
 
                                                      
 
Stakeholder webinars  

The lack of a clear explanation as to which harmonised standards (HS) are applicable to particular types of 
electrical equipment and other relevant products under the EMCD’s scope was mentioned by some of the 
MSAs during the webinars as a factor limiting the Directive’s effectiveness. They gave examples that some 
manufacturers may inadvertently choose to comply with a different HS from that which they should have 
used,  which  could  attributed  to  lack  of  clarity  in  the  scope  of  harmonised  standards  This  can  make  the 
process of checking EMCD compliance harder for MSAs. Beyond this specific point, which is outside the 
scope of the evaluation but indirectly affects its implementation, the webinars validated the findings of the 
research on the effectiveness of the EMCD. 

Roadmap consultation  

Economic operators and industry associations responding to the roadmap consultation appreciated that the 
EMCD essential requirements were formulated in such a way that allows them to remain valid and fit for 
purpose for new and future technologies. The EMCD’s technological neutrality was considered important 
to the Directive’s continuing effectiveness.  

2.2 Efficiency  

Targeted consultation  

The targeted consultation indicated that benefits generated by the EMCD are considerably higher than its 
costs.  For 52%  of  the  212  respondents  who  answered  on  this topic  (including  63  manufacturers  and  44 
industry associations), the benefits largely outweighed the costs. Benefits largely or slightly outweighed 
costs according to almost all stakeholder types, with the exception of wholesalers/distributors. However, in 
this case, the low number of replies (three in total) may impact the results’ representativeness. Although it 
should be noted that only large and medium firms responded to the section on costs and benefits in the 
targeted consultation, and no small or micro firms, where there was generally a low response level. Costs 
relating to ensuring adequate EMC during product development and conformity assessment related costs 
(especially testing and production of the technical file) are the types of costs most frequently identified as 
being costly. There was no indication from stakeholders that simplification / cost reductions could occur. 
To  be  noted  that  the  conformity  assessment  provided  by  the  Directive  is  not  requiring  the  obligatory 
involvement of a third party assessment body, while testing and production of technical file are compliance 
requirements under any product legislation. Four out of five respondents perceive these costs as at least 
“quite costly” (80% and 79%). They are considered “very costly” by about one third of respondents (31% 
and 33%).  

Public consultation  

There was a positive opinion about the EMCD’s benefits greatly outweighing costs in the public consultation 
too. Out of the 41 replies (including 25 economic operators and 11 industry associations) to a question on 
the cost-benefit ratio, according to 46% (19 replies), the benefits greatly outweigh the costs, and somewhat 
outweigh costs for a further 29% (12 replies).  

In-depth interviews  

Interviews with large enterprises confirmed that some types of EMCD compliance costs are perceived to be 
either  ‘very’  or  ‘quite’  costly  by  economic  operators,  in  particular  the  costs  of  compliance  during  the 
development process, testing costs given the need for specialist EMC laboratory equipment and the costs to 
produce the technical file. Nevertheless, the interviews also indicated that benefits generated by the EMCD 

43 

 
 
 
 
are  considerably  higher  than  its  costs.  According  to  interviews  with  small  enterprises  and  with  EMC 
consultants and experts, cost drivers for small businesses are largely similar to those identified through the 
consultation with large enterprises, but SMEs are more likely to have to use third party testing laboratories, 
as in-house testing equipment and EM chambers are costly.  

2.3 Relevance  

Targeted consultation  

The overwhelming majority of respondents to the targeted consultation44 perceived the following needs to 
be either ‘highly’ or ‘quite’ relevant:  

• The need to harmonise standards on EMC issues: 71% think this need remains highly relevant and 
21%  perceive  this  remains  quite  relevant.  Only  2%  of  respondents  perceive  this  need  to  be 
irrelevant.  

•  The  need  to  reduce  the  incidence  of  EM  disturbance,  to  prevent  the  incorrect  functioning  of 
electrical equipment: 75% think this need remains highly relevant, while 16% perceive this need to 
remain quite relevant and only 3% perceive this need to be irrelevant. 

• The need to avoid divergent national regulations: 71% think this need remains highly relevant and 
19% perceive this need to remain quite relevant. Only 2% of respondents perceive this need to be 
irrelevant.  

The emergence of new types of electrical equipment was seen by the majority of stakeholders as affecting 
the EMCD’s relevance, with a combined 72% of respondents agreeing with this statement ‘to a great extent’ 
(34%), or ‘to some extent’ (38%).  

Public consultation  

The results of the public consultation were strongly aligned with the findings of the targeted consultation. 
80% of respondents considered the EMCD to still have a ‘high level of relevance’ (72%) or to have ‘some 
relevance’ (8%).  

In-depth interviews  

The consensus across all stakeholders interviewed is that the needs influencing the objectives of the EMCD, 
as  well  as  previous  iterations  of  the  legislation,  remain  relevant  today.  Feedback  gathered  through  the 
interviews also suggests that the emergence of new types of electrical equipment has had an impact on the 
EMCD’s ongoing relevance, particularly in terms of product scope.  

Stakeholder webinars  

As well as confirming the impact of new types of equipment on the EMCD’s ongoing relevance, the EMC 
ADCO and EMC WP webinars also raised the ongoing debate as to whether specific types of installations, 
such as solar panels, can be considered to be fixed installations. The need to define fixed installations more 
clearly was raised during the webinars.  

44 237 respondents completed this section of the targeted consultation 

44 

 
 
 
 
 
                                                      
Roadmap consultation  

The large manufacturing businesses and industry representatives that responded to the roadmap consultation 
emphasised that the EMCD has been in force (in several iterations) for three decades. The prevailing view 
was that, during this period, the Directive has demonstrated that it is fit for purpose in terms of both its 
requirements  and  scope.  In  contrast,  among  citizens  and  amateur  radio  associations,  the  EMCD  was 
perceived as failing to keep pace with the increase in the usage of electrical devices, with a concern that 
increased density of apparatus is causing unacceptable levels of disturbance to the operation of amateur 
radio equipment45.  

2.4 Coherence  

Targeted consultation  

Overall, in the targeted consultation, there was a positive consensus regarding the EMCD’s coherence, for 
instance in the clarity of the legal text and ease of application. 75% of respondents considered the EMCD 
to be coherent46: 54% considered it to be fully coherent and 19% 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. 
In terms of the EMCD’s coherence with other relevant legislation, the majority of stakeholders responding 
to the targeted consultation reported that there were no problems related to overlaps and inconsistencies 
between the EMCD and the Machinery Directive (58%), and between the EMCD and Low Voltage Directive 
(69%).  This  is  because,  as  highlighted  by  several  industry  associations  in  their  open  comments  to  the 
targeted consultation, the Machinery and the Low Voltage Directives are safety legislation, whereas the 
EMCD is concerned with ensuring the correct functioning of electrical equipment, as well as the protection 
of other equipment. However, there were some concerns regarding coherence between the EMCD and the 
Radio  Equipment  Directive  (RED),  despite  these  being  mutually  exclusive.  The  main  concern  was  that 
manufacturers have to use different EMC-related harmonised standards depending on whether their product 
is  internet-connected  /  has  radio  functionality  or  not,  given  timing  differences  in  the  citation  of  such 
standards between the two Directives.  

Public consultation  

The findings diverged somewhat from the targeted consultation regarding coherence. A small majority of 
respondents  held  that  they  were  ‘neutral’  as  to  whether  the  Directive  is  clear  and  easy  to  apply  (54%). 
Another 20% found the EMCD to be ‘very’ or ‘quite’ clear and easy to apply, with 17% contending that the 
EMCD is ‘very’ or ‘quite’ unclear and difficult to apply. Only 9% of respondents and 10% of users answered 
‘don’t know.’ The number of respondents answering ‘don’t know’ is perhaps surprisingly low, given that 
many of them, particularly users, would be unlikely to have direct experience applying the EMCD’s rules 
and so may not have the knowledge to respond appropriately to this question.  

Respondents from economic operators, industry associations, laboratories and academics tended to consider 
the  EMCD’s  coherence  with  other  applicable  product  safety  legislation  to  be  high,  though  some 
improvements were identified as being necessary. For instance, one industry association highlighted that the 
definition of ‘end user’ and ‘making available on the market’ are unclear within the EMCD guidelines and 

45 237 respondents completed this section of the targeted consultation 

46 Regarding Q41 of the Targeted Consultation, in your view, to what extent is the legal text of the EMC Directive (2014/30/EU) 

internally coherent? (e.g. consistency of the different provisions in the legislation) 

45 

 
 
 
 
                                                      
blue guide47, which impacts the Directive’s coherence with the Machinery Directive. However, the latter is 
addressed through the common reference provisions of the New Legislative Framework (NLF).  

In-depth interviews  

Overall, there was a strong positive consensus in the interviews regarding the EMCD legal text’s coherence, 
and its ease of application, confirming the results of the targeted consultation. The interviewed stakeholders 
also agreed that there is a strong level of coherence between the EMCD and wider EU legislation, such as 
the Low Voltage Directive and Machinery Directive.  

Stakeholder webinars  

In  the  EMC  ADCO  webinars  on  the  evaluation,  it  was  mentioned  that  there  can  be  challenges  for 
manufacturers  in  the  automotive  sector  in  understanding  which  types  of  electronics  and  equipment 
integrated within cars should follow the Car Vehicle Regulation, and which should follow the EMCD. This 
issue has been clarified through the issuance of a guidance note on the topic48.  

Roadmap consultation  

Industry associations and manufacturers responding to the evaluation roadmap consultation appreciated the 
current modularity of EU product legislation in terms of conformity assessment modules available under 
the EMCD, and feared that any kind of merger of product laws such as a merger between the EMCD and 
the RED, would lead to confusion or even disruption. They opposed the merging of the EMCD with the 
RED. Conversely, some stakeholders in the interviews and targeted consultations favoured such a merger 
over  the  medium  term  on the  grounds  that  in future, almost  everything  will become  internet-connected. 
However, this was contested by other industry associations, as not all products will become connected and 
smart.  

2.5 EU added value  

Targeted consultation  

Feedback from the targeted consultation was overwhelmingly positive in emphasising the Directive’s added 
value. “By providing uniform EMC requirements across the EU single market, the EMCD facilitates the 
single market and prevents fragmentation of EMC rules across the Member States”, commented one industry 
association. A Belgium-based consultancy advising EU clients reported that the Directive had “sparked the 
emergence of EMC requirements in other countries” helping to create a level-playing field in relation to 
electrical  products  around  the  world.  Setting  the  Directive  in  its  broader  context,  an  Austria  based 
manufacturer described the EMCD as a typical success story for the standardised approach of the NLF and 
the European single market: “Since EMC characteristics and impact don't change by crossing any border, it 
makes sense to have a single applicable Directive to ensure the free movement of products and to avoid 
administration  efforts.  Beyond  this,  it's  important,  that  the  harmonised  EMC  standards  are  coherent  in 
content  and  timing  with  the  international  standards”.  An  organisation  representing  notified  bodies 

47  Guide  on  the  implementation  of  EU  product  rules  ‘Blue Guide’  on  the  implementation  of  EU  product  rules  Published  on: 
28/02/2014 The update of the Guide to the implementation of directives based on the New Approach and the Global Approach 
(the "Blue Guide") is now available. 

48 Application of EMC Directive and/or vehicle regulation to after-market equipment, January 2016. 

46 

 
 
 
 
                                                      
commented that EU harmonisation of EMC requirements was undoubtedly a big advantage for all economic 
actors and for users.  

Public consultation  

The perception that the EMCD adds value was echoed in the public consultation responses: nearly three out 
of four respondents (74%) agreed that having rules for EMC at EU level continued to have a high level of 
relevance. A further 13% thought having such rules at EU level had at least ‘some relevance’. These figures 
were even more positive among the economic operators and industry associations that responded: 81% of 
economic operators (21 respondents) and 92% of industry associations (11 respondents) took the view that 
having  EMC  rules  at  EU  level  continues  to  be  highly  relevant.  Conversely,  only  57%  of  radio  amateur 
organisations took this view (142 respondents), while 19% of this group considered that having rules for 
EMC at EU level was of either limited or no relevance at all (47 respondents).  

On  average,  respondents  also  rated  positively  the  EMCD’s  role  in  improving  harmonised  standards  on 
electromagnetic compatibility: 15% thought the Directive had brought ‘strong benefits’ in this respect and 
a further 54% thought it had brought at least ‘some benefits’. Its role in improving harmonised standards 
helps ensure that the Directive continues to maintain its relevance and add value over time, particularly to 
economic operators and, indirectly, to consumers.  

In-depth interviews  

The  interview  feedback  confirmed  the  findings  from  the  targeted  consultation,  with  stakeholders 
overwhelmingly positive in emphasising the Directive’s added value. Regarding added value in the area of 
harmonised standards, it was perceived as being highly beneficial that European Standards Organisations 
(ESOs) have developed such standards in close alignment with international EMC standards.  

47 

 
 
 
 
 
 
ANNEX 3  

METHODS AND ANALYTICAL MODELS 

The evaluation study was conducted from January 2020 to April 2021, with data collection activities running 
until February 2021. Data was gathered through the following means: 

-  Desk  research  by  analysing  previous  existing  studies,  legislative  and  guidance documents,  Joint 
Market  Surveillance  Campaigns  on  specific  products.  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:  Prodcom,  Comext  and the  Structural  Business 
Statistics datasets and some market research data were also analysed. 

- 

Interviews with stakeholders such as National authorities, Businesses & industry representatives, 
Standardisation bodies, Consumers and Third country stakeholders. A total of 112 interviews were 
carried out as part of the consultation activities. 

-  Two  Consultations  (public  consultation  and targeted consultation)  addressed  to all categories  of 
stakeholders (industry, industry associations and economic operators, laboratories, MSA, national 
authorities, Notified bodies and standardisation organisation) and EU citizens. The latter category 
was addressed only in the public consultation. In total, 458 respondents answered to the Targeted 
stakeholder consultation and for the Public Consultation 854 replies across 15 Member States and 
7 other countries.  

-  Workshop, organised in October 2020 in four separate webinars. The purpose was to discuss the 
preliminary findings around understanding, implementation and enforcement of the  EMCD. The 
participants were stakeholders, members of the EMC Working Party (WP) and EMC ADCO 

The figure below provides an overview of the methodological approach to the study in three phases.  

Figure – Methodological approach  

48 

 
 
 
 
 
 
Summary of key evaluation issues framework 

The most important evaluation questions are mentioned in the table below, detailed evaluation questions by 
criterion are in Annex 7.   

Evaluation criteria 
Effectiveness 

Key considerations 
  Overall, how effective has the EMCD been in achieving its objectives of requiring 
apparatus to comply with an adequate level of electromagnetic compatibility, and 
guaranteeing the free movement of such equipment within the single market? 

  How far has the EMCD provided a stable legal framework since the Directive was 

adopted in 1989? 

Efficiency 

  What are the costs and benefits of EMCD compliance for economic operators and 

other relevant stakeholders (e.g. market surveillance authorities)? 

  To what extent are administrative and reporting costs proportionate?  

  Were the effects achieved at a reasonable cost? 

  How far – if at all – do the benefits outweigh the costs? 

Relevance 
(including fitness 
for purpose) 

  To what extent does the EMCD remain relevant today in regulating electromagnetic 

compatibility and addressing identified needs? 

  How far is the legal text clear and coherent?  

  Given  the  evolution  of  the  electrical  equipment  market  since  the  Directive  was 

adopted, how far does it remain fit for purpose? 

Coherence 

  Are there any coherence issues regarding the relationship between the EMCD and 

other wider EU legislation? 

EU added value 

  What is the EU added value of the current EMC Directive? 

 

In the absence of the EMCD, what would be the situation (counterfactual evaluation 
consideration)? 

Selection of 14 products for the Market analysis 

The EMCD address almost all electrical products which thus are not a defined sector in the industry and are 
also not logged as a separate group of products in statistical databases. Taking this into account, 14 products, 
including both apparatus and fixed installations, were selected for in-depth analysis. The methodology for 
selecting these products was based on desk research49, and in collaboration with the EMC ADCO members 
who provided their view regarding which products either caused disturbance or which they would generally 
find interesting to include. In order to collect statistical data for each of the considered apparatus and fixed 
installations, it was necessary to attribute a corresponding NACE, Prodcom and CN code to each of them.  

49 A review was carried out of the Joint Market Surveillance Campaigns undertaken annually by the EMC ADCO, which focuses 
on products identified as being potentially problematic from an EM disturbance perspective. There have been 14 Joint Cross-
Border EMC Market Surveillance Campaigns to date.  

49 

 
 
 
 
 
                                                      
Figure– Products covered by the market analysis

Stakeholder consultations  

The stakeholder consultations consisted of:  

 

Initial consultation carried out as part of the evaluation roadmap (organised by the Commission and 
analysed by CSES);  
Interviews with 112 interviewees; 

 
  Targeted stakeholder consultations (carried out through an online survey managed and analysed by 

the study team); 

  Public Consultation (carried out on the Commission’s EUSurvey platform);  
  Four stakeholder webinars focusing on the key evaluation issues held together with the EMC ADCO 

and EMC Working Party members; and  

  Several other presentations outlining the emerging evaluation findings to different EMC stakeholder 
groups, including presenting emerging findings at EMC ADCO meetings and to the EUANB.  

In  carrying  out  the  stakeholder  consultations,  the  Commission’s  Better  Regulation  guidelines  were 
followed.50 The interviews were as wide as possible, with an effort to ensure an appropriate balance across 
different types of stakeholders and in terms of broad representativeness as regards: 

  Geographic coverage across the EU-27 – e.g. stakeholders located in southern, northern, central and 

eastern European countries;  

  Coverage by stakeholder type – e.g. industry stakeholders (industry associations, economic operators), 
Market  Surveillance  Authorities  (MSAs),  standardisation  organisations,  notified  bodies,  testing  and 
certification  laboratories,  consultants  and  academics  specialising  in  EMC  and  radio  amateur 
organisations and individuals; and 

  Coverage of both apparatus and fixed installations. The product scope covered 14 different apparatus 

and fixed installations. 

Table - Summary of the interviews completed 

Stakeholders by type 

Completed 

Third country contacts 

Academic/RTOs/Consultants 

7 

7 

50  European  Commission’s  Better  Regulation  guidelines,  Chapter  VII,  Guidelines  on  Stakeholder  Consultation. 

https://ec.europa.eu/info/sites/info/files/better-regulation-guidelines-stakeholder-consultation.pdf  

50 

 
 
 
 
 
                                                      
Economic operators (incl. SMEs) 

EU/national consumer associations 

Industry associations 

MSAs and national competent authorities  

Notified bodies and testing labs 

Radio amateur associations and radio amateurs 

Technical standard bodies 

Total 

30 

0 

29 

17 

10 

5 

7 

112 

Whilst  the  number  of  interviews  undertaken  exceeded  the  target  of  90,  it  was  not  possible  however  to 
interview  all  types  of  stakeholders.  Although  an  effort  was  made  to  interview  EU/national  consumer 
associations,  those  approached  declined  to  participate,  as  they  do  not  follow  the  EMCD.  However,  a 
consumer perspective was nonetheless ensured through the interviews with radio amateur associations and 
radio amateurs. It was also difficult to persuade Small and Medium-sized Enterprises (SMEs) to take part 
in interviews, although some SMEs responded to the online survey. Large firms and multinationals were in 
contrast well represented among economic operators.  

Concerning the Target consultation answers, an overview of the responses by country is provided below:  

Figure – Targeted survey responses by country – (N = 458)

Which country are you responding from? (N=458)

25%

20%

15%

10%

5%

0%

5% 5%

a
i
r
t
s
u
A

i

m
u
g
e
B

l

21%

9%

6%

2%

5%

2%

0,2%

1%

0,2%

1% 1%

7%

4%

4,0%

3%

6%

5%

4%

0,4%0,4%1%

U
E

d
n
a
n
i
F

l

e
c
n
a
r
F

y
n
a
m
r
e
G

e
c
e
e
r
G

d
n
a
e
r
I

l

y
l
a
t
I

a
i
v
t
a
L

i

a
n
a
u
h
t
i
L

g
r
u
o
b
m
e
x
u
L

a
t
l
a
M

s
d
n
a
l
r
e
h
t
e
N

r
e
h
t
O

d
n
a
o
P

l

l

a
g
u
t
r
o
P

i

a
n
a
m
o
R

a
i
k
a
v
o
l
S

i

a
n
e
v
o
l
S

i

n
a
p
S

n
e
d
e
w
S

i

m
o
d
g
n
K
d
e
t
i
n
U

2% 2%

0,4% 0,2% 0,2%

a
i
r
a
g
u
B

l

a
i
t
a
o
r
C

s
u
r
p
y
C

k
r
a
m
n
e
D

c
i
l

b
u
p
e
R
h
c
e
z
C

1%

i

a
n
o
t
s
E

Source: Targeted online consultation  

51 

 
 
 
 
 
 
 
 
 
The Figure shows that participation in the targeted consultation was of a strong interest from a small number 
of EU Member States, such as Austria (5%), Belgium (7%), Portugal (5%), the Netherlands (5%), Sweden 
(6%) and France (9%). Reflecting the market for electrical equipment, Germany accounted for the highest 
volume  of  responses  by  a  considerable  margin  (22%).  In  addition,  there  were  also  a  high  proportion  of 
responses from outside the EU-27 (14%), especially from the UK and the US. Stakeholders outside the EU 
include, for example, accredited conformity assessment bodies able to carry out conformity assessment and 
testing  under  the  EMCD.  Some  larger  economic  operators  outside  the  EU  also  completed  the  survey, 
especially multinationals.  

Figure–– Overview of the responses by type of stakeholder (N = 458).

What type of stakeholder are you? (N=458)

37%

15%

14%

13%

Economic operator

Industry association

Laboratory

Other

National authority

Market surveillance authority

Standardisation organisation

Notified body

Consumer association

1%

7%

5%

3%

3%

0%

5%

10%

15%

20%

25%

30%

35%

40%

Source: Targeted online consultation  

A good balance was achieved in the survey responses between the different types of stakeholders involved. 
A high response was received from economic operators, 40.8% of the total. This was comprised of 34.3% 
of  respondents  that  were  manufacturers,  1.5%  distributors,  0.7%  importers  and  0.7%  authorised 
representatives and 3.7% organisations providing consultancy services). In addition, a further 15.3% were 
received from industry associations. 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%)  and  notified  bodies  (3.5%)  and 
standardisation organisations (2.8%). There was a low response from consumer associations, as very few 
consumer associations follow the EMCD closely. 51 

Only 40.8% of the total 458 responses (i.e. 184 responses) were from economic operators which answered 
the question regarding their firm size, as shown in table below: 

51 For instance, neither of the two main EU level consumer associations monitor the EMCD, whereas they do participate in expert 

meetings and stakeholder discussions pertaining to the RED. 

52 

 
 
 
 
 
  
 
 
                                                      
Table – Overview of responses to targeted survey from economic operators (EO) – question on enterprise 
size class (N = 184) 

Type of firm by size 

Number (all EO) 

Percentage (%) of total economic operators 

Large (>250 staff) 

Medium (50-249 staff) 

Small (10-49 staff) 

Micro (<10 staff) 

Total  

132 

25 

12 

15 

184 

71.7 

13.6 

6.5 

8.2 

100.0% 

Source: targeted online consultation. Note – not all economic operators responded to the question on size breakdown 

A weakness in the quality of data for economic operators is that whilst there was a good response overall, 
only  a  limited  number  of  responses  were  received  from  micro,  small  and  medium-sized  enterprises.  A 
further challenge is that 7 of the 12 enterprises responding categorised as small were actually consultancies 
working with manufacturers advising on EMCD compliance. More positively, a high number of responses 
were received from large firms. 

Regarding the public consultation, in total, 854 responses were received. A very high number of the total 
responses  were  from  radio  amateurs  and  their  representative  associations.  Users  of  electrical  equipment 
(especially  radio  amateurs)  comprised  60.4%  of  respondents  to  the  consultation,  and  radio  amateur 
organisations comprised 29.0%. There were a more limited number of responses from industry associations, 
economic operators and other types of organisations.  

The most common country of origin of respondents was Germany, which accounted for 59.4% of responses 
(507  respondents).  This  was  followed  by  the  Netherlands  and  Belgium  (114  and  113  respondents 
respectively) and Finland (54 respondents). Together, respondents from these four countries made up more 
than 92% of all responses. Among the 2% from non-EU countries (18 respondents), the most-represented 
country was the United Kingdom (1%, 8 respondents).  

Figure – Country of origin of respondents to Public consultation (N = 854) 

Country of origin (N=854)

59,4%

70%
60%
50%
40%
30%
20%
10%
0%

13,3%

13,2%

6,3%

1,5%

1,2%

0,9%

0,8%

3%

The  largest  group  of  respondents  by  type  were  ‘users  of  electric  equipment/apparatus/fixed  installation 
(individual  citizen  or  other  types  of  organisations)’  with  60%  of  all  consultation  responses  (516 
respondents). The second largest group was ‘radio amateur organisation or other citizen-based organisation’, 
accounting for 29% of responses (248 respondents). Together, those two groups make up almost 90% of all 
responses.  Economic operators accounted for 3.0% of all responses (26) and industry associations  1.4% 
(12). Laboratories accounted for 0.5% of the responses (4) and notified bodies and academic and research 

53 

 
 
 
 
 
institutions 0.4% (3 each). Other respondents were below 0.2% of the responses. It should be noted however 
that economic operators, industry associations, notified bodies etc. were better represented in the targeted 
consultation.  There  were  no  responses  from  consumer  associations  as  they  don’t  generally  follow  the 
EMCD, but consumers are instead represented through the significant numbers of respondents from user 
associations and users (i.e. radio amateurs and their representative associations).  

Throughout the analysis that follows, the answers for these two groups tend to follow a similar pattern, 
suggesting that their interests are aligned. The ‘user’ group probably accounts for a large number of the total 
response, and these were mainly from radio amateurs.  

Figure–– Overview by stakeholder type for Public consultation responses (N=854) 

Contribution given as a: (N=854)

29,0%

60,4%

User of electric equipment/apparatus/fixed…
Radio Amateur organisation or other citizen-…
Economic operator (manufacturer, distributor, …

Industry association
Laboratory in the field
Notified body for the EMCD
Academic / research institution
Non-governmental organisation (NGO)
National/local authority (different from MSA)
Market surveillance authority (MSA)
Other

3,0%

1,4%
0,5%
0,4%
0,4%
0,2%
0,1%
0,1%

4,4%

Source: CSES  

0%

10%

20%

30%

40%

50%

60%

70%

The most common country of origin of respondents was Germany, which accounted for 59.4% of responses 
(507 respondents). This was followed by the Netherlands and Belgium, each accounting for just over 13% 
of  responses  (114  and  113  respondents  respectively),  and  Finland  (6.3%,  54  respondents).  Together, 
respondents from these four countries made up more than 92% of all responses.  

Respondents from EU Member States accounted for 98% of the total (836 respondents). Among the 2% 
from non-EU countries (18 respondents), the most-represented country was the United Kingdom (1%, 8 
respondents).  

The evaluation roadmap consultation was organised by the Commission between January and February 
2020, and received 25 responses. Respondents were drawn from eight countries with the largest numbers 
based  in  Germany  (nine  responses)  and  Belgium  (six),  the  latter  including  five  EU-level  industry 
associations.  Four  responses  were  received  from  France,  two  from  Denmark,  and  one  each  from  the 
Netherlands, Italy, Switzerland and the United Kingdom.  

Four  separate  webinars  were  organised  as  part  of  the  evaluation  in  October  2020.  These  involved  the 
participation of EMCD Working Party (WP) and EMCD ADCO members. These webinars replaced the 
planned evaluation workshop, which could not take place in Brussels due to COVID-19. Presentations of 
the emerging evaluation results were also made to various stakeholder fora, including to the EMC ADCO 
members and EUANB members.  

54 

 
 
 
 
 
 
 
Data analysis 

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, in particular: 

 

Interview feedback (with 112 interviewees). 

  Survey feedback from the targeted consultation (458 respondents).  

  Survey feedback from the public consultation (854 respondents).  

  Analysing the results to the evaluation roadmap consultations (25 respondents), presented in Annex 

7.  

  Analysing the data on market size and structure for 14 selected products (see Annex 4) 

The  analysis  was  carried  out  using  descriptive  statistics  from  three  sets  of  publicly-available 
Eurostat databases, Prodcom, Comext and the Structural Business Statistics datasets.  

In  the  analysis,  the  statistical  data  consistently  refers  to  the  27  current  EU  Member  States52.  In 
agreement with the European Commission, the United Kingdom is treated as an extra-EU partner 
in the foreign trade analysis.  

Methodology for the assessment of efficiency 

The assessment of efficiency in the main evaluation report was based on an analysis of costs and benefits 
generated by the EMCD. 

Data  and  information  were  gathered  through  the  targeted online consultation  about the  average  costs  of 
compliance  as  a  percentage  of  the  total,  and  through  the  in-depth  interviews  conducted  with  economic 
operators, experts and national authorities. However, in many cases, it was difficult to obtain any costs data 
through interviews. Nonetheless, some useful data was obtained which informed the analysis of costs.   

The  analysis  was  complemented  by  desk  research,  for  instance,  reviewing  the  approach  adopted  to 
undertaking the assessment of costs and benefits in other recent relevant evaluations and impact assessments 
(e.g. Interim evaluation of the Low Voltage Directive, Impact assessment of the Machinery Directive). The 
lists are structured based on the categories set out in the European Commission’s Better Regulation Toolbox, 
which distinguishes between direct costs, enforcement costs and indirect costs53, and between direct and 
indirect benefits54. 

52 Austria, Belgium, Bulgaria, Croatia, Cyprus, Czechia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, 
Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovakia, Slovenia, Spain and Sweden.  

53  Direct  costs  from  regulation  include:  regulatory  charges,  substantive  compliance  costs,  administrative  burdens,  hassle  costs. 
Enforcement costs are associated with activities linked to the implementation of an initiative (e.g. monitoring). Indirect costs 
include negative impacts on market functioning, costs related to substitution, and costs incurred by stakeholders not directly 
targeted by the regulation. Source: European Commission (2017). 

54 Direct benefits include improvements in well-being (e.g. safety or health improvements) and efficiency improvements (e.g. cost 
savings,  information  availability,  enhanced  quality  for  end  consumers).  Indirect  benefits  include  wider  macroeconomic 
benefits, spill-over effects and other non-monetizable benefits. 

55 

 
 
 
 
 
 
                                                      
Table - Costs generated by the EMCD 

Direct costs 

Cost of product development (EMC relevant): 
a)  Cost of purchasing the relevant standard 
b)  Cost of engineering  
c)  Cost of pre-testing  
d)  Cost of risk assessment 

Cost of conformity assessment to produce the technical file: 
a)  Documentation 
b)  Cost of laboratory tests (internally / third party)  
c)  Involvement of a notified body 

Compliance costs during the production process: 
  EMC-relevant measures (e.g. shielding) 
 
Including information to the user 
  Markings (traceability, identification, CE marking) 
  Ensuring that the manufacturing process and its monitoring are 

compliant with the technical documentation 

Cost of familiarisation with the legal framework 

Cost of keeping technical documentation for 10 years 

Cost of authorised representative 

Enforcement 
costs 

Enforcement costs: 
a)  Enforcement costs (for authorities) 
b)  Enforcement costs (for manufacturers) 

Source: EMCD Evaluation Study – CSES with CSIL. 

Table - Benefits generated by the EMCD 

Direct benefits 

Technical benefits 
a)  Reduction  of  the  incidence  of  electromagnetic  disturbance 
leading to incorrect functioning of electrical equipment 
b)  Regulation  of  application  of  good  engineering  practices  for 

fixed installations  

c)  Improvement of harmonised standards relating to EMC 
d)  Increased electromagnetic immunity 

Market efficiency 

56 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
Indirect 
benefits 

Industrial competitiveness (EU vs Third countries) 

Source: EMCD Evaluation Study – CSES with CSIL. 

57 

 
 
 
 
 
 
 
ANNEX 4 

ANALYSIS OF THE EMCD MARKET 

This  Annex  provides  an  indication  about  the  economic  importance  and  the  trade  levels  for  the  selected 
apparatus and fixed installations for this study (14 products). 

Economic importance in the EU of selected apparatus and fixed installations  

According to Eurostat data55, in 2017 there were nearly 67,000 enterprises in the EU27 operating in the 
manufacturing  sectors  producing  the  14  products,  with  about  2.37  million  employees  and  a  cumulative 
turnover of €566 billion. Between 2012 and 2017, the number of companies operating in the manufacturing 
sectors subject to the EMCD and covered by the analysis decreased by 4%. Yet, employment increased by 
3% over the same period. In terms of size, micro enterprises are those which experienced a drop in their 
number. Conversely, the number of large enterprises and their share over the total have increased, which 
reflects a process of industry consolidation. 

Between 2012 and 2017, the level of manufacturing activity in sectors producing the 14 selected products 
has  grown  at  a  slightly  lower  rate  than  the  overall  average  for  the  EU27  manufacturing  industry.  The 
cumulative production of the 14 selected apparatus and fixed installations in 2018, accounted for 5.3% of 
the  value  of  the  total  electrical  equipment  production56.  The  drop  recorded  in  2013  can  be  attributed 
especially to a contraction in the production of computer networks, and, in general, to an increase in imports 
of the considered products from the extra-EU countries. 

When considering consumption, the market size for the selected products57 represents approximately 0.3% 
of EU27 GDP. This share has been progressively decreasing since 2007 (from 0.4% to 0.31%), suggesting 
that  cumulatively  their  markets  were  hit  harder  than  those  of  other  manufacturing  sectors  by  the  2008 
financial and economic crisis58. Since then, their share has not returned to pre-2008 levels. 

There are important differences in the production values for the selected products among the EU27 Member 
States as shown in Figure 5-1 for the average annual production59 values over the last five years compared 
with the previous five years. Product-specific information by country are provided later in this Annex. 

55 Eurostat Structural Business Statistics (sbs data)  

56 Defined as the aggregation of the two NACE Rev. 2 codes C26 – “Manufacture of computer, electronic and optical products” 

and C27 – “Manufacture of electrical equipment” 

57 The apparent consumption was calculated as Production level + Extra-EU27 imports – Extra-EU27 exports. 

58 At the same time, external factors such as the emergence of new products and services may help explain the overall evolution. 

59  A  five-year  average  is  used,  as  annual  data  could  give  an  inaccurate  picture  because  there  can  be  significant  fluctuations  in 

production values, largely due to data availability. 

58 

 
 
 
 
 
 
 
 
 
 
                                                      
Figure– Top 10 Member States in terms of annual average production of the 14 selected products, million 
Euro. 2007-2012 and 2013-2018.  

av. 2007-12

av. 2013-18

12.000

10.000

8.000

6.000

4.000

2.000

0

y
n
a
m
r
e
G

k
r
a
m
n
e
D

y
l
a
t
I

d
n
a
o
P

l

e
c
n
a
r
F

i

n
a
p
S

y
r
a
g
n
u
H

d
n
a
n
i
F

l

n
e
d
e
w
S

a
i
k
a
v
o
l
S

Source: CSIL processing Prodcom data 

Looking at the contribution of each country to the total EU27 production of each product, it emerges that: 

• 

Denmark accounts for 57% of the EU27 production of wind turbines; 

Germany  accounts  for  57%  of  solar  photovoltaic  inverters  (and  Finland  also  has  a  high 

• 
market share, 14%); 

• 

• 

Poland accounts for 47% of washing machines; 

Slovakia accounts for 43% of switching power supplies. 

Intra- and extra- EU trade for selected apparatus and fixed installations 

This section presents cumulative trade levels for the selected group of products, both within and outside the 
EU27, and the main trade partners.  

Between  year  2007  and  2018,  imports from  intra-EU27  and  extra-EU27  countries  grew at  similar  rates. 
However, exports to intra-EU27 countries increased more rapidly than exports to extra-EU27 countries.  

Overall, the EU has a negative trade balance for the selected electrical equipment products, with China being 
the largest partner for imports to the EU (see Figure 5-3) and the UK accounting for largest share of exports 
from the EU (see Figure 5-4). 

59 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure– Extra-EU27 trade of the 14 selected products, million Euro. 2007-2019. EU27 

50.000
45.000
40.000
35.000
30.000
25.000
20.000
15.000
10.000
5.000
0

2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019

Import

Export

Trade deficit

Source: CSIL processing Comext data 

As  a  result  of  growing  competition  from  manufacturers  outside  the  EU27,  some  companies  have  been 
pushed  out  of  the  market,  others  have  consolidated  in  larger  groups,  others  have  relocated  part  of  their 
production outside the EU27.  

Electronics  (computers,  televisions,  and  mobile phones60)  and electrical  products (domestic  appliances) 
were  two  of  the  three  manufacturing  subsectors  that  suffered  the  most  from  offshoring  trends,  together 
accounting for around 60% of total offshoring job losses, according to a 2016 ERM report61. 

It remains to be seen to what extent supply chain disruptions in the availability of key electronic parts and 
components due to the COVID-19 pandemic will lead to changes in practices of EU manufacturers regarding 
their sourcing. 

When considering the contribution of each Member State to the total value of exports and imports of the 
selected products, it can be highlighted that the Netherlands emerges, by far, as the largest exporter and 
importer both intra and extra-EU, thanks to its position as a large ports hub. Germany ranks second but it is 
the largest manufacturing country for export and consumption market for import. Czechia and Poland are 
respectively the 3rd and the 5th largest exporters of the selected products (with France being the 4th). For 
both Czechia and Poland, intra-EU27 flows account for over 83% of the total values, whereas for Germany 
and France this share is around 61%. 

Among  the  top  10  countries  where  EU  exports  go  to,  besides  the  United  Kingdom,  Turkey,  the  United 
States, Malaysia, and Mexico, the other importers are from the South-East Asian region, with China being 
the main importing country in this region. 

Approximately 60% of extra-EU27 imports of the 14 selected products to the EU in 2018 came from China. 
The significant growth of imports from China started in the early 2000s and has been growing exponentially 
since 2014. As a result, the same exponential growth was observed in terms of the trade deficit with China. 

60 Televisions and mobile phones are not product under EMCD but they are also impacted by EMCD product, and here the electrical 

market is presented on a whole. 

61 ERM annual report 2016: Globalisation slowdown? Recent evidence of offshoring and reshoring in Europe (2016). The third 

manufacturing sector included in the 60% figure is the production of motor vehicles. 

60 

 
 
 
 
 
 
                                                      
Figure  – Imports to the EU: Top 10 non-EU countries for the 14 selected group of products, million Euro. 
2010-2019. EU27 

30.000

25.000

20.000

15.000

10.000

5.000

0

i

a
n
h
C

K
U

A
S
U

a
i
s
y
a
a
M

l

o
c
i
x
e
M

d
n
a

l
i

a
h
T

n
a
w
a
T

i

y
e
k
r
u
T

m
a
n
t
e
V

i

s
e
n
p
p

i

i
l
i

h
P

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

Source: CSIL processing Comext data 

Export partners are more varied, with the UK accounting for the largest share of extra-EU exports, followed 
by the US. They are followed by Russia (whose imports from the EU recorded a strong contraction in 2014 
due to trade restrictions but have been improving over the last three years), Switzerland, and China.  

The US accounted for only 15% of extra-EU27 exports in 2019. The trend of trade between the EU27 and 
the US has been fluctuating over the last ten years. The contraction in exports to the US between 2010 and 
2013 was mainly due to a decline in the export of wind turbines. After 2013, exports have been steadily 
growing.  

It should be noted that whilst trends in exports and intra-EU trade data provide interesting context, as the 
essential requirements have not changed in 32 years since the EMCD’s adoption in 1989, no correlation or 
causation in terms of market size and structure and the EMCD can be easily derived. However, the survey 
results and interviews confirmed that most stakeholders viewed the impacts of the EMCD on facilitating 
trade within the EU and exports globally as beneficial. Also, the trend of increasing trade exchanges has not 
been reversed. 

61 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Figure  – Exports from the EU: Top 10 non-EU destination countries for the 14 selected groups of products, 
million Euro. 2010-2019. EU27 

7.000

6.000

5.000

4.000

3.000

2.000

1.000

0

K
U

A
S
U

a
i
s
s
u
R

2010

2011

2012

d
n
a
l
r
e
z
t
i

w
S

2013

Source: CSIL processing Comext data 
Production evolution and supply structure 

i

a
n
h
C

y
a
w
r
o
N

y
e
k
r
u
T

n
a
p
a
J

a

i
l

a
r
t
s
u
A

2014

2015

2016

2017

2018

a
e
r
o
K
h
t
u
o
S

2019

The aggregated data on the production evolution of the 14 selected products between 2007 and 2018 in the 
EU27 shows cumulatively a decline in production by an annual average rate of 3%. 

A longer time series (1995-2018) is available for 7 out of 13 categories of products. Overall, their production 
has grown steadily since the mid-1990s, with an annual average growth rate of 5%. Their performance in 
the period 1995-2007 was much stronger than in the subsequent period (2008-2018), with an overall annual 
growth rate of 11% (Table 1). 

Table - Production of the 14 selected products, compound annual growth rate (CAGR). 1995-2018. EU27 

Source: CSIL processing Prodcom data 
Note: “Power Line Communication” apparatus is not displayed in the table because it is part of the “Computer networks” installation. 

Looking at the contribution of the individual products within scope allows to identify different patterns: 

  Most  of  the  cumulative  negative  trend  observed  at  the  aggregate  level  is  due  to  the  negative 
performance of computer networks and cable TV networks, and, to a smaller extent, to washing 

62 

 
 
 
 
 
 
 
machines and induction hobs. In fact, these are the only products in scope that did not overcome 
their pre-crisis level by 2018.   

Figure - Production of selected products, million Euro. 2007-2018. EU27 

Source: CSIL processing Prodcom data.  
Note: The selection of the sub-group of four products included in the Figure was driven by the identification of a negative trend over the 
considered timespan. 

  The production of LED lights, solar inverters and wind turbines shows an overall positive dynamic 
over the 2007-2018 period, as these products do not show signs of a permanent impact of the 2008 
crisis. Different reasons underlie their positive trends: the growth of LED lights was mainly driven 
by  technological  innovation,  but  also  by  regulations  supporting  energy  efficiency  (e.g.  the  Eco-
design Directive) and solar inverters and wind turbines benefited from public support programmes 
and incentives in support of renewable energy.  

Figure - Production of selected products, million Euro. 2007-2018. EU27 

Source: CSIL processing Prodcom data.  
Note: The selection of the sub-group of three products included in the Figure was driven by the identification of a positive trend over the 
considered timespan. 

  Before  2008,  some  electrical  appliances  (Washing  machines,  Power  tools,  TV  screening  and 
signage, and Microwave ovens) already showed a declining or stable trend in the 2003-2007 period, 
which contrasts with the positive dynamic characterising the 1995-2002 years and which can be 
attributed mainly to the offshoring process and import competition. The financial crisis has further 
negatively affected these productions, and only Power tools show a clearly positive trend from 2011 
onwards. 

63 

 
 
 
 
 
 
Figure - Production of selected products, million Euro. 1995-2018. EU27[3] 

Source: CSIL processing Prodcom data.  
Note: The selection of the sub-group of four products included in the Figure was driven by the identification of a stable or declining trend over the 
2003-2007 period. 

Three  products  (air  conditioning  systems,  switching  power  supply  and  vacuum  cleaners)  cannot  be 
attributed to any of the three patterns identified. As illustrated in Table 1, Air conditioning systems and 
Switching power supply suffered a moderate decline in terms of compound annual growth rate between 
2008  and  2013  (-2%),  followed  in  the  2013-2018  period  by  a  moderate  recovery  for  Air  conditioning 
systems (+2%) and a stronger one for Switching power supply (+7%). The production of Vacuum cleaners, 
by contrast, remained rather stable over the entire period (+1% in 2008-2013 and 0% in 2013-2018, in terms 
of annual compound growth rate). No data are available on the pre-2008 production of these three products.  

Considering production data by EU Member State, Section 3 illustrates that Germany is cumulatively the 
largest producer of the selected products, followed by Denmark and Italy. 

As shown in Figure 4, most of Denmark’s production is due to their strong global market position in wind 
turbines, without which it would rank 9th after Sweden and report a negative 10-year performance for the 
other products within scope. Similarly, washing machines account for most of the production from Poland, 
and  computer  networks  account  for  a  high  percentage  of  production  in  Hungary  and  Sweden,  solar 
photovoltaic inverters in Finland, and switching power supply in Slovakia. 

More specifically, looking at the contribution of each country to the total EU27 production of each product, 
it emerges that: 

  Denmark accounts for 57% of the EU27 production of wind turbines; 
  Germany accounts for 57% of solar photovoltaic inverters (and Finland also has a high market share, 

14%); 

  Poland accounts for 47% of washing machines; 
  Slovakia accounts for 43% of switching power supplies. 

64 

 
 
 
 
 
 
 
 
 
Figure - Top 10 largest Member State production by product type, million Euro. 2018. 

Source: CSIL processing Prodcom data 
Note: “Power Line Communication” apparatus is not displayed because it is part of the “Computer networks” installation. 

 Trade evolution 

Table 2 shows the levels of EU27 trade for the selected products with EU27 Member States and countries 
outside of the EU27 (referred to as intra- and extra-EU countries). Table 3 and Table 4 present the evolution 
of EU27 trade of each of the considered category of products between 2002 and 2018.  

Table - Intra and extra-EU27 trade of the 14 selected products, million Euro. 2018. EU27 

Intra-EU 

Extra-EU 

Export 

Import 

Export 

Import 

Trade 
Balance 

Top importing 
partner 

Air conditioning 
installations 

541 

729 

Cable TV networks 

245 

413 

155 

462 

1,456 

-1,301 

362 

100 

Computer networks 

21,319 

18,160 

14,590 

23,914 

-9,324 

Induction hobs 

1,007 

990 

424 

180 

244 

LED lights 

3,279 

3,003 

1,626 

3,799 

-2,173 

Microwave ovens 

291 

307 

Power tools 

2,579 

2,416 

Solar Photovoltaic 
inverters 

2,477 

2,007 

576 

-487 

1,629 

-791 

China 

823 

1,440 

89 

838 

2,263 

65 

China 

USA 

China 

China 

China 

China 

China 

 
 
 
 
 
  
  
Switching power supply 

1,420 

1,266 

TV screens and signage 

319 

261 

Vacuum cleaners 

2,526 

2,525 

Washing machines 

2,151 

2,049 

949 

221 

626 

877 

1,939 

346 

-990 

-125 

1,859 

-1,233 

1,264 

-387 

Wind turbine 

2,107 

2,017 

2,711 

121 

2,589 

Total 

40,260 

36,142 

25,831 

38,268 

-12,437 

China 

China 

China 

Turkey 

China 

Source: CSIL processing Comext data  
Note: “Power Line Communication” apparatus is not displayed in the table because it is part of the “Computer networks” installation. 

Table - Intra and extra-EU27 export of the 14 selected products, compound annual growth rate (CAGR). 
2002-2018. EU27

Source: CSIL processing Comext data  
Note: “Power Line Communication” apparatus is not displayed in the table because it is part of the “Computer networks” installation. 

Table - Intra and extra-EU27 import of the 14 selected products, compound annual growth rate (CAGR). 
2002-2018. EU27 

Source: CSIL processing Comext data 
Note: “Power Line Communication” apparatus is not displayed in the table because it is part of the “Computer networks” installation. 

With reference to specific products, the analysis of trade data leads to the following findings: 

  The most traded product is by far Computer networks.  

66 

 
 
 
 
  
 
 
 

Intra-EU27 trade shows similar monetary values for all products except for Cable TV networks, 
Microwave ovens, and TV screens and signage, whose aggregate monetary trading value is well 
below the level of the other products.  

  Some of the products within scope have high levels of extra-EU27 exports, such as wind turbines, 

Solar Photovoltaic inverters, and LED lights.  

  Wind turbines and solar photovoltaic inverters are also the products that recorded the highest trade 

surplus.  

  A  positive trade  balance  was  also  reported for  Cable TV  networks  and  Induction  hobs  but  with 

much smaller values. 

  Washing machines (for which the entire 1995-2018 time series data is available, see data presented 
above) used to be the product with the highest trade surplus until 2007. After 2007, the trade balance 
started to decline, and became negative in 2011. It has worsened progressively since then. 

Trends and developments within the EMC market 

There is a growing need to consider the following factors in the evolution of electrical and electronic product 
markets: (1) the increase in connected products, (2) the emergence of new types of electrical equipment, (3) 
the presence of new economic operators in the market and (4) the development of e-commerce. 

Over the past 5-10 years in particular, electronic products and equipment have increasingly been influenced 
by the emergence and growth of the Internet of Things (IoT), meaning more and more products can be 
connected through internet. The growth in the IoT is expected to have a significant impact on the application 
of the EMCD, as products connected to the Internet via radio (wirelessly) are not covered by the EMCD. 
They fall within the RED’s scope - see section 5 for more details.  

Overall, whilst the IoT is a growing market that has impacted on the scope of products falling under the 
EMCD,  there  has  in  parallel  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.  

Although the growth of internet-connected electrical equipment (falling under the EMC requirements of the 
RED) is an important trend, it needs to be considered in the wider context of significant overall growth in 
the  EU  electrical  equipment  market  –  Figure  –  Production  evolution  of  electrical  equipment,  Million 
Euro. 2008-2018. EU27 below. A greater number and variety of products which fall under the EMCD are 
present  in  the  market  than  when  the  Directive  was  adopted  in  1989.  A  significant  evolution  could  be 
observed since the 2004 recast Directive, and even the 2014 NLF-aligned Directive. The environment in 
which apparatus are placed contains a lot more  electrical  equipment located at closer distance from one 
another  than  in  the  past.  As  a  result,  the  EMCD  is  considered  to  have  increased  in  relevance  as  the 
environment  for  which  products  are  intended  for  use has  changed,  resulting  in  the  need  to  consider the 
possibility of putting in place more stringent limit values (LVs) in some cases, and also reviewing LVs in 
harmonised standards more regularly. This would help to address concerns among radio users about the 
cumulative impacts of disturbance. 

67 

 
 
 
 
 
 
 
 
 
Figure  – Production evolution of electrical equipment, Million Euro. 2008-2018. EU27 

600.000

500.000

400.000

300.000

200.000

100.000

0
2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018

Electrical equipment (C27)

Computer, electronic and optical products (C26)

Source: CSIL processing Eurostat data 

The  relevance  of  e-Commerce  is  envisaged  to  grow  over  the  coming  years,  as  this  form  of  shopping 
becomes more ubiquitous and is further invigorated by the effects of the Covid-19 pandemic. The increasing 
digitalisation of distribution channels for electrical products resulting from the growth of e-commerce means 
that Market Surveillance Authorities (MSAs) face more difficulties in identifying non-compliant products 
placed  on  the  European  market.  To  give  an  example,  this  is  the  case  for  LED  products  sold  via  online 
platforms  as  indicated  by  the  case  studies.  MSAs  suggested  that  marketplaces  outside  the  EU  pose  a 
particular  challenge  in  this  regard,  although  national  MSAs  reported  good  cooperation  with  the  biggest 
marketplaces in removing non-EMCD compliant products, after having been alerted by MSAs. E-commerce 
in Europe grew to €621 billion in 2019 and to €757 billion in 2020, which constitutes an increase by 21,9% 
compared to 2019. 

The key challenges stemming from the above market-related developments are the increasing presence of 
non-compliant products on the market including the increased proportion of products from third countries, 
which according to stakeholder were more often non-compliant. In addition, the growing number of products 
in the market makes it more difficult for the Member States to monitor their compliance and enforce EU 
rules. Furthermore, there has been a large increase in the entry of goods into the EU through direct consumer 
online purchases, which cannot be controlled and tracked through traditional methods62. The sheer volume 
of products makes it impossible to control all shipments, as imports constitute 30% of all products placed 
in the EU. 

[1] Induction hobs, LED lights, Microwave ovens, Power tools, Solar Photovoltaic inverters, TV screens and signage, Washing machines. 

[2] As explained under Section 1.3.5, Powerline Communications can be considered included into the data for “Computer networks”. 

[3] Before 2003, data refer to EU15 Member States only (Austria, Belgium, Denmark, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, 
Netherlands, Portugal, Spain, Sweden, and the United Kingdom). 

62 V. J Massad and K. Berardelli. (2016). The Roles of Bounded Rationality and Ethical Self-efficacy in Online Shopping 
Orientation. Academy of Marketing Studies Journal, Vol. 20, No.3, 2016, pp. 26-37 

68 

 
 
 
 
 
 
 
                                                      
 
The case studies presented cover the following products:  

ANNEX 5  

CASE STUDIES 

• Case study 1 – Powerline Communications (PLCs);  
• Case study 2 – Ready-made connecting devices (RMCD);  
• Case study 3 – Solar photovoltaic inverters and optimisers;  
• Case study 4 – LED lights; and  
• Case study 5 – Wireless power transfer chargers for electric vehicles (WPT for EVs).  

Case studies – overview of key issues identified 

Product type 

Key issues identified in case studies 

Powerline 
Communications 
(PLCs) 

  PLCs  were  raised  as  a  concern  in  terms  of  the  electromagnetic 
disturbance generated by many radio amateurs and some MSAs in the 
interviews, targeted and open consultations. There were concerns for a 
period of years that no suitable Harmonised Standard (HS) was available 
for  such  products,  despite  the  disturbance  issue  being  discussed  in 
technical communities. However, a HS was developed  [1] and published 
in 2015.  

  On  the  positive  side,  there  have  been  technological  advances  in  the 
design  of  PLCs  to  reduce  disturbance  through  the  use  of  notching 
techniques to avoid creating disturbance to short-range radio waves used 
by radio amateurs.  

  However,  whereas  powerline  equipment  searches  for  any  potential 
conflicting  radio  signals  used  by  other  electrical  equipment  using 
dynamic notching to check for compatibility with other frequency bands 
being used, some radio frequency bands may not be detectable whilst in 
use (e.g. radio amateur and aeronautical frequency bands).   

  The Harmonised Standard EN 50561-1 requires notching broadcast and 
other  essential  radio  services.  However,  mandatory  notches  appear  to 
create interference, which could be caused by intermodulation in the unit 
itself  or  by  other  units  connected  to  the  power  line.  Accordingly,  a 
revised  standard  is  under  development  to  overcome  these  technical 
challenges  which  could  in  future  be  put  forward  as  a  harmonised 
standard. 

  The effectiveness of the only existing harmonised standard in reducing 
disturbance created by PLCs was questioned by some stakeholders (e.g. 
radio  amateurs,  some  MSAs).  Some  PLC  products  remain  on  the 
European  market,  even  though  the  manufacturers  know  that  the  EM 
disturbance  being  created  may  impede  some  radio  equipment  from 
functioning. However, they are legally able to demonstrate presumption 
of  conformity  with  the  essential  requirements  based  on  the  existing 
harmonised standard. 

  PLC  technologies  are  evolving,  such  as  the  growing  use  of  MIMO 
technologies. This poses challenges for standardisation bodies in terms 
of the timeframes for developing new harmonised standards to ensure 
that these represent state of the art. 

69 

 
 
 
 
 
 
  The non-inclusion of noise filters could be an unintended consequence 
of allowing PLC products onto the market without stricter requirements, 
according  to  some  stakeholders  (e.g.  radio  amateurs,  consultants 
specialising in EMC). This can disturb the operation of the equipment 
of radio amateurs.  

Conclusions 

  PLCs  were  seen  as  being  a  problematic  product  in  terms  of  EM 
levels  vary  across 

interference 

disturbance  generated,  although 
products.  

Ready-made 
connecting devices 
(RMCD) 

  Whilst several stakeholders indicated that PLCs remain a product group 
of concern from the point of view of radio interference levels due to both 
EM emissions and  high noise levels (80 – 90 dB), PLCs may become 
less  widely  used  in  future.  Wireless  technologies  are  becoming  more 
ubiquitous,  and  technological  progress  has  been  made  through  the 
development of Wi-Fi 6 (802.11ax). This is expected to enable routers 
to  better  handle  the  growing  number  of  internet-connected  devices  in 
homes, offices and industrial environments. 

  The delay in the development of the harmonised standard for PLCs prior 
to its citation created some degree of regulatory uncertainty for a number 
of  years.  Some  PLC  manufacturers  were  able  to  exploit  gaps  in  the 
availability of a harmonised standard in the interim period before it was 
available and then cited.  

  Harmonised  standards  appear  to  be  an  effective  tool  to  address  the 
problem of EM disturbance generated by PLCs, although the technical 
characteristics of the original HS for PLCs needs to be updated to rectify 
some challenges in the efficacy of notching in some circumstances 

  RMCD are considered to be passive but are designed to be connected to 
apparatus covered within the EMC or RE Directive's scope. RMCD are 
the  EMC  Directive  (Directive 
the  scope  of 
presently  outside 
2014/30/EU), due to being considered 'inherently benign’. 

  Whilst cables are passive, and therefore outside the Directive’s scope, 
RMCD were raised as a concern by many radio amateurs and MSAs in 
terms of the disturbance they generate.  

  A further problem is that even though some industry standards exist for 
cables, as cables are excluded from the Directive’s scope, these are not 
harmonised standards. Moreover, there are cheap cables on the market 
that  fulfil  the  technical  requirements  of  industry  standards,  but 
expensive cable that do not fulfil the requirements, but as the products 
are not regulated, MSAs cannot remove these products from the market.  
  RMCD have been subject to joint surveillance campaigns twice by the 
EMC ADCO firstly in 2012, with a follow-up campaign in 2021. 
  The  2012  benchmarking  assessment,  conducted  by  three  MSAs  – 
Bundesnetzagentur (DE), OFCOM (CH) and Agentschap Telecom (NL) 
– focused on assessing the level of interference caused by ready-made 
coaxial connecting devices (receiver leads) for cable TV and IT services 
with  IEC  and  F-  connectors.  Other  types  of  ready-made  connecting 
devices,  such  as  SCART  or  HDMI  cables  were  excluded  from  the 
exercise at that time. However, a limitation is that coaxial cables for TVs 
now mainly fall under the RED’s scope. 

70 

 
 
 
 
  Among  the  findings  from  the  2021  surveillance  campaign,  which 

focused on cables falling under the EMCD’s scope, were that: 

  Only 13% of coaxial RMCD meet the respective class A requirements 

(screening classes according to EN 60966 series). 

  Only 11% of the coaxial RMCD meet their own declaration with regard 

to screening attenuation or class. 

  Compared to the benchmark  results from 2012 a  medium  decrease of 

quality parameters of coaxial RMCD has been observed. 

  Only 10% of the HDMI RMCD meet an acceptable quality limit of 50 

dB coupling attenuation. 

  For both types of RMCD, no correlation between price and EMC quality 

could be observed  

  Spot checks of the  mechanical resistance of the samples to pull  force 

stress showed negligible impacts.   

Conclusions 

  Ready-made connecting devices are inherently benign equipment,  but 
when  connected  to  electrical  devices  falling  under  the  EMCD  scope, 
may system-wise become non-benign, leading to EM interference.  
  The level of such interference cannot presently be checked by MSAs as 
RMCD  are  outside  the  Directive’s  scope.  Poor  quality  cables  that 
generate disturbance cannot be removed from the market.  

  There  was  a  consensus  that  product  testing  of  apparatus  against  the 
EMCD’s essential requirements should be made with RMCD connected 
to  the  apparatus,  as  there  is  a  need  to  ensure  testing  occurs  in  a  real-
world environment. As equipment is used with cable connecting devices 
plugged in, RMCD should be plugged in with the specific equipment it 
is designed for.  

  Consideration should be given to bringing RMCD within the Directive’s 
scope, supported by a clear definition of such devices. Article 2 (d)(i) on 
benign products could therefore be reviewed by the Commission. 
  However,  it  should  be  noted  that  the  European  industry  association, 
Europa cable and their members are against any changes to the EMCD 
in bringing some types of cables within the EMCD’s scope and are in 
favour of a continuation of the status quo. 

 

  The  results  from  the  2021  study  demonstrated  the  poor  EMC  quality 
levels of both coaxial and HDMI RMCD in the current market. These 
findings should be considered to estimate whether a regulatory or non-
regulatory approach would be more effective. 
It  would  be  easier  for  MSAs  to  address  the  challenges  identified  if 
certain  types  of  cables,  namely  RMCD,  were  included  within  the 
Directive’s  scope,  as  their  exclusion  means  that  they  are  not  part  of 
European standardisation processes. Harmonised standards could help 
to resolve some of the technical problems identified and improve cable 
quality.  

Solar photovoltaic 
inverters and 
optimisers 

  There is a debate among EMCD stakeholders regarding whether solar 
panels should be classified as apparatus or as fixed installations.  
  According  to  most  but  not  all  MSAs,  they  should  be  considered  as 
apparatus  (so  long  as  they  include  standardised  parts  that  are  then 

71 

 
 
 
 
reassembled  in  a  solar  panel  installation),  with  all  consequences  this 
entails in terms of regulatory compliance.  

  There  is  a  question  mark  as  to  whether  it  is  sufficiently  clear  which 
actors  are  responsible  for  EMCD  compliance  of  solar  panels.  In  MS 
where MSAs consider them to be a fixed installation, the building owner 
is  responsible  for  checking  disturbance.  Installers  are  not  presently 
directly  responsible  under  the  EMCD,  although  there  may  be 
requirements  for 
them  to  assume  responsibility  under  national 
legislation pertaining to the installation of equipment in buildings. 
  Both inverters and optimisers that are parts integrated into solar panel 
installations have been found to cause EM disturbance in many product 
types. 

  As two ADCO campaigns have demonstrated (in 2014 and 2019), many 
solar inverters are non-compliant with existing harmonised standards. In 
this regard, increasing market surveillance actions could be part of the 
solution.  

Conclusions 

  Due  to  rapid  changes  in  electrical  current,  solar  panel  inverters,  can 
generate high electromagnetic interference emissions. Through cables, 
disturbance can also be radiated into the surrounding environment. To 
avoid  this,  EM  reduction  and  minimisation  measures  need  to  be 
implemented, such as making greater use of shielding and filtering.  
  During its 2014 campaign, the MSAs from the EMC ADCO taking part 
found  a  low  level  of  both  administrative  and  technical  compliance 
among  sampled  inverters.  In  its  2019  campaign,  compliance  was  not 
found to have improved. 

  While  solar  panel  inverters  can  be  problematic  in  terms  of  EMC,  the 
difficulty appears to be not related to the EMC Directive, but rather to 
standardisation, and more specifically to non-compliance with existing 
standards. Whilst previously there was a lack of specific standards for 
solar  inverters,  since  2010  standards  have  been  in  place,  but  not 
necessarily complied with. In this regard, increasing market surveillance 
actions  could  be  part  of  the  solution.  Currently,  the  highest  EMCD-
related priority with regard to solar panels lies in increasing the number 
of compliant solar inverters. 

  While  non-compliant  products  represent  the  biggest  issue,  a  second 
problem  is  that  some  harmonised  standards  are  perceived  as  not  yet 
being  optimal  to  prevent  or  at  least  to  reduce  EM  disturbance 
sufficiently.  Overall,  it  is  difficult  to  generalise  whether  additional 
changes  in  standards  are  needed  or  not.  Current  measures  could 
potentially  be  sufficient,  if  consistently  applied  across  the  board.  For 
standards  for  microinverters/optimisers  in  particular,  it  can  be  argued 
that  there  is  room  for  further  developments  (e.g.  with  regard  to 
measurements on cables under 3 meters). 
In  the  case  of  optimisers,  further  standardisation  work  could  be 
undertaken  to  set  technical  parameters  that  would  enable  an  adequate 
level of EM compatibility.  

 

72 

 
 
 
 
LED lights and 
luminaries 
integrating LEDs 

  Whilst  not  all  LED  lights  and  luminaries  integrating  LEDs  cause 
disturbance,  LEDs  were  mentioned  relatively  often  by  respondents  to 
the targeted and public consultations as being problematic.  

  One of the key issues is the fact that there has been a proliferation in the 
use of LED lights, and these lights are often placed in close proximity 
to one another.  They  may therefore sometimes cause EM  disturbance 
that  interferes  either  with  other  LED  lights,  and  /  or  with  other 
equipment.  

  Similar  to  RMCD,  LEDs  have  been  subject  to  a  previous  joint 
surveillance  campaigns  by  the  EMC  ADCO  (4th  EMC  Market 
Surveillance Campaign 2011), and a new campaign will be launched to 
test them in 2021. 

  A technical issue raised was that there is evidence of minor divergence 
in the limit values set for LEDs in HS under the EMCD and the RED 
respectively, depending if a LED product has been integrated with radio 
functionality / internet connectivity. This means that there is divergence 
in the  limit values for  wired and  wireless products,  which is complex 
from  a  manufacturers’  perspective.  They  would  prefer  common  LVs 
across a suite of wired and wireless products.  

Conclusions 

  MSAs should engage in more proactive surveillance of LED products 
from third countries. There should be a particular focus on improving 
the surveillance of online marketplaces which introduce LED products 
to the European market where non-compliance levels and the prevalence 
of cheaper, lower-quality products is perceived to be higher. 
  Use of dissuasive penalties for non-compliant economic operators. 
  The cumulative effects of the use of numerous individually compliant 
LED in office-, industrial lightning and LED-panels at the same time in 
LED  walls  needs  to  fully  considered  within  the  EMCD’s  legal 
implementation framework. The cumulative effects of disturbance could 
be incorporated into the design of harmonised standards and the setting 
of  limit  values  rather  than  in  the  EMCD  itself,  although  the  need  for 
manufacturers to strengthen attention to cumulative EM emissions could 
be mentioned in the Directive’s recitals. 

  The development of harmonised standards should be accelerated by the 
responsible European standardisation organisations, to ensure that new 
technologies  can  be  accommodated  more  quickly  such  as  to  maintain 
their role as accommodating state-of-the-art. 

  Better awareness of the negative impact of the use of low-quality LEDs 
that generate disturbance is required among economic operators and the 
general public. 

  Awareness-raising  of  the  possible  technical  solutions  to  limit  LED-
related  disturbance,  e.g.  using  two-stage  power  supplies  or  replacing 
transformers  of  MR16  lamps,  might  constitute  a  practical  mitigating 
measure.  

Wireless power 
transfer chargers for 

  Wireless power transfer for electric vehicles (WPT for EVs) is a state-
of-the-art  technology.  It  offers  the  advantages  of  convenience  and 
flexibility,  as  well  as  the  capability  of  enabling  fully  automated 
charging. 

73 

 
 
 
 
electric vehicles  
(WPT for EVs) 

  Most WPT for EVs fall within the scope of the RED, but some that do 

not have communication capabilities fall under the EMCD.  

  There is a need to strike a balance between  high switching frequency 
(and increased power) and high frequency electromagnetic interference: 
frequency 
when 
electromagnetic 
electromagnetic 
compatibility becomes a challenge. 

increases, 
frequency 

frequency 
or 

interference 

switching 

high 

the 

  There  are  concerns  regarding  the  risk  of  the  degradation  of  WPT 
chargers for EV cars and buses over their full lifetime, which may be up 
to 20 years, as these are embedded in tarmac and risk erosion with the 
weather. The impacts on health and on levels of disturbance over time 
need to be checked and factored into the development of HS.  

  EMCD-related issues needs to be considered alongside health and safety 
issues, given concerns around the use of WPT for EVs and human health 
raised by some interviewees and in literature.  

Conclusions 

  With  WPT  for  EVs,  there  is  a  need  to  strike  a  balance  between  high 
switching  frequency  (and  increased  power)  and  high  frequency 
electromagnetic interference: when the switching frequency increases, 
high 
frequency 
interference 
electromagnetic compatibility becomes a challenge. 

electromagnetic 

frequency 

or 

  Research  has  demonstrated  that  shielding  structures  can  significantly 
mitigate  the  magnetic  field  in  an  automotive  WPT  system  with  very 
limited  influence  on  electrical  performance.  Further  research  in  this 
domain is ongoing.  

  Unsurprisingly,  manufacturers  of  WPT  for  EV  are  confident  of  the 
safety of the technology with regard to human health. However, as other 
stakeholders  have  expressed  some  considerable  concerns,  this  issue 
could  be  examined  in  parallel  with  EMC-related  issues  by  regulators 
(i.e. the implications of WPC for EVs extend beyond the EMCD alone.  
  WPT for EVs could be vulnerable to cybersecurity threats, particularly 
high-power  WPT  and  wired  extreme  fast  charging  installed  in  public 
places. Vulnerabilities may result in negative impacts on public safety 
and  electric  grid  security,  in  addition  to  denial  of  service,  hardware 
damage, and theft or alteration of data. 

  Stakeholders agree on the need to regulate WPT for EVs. There is a lack 
of clarity regarding whether the EMCD or RED should be applicable for 
such technologies. The issue of how ‘radio waves’ are defined is at the 
heart of this question, and is an issue that may need to be addressed in 
future. 

  There  is  currently  no  harmonised  standard  covering  WPT  for  EVs. 
Stakeholders expect the process of developing an appropriate standard 
to  take  considerable  time,  based  on  recent  experience  with  other  new 
technologies. This risks leaving a gap for manufacturers in the interim 
period until such a HS has been developed.  

[1] EN 50561-1;2013/AC:2015; Power line communication apparatus used in low-voltage installations - Radio disturbance characteristics - Limits 
and methods of measurement - Part 1: Apparatus for in-home use 

74 

 
 
 
 
 
 
ANNEX 6  

DESK RESEARCHS 

EU legal framework - EMCD 

  Council Directive 89/336/EEC of 3 May 1989 on the approximation of the laws of the Member States 

relating to electromagnetic compatibility (OJ L 139, 23.5.1989, p. 19–26). 

  Directive 2004/108/EC of the European Parliament and of the Council of 15 December 2004 on the 
approximation of the laws of the Member States relating to electromagnetic compatibility (OJEU L 390, 
31.12.2004, p. 24–37).  

  Directive  2014/30/EU  of  the  European  Parliament  and  of  the  Council  of  26  February  2014  on  the 
harmonisation of the laws of the Member States relating to electromagnetic compatibility (recast) Text 
relevance,  OJ  L  96,  29.3.2014,  p.  79–106,  https://eur-lex.europa.eu/legal-
with  EEA 
content/EN/TXT/?uri=celex%3A32014L0030  

  COMMISSION IMPLEMENTING DECISION (EU) 2019/1326 of 5 August 2019 on the harmonised 
standards for electromagnetic compatibility drafted in support of Directive 2014/30/EU of the European 
Parliament and of the Council 

  Regulatory Impact Analysis (RIA), European Union (Electromagnetic Compatibility) Regulations 2016 
to transpose Directive 2014/30/EU of the European Parliament and of the Council of 26 February 2014 
on the harmonisation of the laws of the Member States relating to electromagnetic compatibility (recast), 
Department of Jobs, Enterprise & Innovation, April 2016 

 

 Directive 2004/104/EC of 14 October 2004 of 14 October 2004 adapting to technical progress Council 
Directive 72/245/EEC relating to the radio interference (electromagnetic compatibility) of vehicles and 
amending Directive 70/156/EEC on the approximation of the laws of the Member States relating to the 
type-approval of motor vehicles and their trailers. 

  DG GROW Guidance document on the application of the EMC, December 2018 – note, non-binding 

guidance document. 

  The EMCD website of DG GROW. This includes documents adopted or endorsed by the EMCDD WP, 
the EMCD ADCO's recommendations, reports and information documents, and EC opinions within the 
the  EMCD.  See  https://ec.europa.eu/growth/sectors/electrical-engineering/emc-
framework  of 
directive_en 

Horizontal legal framework relevant to the EMCD 

  Regulation (EU) 2019/1020 of the European Parliament and of the Council of 20 June 2019 on market 
surveillance and compliance of products and amending Directive 2004/42/EC and Regulations (EC) No 
765/2008 
https://eur-lex.europa.eu/legal-
No 
content/EN/TXT/?uri=celex:32019R1020 

305/2011 

(EU) 

and 

- 

  New Legislative Framework and the associated Decisions and Regulations from 2008. 

  Regulation (EC) No 765/2008 setting out the requirements for accreditation and market surveillance 

relating to the marketing of products. 

  Decision No 768/2008/EC on a common framework for the marketing of products. 

  Regulation (EC) No 764/2008 laying down procedures relating to the application of certain national 

75 

 
 
 
 
 
technical rules to products lawfully marketed in another Member State. 

  DIRECTIVE 1999/5/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 9 March 
1999 on radio equipment and telecommunications terminal equipment and the mutual recognition of 
their conformity 

  DIRECTIVE  2014/53/EU  OF  THE  EUROPEAN  PARLIAMENT  AND  OF  THE  COUNCIL  of  16 
April 2014 on the harmonisation of the laws of the Member States relating to the making available on 
the market of radio equipment and repealing Directive 1999/5/EC 

Standardisation  

  Summary list of harmonised standards 

Relevant studies and evaluations 

  REPORT  OF  THE  SLIM  III  TEAM  ON  THE  ELECTROMAGNETIC  COMPATIBILITY 

DIRECTIVE (89/336/EEC as amended) Brussels, 24th September 1998. 

  Cost Benefit Analysis on the Draft Amendment of the EC Directive on Electromagnetic Compatibility, 

Final Report, RPA for DG Directorate-General for Enterprise, European Commission, 2002 

  Evaluation of the Machinery Directive (Directive 2006/42/EC), Technopolis, 2017 

 

Interim 
https://ec.europa.eu/docsroom/documents/38701  

Evaluation 

the 

of 

Low 

Voltage 

Directive 

(2014/35/EU). 

  Ex-post  evaluation  of  the  application  of  the  market  surveillance  provisions  of.  Regulation  (EC)  No 
- 
765/2008. 
REPORT. 
https://ec.europa.eu/docsroom/documents/26963/attachments/1/translations/en/renditions/pdf 

FINAL 

2017 

May 

  Commission Staff Working Document, Evaluation of the Machinery Directive, [SWD(2018) 161 Final], 

2018 

  CIRCABC interest groups related to the EMCD 2014/30/EU (see https://circabc.europa.eu) 

  Analysis of consultation responses received to the February 2020 evaluation roadmap published by DG 

GROW 

Reports and guidance provided by EMC stakeholder fora (e.g. EMC ADCO, EMC WP, meeting minutes) 

  EMC ADCO recommendations and meeting minutes and those of the EMC WP. 

  1st  -  10th  EMC  Market  Surveillance  Campaigns  (e.g.  covering  LED  floodlights,  induction  cooking 

hobs, etc.). 

  EMC  ADCO  list  of  national  language  requirements  (2018).  European  language  requirements  for 
products covered by EMCD 2014/30/EU v.2.0. https://ec.europa.eu/docsroom/documents/26690 

  Guide for the EMCD (Directive 2014/30/EU) – non-legally binding guidance document updated in 

2018 - 
https://ec.europa.eu/docsroom/documents/33601/attachments/1/translations/en/renditions/nati
ve  

Position papers on the EMCD e.g. by industry associations, other stakeholders 

Orgalim have published two position papers on the EMCD. 

76 

 
 
 
 
  Orgalim  Comments  on  EMC  Directive  Evaluation  Consultation  Roadmap,  2020 

- 
https://orgalim.eu/position-papers/internal-market-orgalim-comments-emc-directive-roadmap  

  CEEMET / ORGALIM Position Paper on the Electromagnetic Fields Directive (2004/40/EC), 2007 
https://orgalim.eu/position-papers/ceemet-orgalime-position-paper-electromagnetic-fields-directive-
200440ec  

International studies 

  Canada's Communication's Future  - Time to Act, Broadcasting and Telecommunications Legislative 
Review.  January  29,  2020,  the  Broadcasting  and  Telecommunications  Legislative  Review  Panel 
- 
presented 
report, 
https://www.ic.gc.ca/eic/site/110.nsf/vwapj/BTLR_Eng-V3.pdf/$file/BTLR_Eng-V3.pdf  

Independent 

report 

final 

their 

  Ryan, Mike H. A Comparative Analysis of Institutional Frameworks for the Communications Sector in 
Canada, the United States of America, Australia, the United Kingdom, France and Germany. London: 
MHRyan Law, 2019. 

Other studies and research (including literature related to products in scope) 

Risk assessments, functional safety and EMC 

  EMI Stories, Cherry Clough Consultants, Limited, A collection of 890 real-life short stories about the 
dangers of electromagnetic interference (EMI) Indexed by type of application, type of EMI, and whether 
safety was an issue, to aid research. Numbers 1-855 were originally published as ‘Banana Skins’ in The 
EMC Journal, www.theemcjournal.com 

  How  to  perform  a  risk  assessment  in  accordance  with  Directive  2014/53/EU?,  Mr  Holger  Bentje, 
PHOENIX  TESTLAB GmbH, Mr Thoralf Schulz, Federal Network Agency, REDCA, Copenhagen, 
15-May-2018, 
http://redca.online/Unrestricted%20Documents/RED%20Risk%20Assessment%20introduction.pdf  

Installations 

  Leferink, F. ‘Risk-Based vs Rule-Based Electromagnetic Compatibility in Large Installations’. In 2018 

IEEE 4th Global Electromagnetic Compatibility Conference (GEMCCON), 1–4, 2018.  

Power Line Communications (PLC) 

  P. Mlynek, R. Fujdiak, J. Misurec and J. Slacik, “Experimental Measurements of Noise Influence on 
International  Congress  on  Ultra-Modern 

Narrowband  Power  Line  Communication”,  8th 
Telecommunications and Control Systems and Workshops (ICUMT) Lisabon: pp. 1–7, 2016.  

  Special  issue  of  the  3rd  International  Conference  on  Computational  and  Experimental  Science  and 
Engineering  (ICCESEN  2016),  Application  of  Multiple  Input  Multiple  Output  Power  Line 
Communication (MIMO-PLC) to Power Systems, A. Recioui∗ 

  Laboratory Signals and Systems, Institute of Electrical Engineering and Electronics 

  University of Boumerdes, Algeria 

  P. Mlynek, J. Misurec and M. Koutny, “Noise Modelling for Power Line Communication Model”, 35th 
International Conference on Telecommunications and Signal Processing (TSP), pp. 282–286, 2012.  

  F.  Hossner,  J.  Hallon,  M.  Orgon  and  R.  Roka,  “Testing  of  Electromagnetic  Compatibility  of  PLC 
Modems”, International Journal of Engineering Research & Technology (IJERT), vol. 5, no. 01, 2016 

77 

 
 
 
 
  R. Roka, “Modelling of Environmental Influences at the Signal Transmission by means of the VDSL 
and PLC Technologies”, International Journal of Electrical Communication Networks and Information 
Security - IJCNIS, vol. 1, no. 1, 2009, pp. 6–13. 

  M. Zimmermann, K. Dostert. “Analysis and Modelling of  Impulsive Noise in Broadband Powerline 

Communications”, IEEE Transactions on Communications, pp. 249 – 258, 2002 

LEDs and lighting  

  Electromagnetic  Compatibility  Requirements  for  LED  Lighting  Products,  White  Paper,  TuV, 
https://www.tuv.com/media/india/informationcenter_1/products/documents_4/light/EMC_LED_Whit
epaper.pdf  

  EMC  measurement  systems  and  noise  suppression  methods  for  led  lamps  and  RF  lighting  controls, 
2016, 
Róbert 
Peter 
https://www.researchgate.net/publication/311212144_EMC_measurement_systems_and_noise_suppre
ssion_methods_for_led_lamps_and_RF_lighting_controls/citation/download  

Kadar, 

Istók, 

  Electromagnetic  Compatibility  of  Light-emitting  Diode  (LED)  Lamps  and  Wireless  Medical 
Telemeters, Kai Ishida, Sazu Arie, Kaoru Gotoh, Eisuke Hanada,  Minoru Hirose, Yasushi Matsumoto, 
2017  https://www.researchgate.net/publication/320016393_Electromagnetic_Compatibility_of_Light-
emitting_Diode_LED_Lamps_and_Wireless_Medical_Telemeters  

  Minimizing EMI from LED Lighting - Case Study - EMC FastPass, 2020 https://emcfastpass.com/emi-

led-lighting/  

  How 

to 

the  LED  power 
http://www.nbpengwang.com/index.php?c=article&id=128  

supply  design  EMC 

solve 

/  EMI  problems,  2015 

- 

  Schaffner, Electromagnetic compatibility of lighting equipment - Common mode chokes for lighting 

Wireless Power Chargers 

  Baikova,  Elena  &  Valtchev,  Stanimir  &  Melicio,  Rui  &  Pires,  Vítor.  (2016).  Electromagnetic 
Interference  from  a  Wireless  Power Transfer  System:  Experimental  Results.  Renewable  Energy  and 
Power Quality Journal. 1020-1024. 10.24084/repqj14.560. 

  European Commission's JRC (2018), Pliakostathis K., Scholz H. On the evaluation of Electromagnetic 
Compatibility  (EMC)  of  a  prototype  electric  vehicle:  Electromagnetic  interference  filters  and  EMC 
remedies to conducted disturbances in AC-charging. 

  UNWANTED EMISSIONS IN THE SPURIOUS DOMAIN FROM WIRELESS POWER TRANSFER 

FOR ELECTRIC VEHICLES WPT(EV), International Amateur Radio Union (IARU) 

Market Surveillance 

  GOOD PRACTICES for joint Market Surveillance actions Sectoral and cross sectoral actions in the 
new Product Compliance Network (PCN), JRC Technical Report, Larcher. F and Robouch P, February 
2020.  

Other  

  Chu,  J.  ‘Electromagnetic  Compatibility-An  Expert  Overview  [Book/Software  Reviews]’.  IEEE 

Microwave Magazine 19, no. 2 (March 2018): 85–86. 

Section on Efficiency:  

  Court  of  Justice  of  the  European  Union  (2016),  James  Elliott  Construction  Limited  v  Irish  Asphalt 

78 

 
 
 
 
Limited, Judgment of the Court (Third Chamber) of 27 October 2016. 

  European Commission (2019). Interim evaluation of the Low Voltage Directive 2014/35/EU. 

79 

 
 
 
 
 
 
 
ANNEX 7  

EVALUATION QUESTIONS 

The following evaluation matrix outlines the evaluation questions relating to each of the five evaluation 
criteria of effectiveness, efficiency, relevance (including fitness for purpose), coherence and EU added 
value. The matrix sets out judgement criteria, indicators, data sources and assessments methods. The 
evaluation matrix was aligned with the intervention logic mapping presented in the inception report and 
guided the data collection and analysis during the study. 

80 

 
 
 
 
 
 
 
Evaluation matrix 

Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

Market overview 

What is the economic 
importance of the equipment 
affected by the directive? 

  Importance, growth and trade 
in the selected product groups 
and other measures of 
economic performance since 
1989 baseline 

  Market data on main EMC 

  Commercial Data 

products groups e.g. market size 
(i.e. total consumption in the 
EU), turnover, employment, 
investment, value and volume of 
Internal and external trade 

Sources e.g. CSIL / 
MarketResearch.com  

  Eurostat’s SBS 
  COMEXT 

  Trend analysis 
  Descriptive statistics analysis 

Effectiveness: How effective has the EMCD been in achieving its objectives? 

1.  To what extent has the 
EMCD contributed to an 
effectively operating 
internal market for the 
products within scope? 

  Existence of obstacles to an 
effective Single Market 
(“SM”) e.g. extent of non-
compliance, extent of gold-
plating 

  EMC contribution to the 

removal of conflicts of 
jurisdictions of authorities 
and related advantages 

  Extent to which CE 

marking is being applied 
correctly. 

  Estimated % of products that 
comply with the essential 
requirements relating to 
electromagnetic compatibility  

  Number of infringement 

procedures against Member States 
  Feedback on perceived obstacles  
  Number of non-compliant products 
withdrawn from the market, by 
reason for non-compliance  

  Formal objections to harmonised 

standards 

  Single Market 

Scoreboard (SMS) 
ICSMS 

 
  Survey of stakeholders 
(national authorities, 
MSAs, industry 
associations and 
economic operators) 
Interviews with national 
authorities, MSAs, 
industry associations 
and economic operators 

 

  Effect on coordination 

  Complaints regarding disturbance 

  Desk review 

among national authorities 

(EMC fields) 

  Elements of EMCD 

  Number and types of “gold 

81 

 Case studies  
 Descriptive statistics analysis  
 Contextual multi-stakeholder analysis of 

perceptions around advantages 

 Qualitative assessment of ‘effectiveness’ 

evaluation criterion (focus on Single 
Market) 

 
 
 
 
 
 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

implementation that 
negatively influence its 
effectiveness 

plating” requirements and other 
obstacles introduced by Member 
States  

  Extent to which the EMCD 
applies special measures 
coherently 

  Annual frequency of disagreement 

/ conflicts of jurisdictions 

  Degree of coordination among 

national authorities 

  Reported court cases relating to the 
EMCD (including litigation) and if 
possible, also EMC requirements 
under other EU legislation (e.g. the 
RED, MDR) 

  Number of accidents, by Member 

State 

2.  To what extent has the 

  Extent of compliance of 

  Number of non-compliant 

EMC directive achieved its 
aims with regards to the 
functioning of the 
equipment? 

electrical equipment under 
EMCD 

  Extent of disturbances 

reported 

  Extent harmonised 

standards have improved 
the EMC environment 
  Extent (self-)certification is 

sufficient to ensure 
compliant equipment 
  Degree to which the 

concept of ‘intended use’ is 
sufficient 

  Extent to which there is 

evidence of applying good 

products withdrawn from the 
market, by reason for non-
compliance e.g. related to CE 
marking, declaration of 
conformity, technical 
documentation 
  Complaints regarding 

disturbance by product type 
(apparatus / fixed installation) 
  No. of requests for evidence of 

compliance of the fixed 
installation from MSAs Number 
of harmonised standards 
developed under the EMCD 
  Number of objections received 

82 

ICSMS 

 
  Market Surveillance / 
Consumer / Other 
Authorities 

  EU - European Injury 
Data Base (IDB) 
https://ec.europa.eu/heal
th/data_collection/datab
ases/idb_en  

  Survey of stakeholders  
 
Interviews 
  Desk review 
  CEN/CENELEC 
  Standardisation Experts 

  Qualitative assessment of 

‘effectiveness’ criterion (focus on the 
functioning of equipment) 

  Analysis across 14 product groups for 

which data available 

  Desk research to review non-

compliance levels (e.g. in Market 
Surveillance reports by EMC ADCO. 

  Case studies  
  Contextual multi-stakeholder analysis of 

perceptions around advantages 

 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

engineering practice for 
fixed installations.  
  Whether good practices 

being shared in this regard 
by EU MS. 

 

by CEN /CENELEC when 
launching standardisation 
processes  
1 to 5 Likert scale measure of the 
perception regarding (self-) 
certification  

  Reported court cases, litigation 
or accidents, by Member State 

3.  To what extent do notified 

  Whether a different type of 

  % of products where 

bodies help to guarantee 
that electrical equipment 
and appliances avoid 
unacceptable levels of 
electromagnetic 
interference in the 
environment? 

enhanced role for notified 
bodies could improve the 
effectiveness of the 
EMCD’s implementation  

  Whether notified bodies are 

consistent in their 
approaches 

  Extent to which technical 
documents ensures an 
acceptable EMC 
environment. 

manufacturers (or their 
authorized representatives) have 
requested a Notified Body to be 
involved in the conformity 
assessment procedure of 
apparatus. 

  Number of EU-Type 

Examination certificates 
approved by Notified Bodies 
  Number of complaints against 

notified bodies 

  Number of complaints related to 

technical documents 

Context indicators 
  % of products that comply with 
the essential requirements 
relating to electromagnetic 
compatibility 

  Survey of specific 
stakeholders (e.g. 
notified bodies, MSAs) 

  Qualitative assessment of role of 
notified bodies in ensuring an 
acceptable electromagnetic environment  

  Desk review 
  Focus group  
 
ICSMS 

4.  To what extent are users 

  User awareness about the 

  Number / % of users aware of 

  Survey of stakeholders 

  Assessment of survey results 

83 

 
 
 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

aware about the EMC? Is 
information sufficient to 
avoid misuse? 

EMC Directive and the 
essential requirements  

  Adequacy of product 
information regarding 
product misuse 

the EMC Directive and the 
essential requirements 
  % of users not satisfied with 
sufficiency of product 
information 

(OPC) 

  Market surveillance 
authorities (“MSA”) 
  Database of complaints 

(perception-based survey) 
Interview feedback 

 

Interviews and survey 
with Market 
Surveillance Authorities  

  Qualitative assessment, lack of EU-27 

wide data  

5.  How effective are the MS 

  Effectiveness of MS 

  Number / % of non-compliant 

 

authorities at 
identifying/adopting 
restrictive measures for 
non-compliant electrical 
equipment and electrical 
products? How does this 
affect the EMCD? 

authorities in identifying 
and adopting measures to 
deal with non-compliant 
products 

  Effectiveness of 

information exchange 
among market surveillance 
authorities and subsequent 
action 

  Extent to which MSA 

measures for non-compliant 
online products are 
sufficient 

  Whether MS authorities 
could learn from key 
international trading 
partners 

equipment recalled from the 
market per Member State, per 
EU/non-EU product, and in 
comparison to (major) trading 
partners 

  Number / % of objections raised 

regarding non-compliant 
equipment per Member State 

  Ratio of number of annual 
product recalls to national 
market size for main EMC 
products by value  

  Similar measures for key trading 

partners 

  Number of inspections carried 
out by MSA of the Member 
States as reported in the national 
reports  

  Ratio of number of inspections to 
national market size for main 
EMC products by value 

63 Information and Communication System on Market Surveillance (ICSMS) 

84 

  Review of data on 

complaints made and 
national technical 
regulations commented 
on in ICSMS63  

  EMC ADCO 
  Member State national 

reports  

  Commercial Data 

Sources e.g. CSIL / 
MarketResearch.com  

 
 
 
 
 
 
                                                      
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

 

 

 

 

The time necessary to take 
product off the market in 
MS/ across the EU 

The timeframe from 
placing a product on the 
market to assessment of 
non-compliance; 

Frequency of controls, per 
Member State  
Frequency of controls 
disaggregated across the 
main EMC product groups 
selected (up to 15) 

  Average time to take a product 

  Survey of Market 

  Not possible to obtain data 

off the market 

Surveillance Authorities 

  Average time for all Member 
State authorities to jointly 
respond to product removal 
requests 

  Average time taken from the 

  Survey of Market 

  Not possible to obtain data 

initial placing on the market to 
assessment of its non-compliance  

Surveillance Authorities 

  Annual number of product 

  Survey of Market 

  Not possible to obtain data 

controls broken down by 
Member State  

  Annual number of product 

controls broken down by the 
main EMC product categories 

Surveillance Authorities 

  Methodology for how 

products are targeted for 
control (differences 
between Member States) 

  Benchmarking of Member States 
methods for targeting of products 
against best practice, considering 
assessments of the extent of risks 
(e.g. 1 to 5 score)  

 

Interviews of Market 
Surveillance Authorities 

  Document review 

  Qualitative assessment of Member State 

methods  

 

 

Percentage of controls that 
resulted in identification of 
non-compliance (by type of 
product and reason for 
non-compliance) 
Percentage of controls that 

  Proportion of controls by 

  Survey of Market 

Member State and by main EMC 
products falling into specified 
non-compliance types and 
removals from the market  

Surveillance Authorities 

  Descriptive statistics analysis 
  Analysis of data on levels of non-

compliance produced by EMC ADCO 
reports on particular product types 

85 

 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

resulted in taking products 
off the market broken 
down by: Member State, 
and across key EMC 
product categories 

 

Extent to which 
discrepancies and 
inconsistencies have 
emerged across different 
MS, by type of product 
  Extent of gold-plating 

6.  Are there any 

discrepancies in MS 
interpretation of the 
EMCD’s requirements? 

  Number of discrepancies by area 
  Type of inconsistencies in legal 

 

transposition 

  Number of discrepancies by 
product group for main EMC 
products 

  Number of discrepancies by 

Member State 

  Number of infringement 

proceedings 

Interviews (DG GROW 
responsible for 
monitoring the national 
transposition and 
infringement deficit, 
national authorities)  

  Qualitative assessment of how far there 

are discrepancies in MS interpretation 
of the EMCD’s requirements 

7.  To what extent has the 

  Role of the EMCD in 

  Number and type of technologies 

  Stakeholder 

EMCD requirements had 
an impact on 
technological 
progress/innovation? 

stimulating technological 
progress/innovation (e.g. 
integrating EMCD 
requirements at low cost, 
investing in R&D&I into 
alternatives, manufacturers 
removing non-compliant 
equipment from the market) 
Innovative technologies 
that are/could be affected 
by the effective (or 
conversely non-effective) 
implementation of the 

 

affected 

  Number and type of obstacles 

identified affecting technological 
progress and innovation broken 
down by severity (1 to 5) 
  Main types of innovation 

stimulated  

  % of electrical equipment and 

 

consultations  
Interviews (all 
stakeholders, but 
especially with ESOs, 
national authorities and 
notified bodies) 
  Surveys (stakeholder 
targets as above). 

apparatus that incorporates radio 
functionality whereby EMC 
RED requirements applicable 
rather than the EMCD essential 
requirements 

86 

  Quantitative assessment of 
technological progress  

  Content analysis based on survey and 

interview data 

  Qualitative assessment of technological 
progress and its implications for EMCD 
vs. RED applicability 

 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

  Survey and interviews 

  Cost-benefit assessment (CBA) 

with economic 
operators and industry 
associations 
  Survey of Market 

Surveillance Authorities 

EMCD 

Efficiency: Were the effects achieved at a reasonable cost? 

8.  What are the regulatory 

costs and benefits for the 
different 
stakeholders/actors? 

  Regulatory costs and 
benefits for economic 
operators 
  Regulatory and 

administrative costs and 
benefits for notified bodies 
and market surveillance 
authorities  

  Actions required for 

inspections and their costs 
for national authorities and 
economic operators 
  Costs to follow/participate 
in the standardisation 
process 

  Main benefits for 

consumers, civil society 
and other stakeholders 

  Benefits Costs Ratio and Net 
Present Value for economic 
operators  

  Benefits Costs Ratio and Net 

Present Value for all 
stakeholders  

  Estimation of reputational 

benefit for economic operators to 
have CE marking in worldwide 
markets 

  Estimated benefit of the 

harmonisation in case of national 
divergent regulations for the 
same product 

  Number and cost of eliminated 
inspections (as conducted in 
other MS) 

  Benefits for MSA regarding 
labelling requirements 
  Average time and cost for 

manufacturers to ensure 
conformity of equipment 

9.  To what extent do 
discrepancies in 
interpretation create extra 
burden for MS? 

  Extent to which 

  Number of discrepancies by type 

  Survey and interviews 

discrepancies and 
inconsistencies in 
transposition and 
interpretation of legislation 

and Member State 
  Average associated costs 
  Main influence on market 

behaviour 

with economic 
operators and industry 
associations 
  Survey of Market 

  CBA 
  Analysis based on survey and interview 

data 

87 

 
 
 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

10.  How affordable were the 
costs borne by the 
different stakeholders? 
Proportion of admin and 
reporting costs? Benefits 
achieved at reasonable 
cost? 

influence compliance costs. 

  How discrepancies 

influence market behaviour 
(e.g. decision of economic 
operators to enter the 
European market via 
certain MS). 

Costs of self-certification as 
a % of product costs (for 
main EMC products, per 
Member State, and by 
enterprise size threshold 
(SMEs and large) 

Level of certification costs 
with the involvement of a 
notified body as a % of 
product costs (for main 
EMC products, per 
Member State, and by 
enterprise size threshold 
(large firms, SMEs) 

Level of costs for economic 
operators to engage with 
authorities during 
inspections (in terms of 
time, persons involved, in 

 

 

 

Surveillance Authorities 

Interviews / Surveys 

 
  Literature Review 

  Cost-benefit analysis (CBA)  

  Consultation / 

  CBA  

Interviews / Survey 

  Literature Review 

  Average cost of compliance as 
percentage of product turnover 
broken down by company size 
and Member State  

  Quantitative benchmarking of 

cost of compliance against other 
similar regulations to determine 
relative affordability  

  Average cost of compliance as 
percentage of product turnover 
broken down by company size 
and Member State  

  Quantitative benchmarking of 

cost of compliance against other 
similar regulations to determine 
relative affordability 

  Average annual cost for 

  Consultation / 

  CBA  

economic operators to engage 
with authorities considering the 
cost incurred and the proportion 
of the product value, 

Interviews / Survey 

88 

 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

absolute value and as % of 
turnover - for main EMC 
products, per Member 
State and by enterprise size 
threshold (large firms, 
SMEs) 

considering:  

  Overall cost to the main EMC 

products selected;  

  Overall cost to the population of 
firms that are inspected only; 

  Average costs to the firms that 

are inspected.  

 

 

 

 

 

Likelihood of economic 
operators to be inspected 
(qualitative)  

  Estimated % of EO that are 
inspected to check EMCD 
compliance. 

  Consultation / 
Interviews  

Extent to which inspection 
is restricted to one 
product/one family of 
products, or whether all 
products are inspected. 

 

Inspection practice approach 
using categorical variables e.g. a 
score of 1 equates to only one 
product covered and a score of 5 
equates to all products covered. 
Per Member State. 

 

Interviews with MS 
authorities  

  Data obtained from selected MSAs on 
number of EMCD compliance checks 
performed annually. 

  Qualitative analysis of efficacy of 

surveillance and enforcement regime 
  Quantitative analysis of surveillance 

and enforcement regime 

  Cumulative and annual costs, per 

  Consultation / 

  Cost-benefit analysis  

main EMC product, per 
stakeholder and per MS 

Interviews / Survey 

  Commercial Data 

Sources e.g. CSIL / 
MarketResearch.com  

Trends in respect of the 
costs involved for 
economic operators in 
carrying out the necessary 
tests. 
Extent to which costs are 
borne by different actors in 
the value chain 

Impact of the lack of 
harmonised standards for 
small actors like SMEs. 

  Level of competition 
  Change in market size 
  Changes in imports and exports 

  Commercial Data 

  Qualitative analysis 

Sources e.g. CSIL / 
MarketResearch.com 

  COMEXT 

89 

 
 
 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

Relevance: Do the objectives correspond to the current needs? 

11.  To what extent do the 

objectives correspond to 
the current needs? 

 

 

Extent to which identified 
needs and objectives are 
aligned. 
Extent to which the scope 
of the EMCD is considered 
appropriate 

  Whether provisions are 
needed to ensure the 
product remains compliant 
during its lifetime. 

  Whether conformity 

assessment and safeguard 
clause procedures (article 
39) efficient. 

  Adequacy of EMCD 

 

definitions 
Examples of good and bad 
application of the Directive 

  Degree of alignment between the 
EMCD’s objectives, the essential 
requirements and identified 
needs 

 

 

Interviews with MS 
authorities and MSA 
Interviews with 
manufacturers 
  Literature review 

  Qualitative  analysis based on interview 

feedback and survey data 

  Contextual multi-stakeholder analysis of 

the relevance of the EMCD 

 

1 to 5 Likert scale measure of the 
efficiency of procedures  

  Differences in national 
legislation/regulations 
transposing EMCD regarding 
product disturbance/immunity 
  Annual frequency of the number 
of complaints received by 
authorities broken down by MS 
and type 

  Survey and interviews 

with MS authorities and 
MSA 

  Literature review 

  Document review 
  Consultation / 

Interviews / Survey 
  Market Surveillance / 
Consumer / Other 
Authorities 

  Descriptive statistics analysis  
  Content analysis based on interview 

data 

  Contextual multi-stakeholder analysis of 
perceptions of good and bad application 
of the Directive 

  Whether certain concepts 

and exclusions of the EMCD 
require clarification or 
updating e.g. benign 

  Differences in national 
legislation/regulations 
transposing EMCD regarding 
product disturbance/immunity 

  Document review 
  Consultation / 

Interviews / Survey 

  Contextual multi-stakeholder analysis 

regarding exclusions  

90 

 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

equipment or fixed 
installations 

  Whether the EMCD scope 
and tracking is relevant to 
today’s business markets 
e.g. e-commerce and sales 
techniques 

 

 

 

Extent to which economic 
operators’ responsibilities 
and obligations as 
contained in the EMCD be 
changed 

Extent to which technical 
standards are able to keep 
pace with technological 
innovation sufficiently 
quickly. 
Fitness for purpose of EMC 
WP and EMC Committee 
and EMC ADCO in dealing 
with how legislation and 
technical standards 
respond to technological 
innovation and progress 

  Rating scale of 1-5 (e.g. 1 = not 

relevant; 5 = extremely relevant)  

  Document review 
  Consultation / 

Interviews / Survey 

  Contextual multi-stakeholder analysis of 

relevance of EMCD scope to e-
commerce 

ICSMS 

  Survey of stakeholders 
 
  Market Surveillance / 
Consumer / Other 
Authorities 

  Content analysis based on survey and 

interview data 

Interviews  

 
  Survey 

  Qualitative analysis based on survey 

and interview data 

  Trends in complaints filed for 

non-compliant products by type 
of non-compliance, per Member 
State 

  Clarity of obligations and 

responsibilities for economic 
operators 

  Number and type of 

technological developments 
affecting EMCD 

  Main effects of emerging 

technical developments (IoT, 
wireless power transmission, 5G, 
etc) 

  Degree to which essential 

requirements 
(immunity/disturbance) are 
adjusted to new technologies 

12.  To what extent is the 
EMCD suited to 
technological innovation?  

Note: the EMCD impact 
on tech innovation is also 
covered under the 
effectiveness criterion. 

Coherence: Are there any issues of coherence with other interventions and wider EU policy or legislation? 

91 

 
 
 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

13.  To what extent are there 

 

issues of coherence within 
the EMCD or with other 
legislation with similar 
objectives? 

Extent of clarity to 
manufacturers and 
authorities which kind of 
requirements they need to 
follow 

  Extent to which there are 

 

1 to 5 Likert scale measure of 
clarity of requirements  

  Additional expenditure related to 
coherence/borderline issues 

  Document review of 
relevant legislation  
Interviews  

 
  Survey 

  Cost-benefit analysis  
  Qualitative analysis based on survey 

data and interview feedback  

  Contextual multi-stakeholder analysis of 

perceptions 

 

 

additional administrative or 
financial costs due to an 
unclear borderline between 
legislation 
Impact (in terms of 
administrative or financial 
costs) to economic 
operators within EMC due 
to the fact that more and 
more equipment includes 
radio functionality, and 
therefore the essential 
requirements relating to 
electromagnetic 
compatibility are covered 
by the RED. 

Extent to which similar 
additional requirements 
from other legislation than 
the ones already defined 
by the EMC (both EU and 
national level) with regard 
to certain products  

 

Identified number of similar 
additional requirements broken 
down by product types 1 to 5 
Likert scale measure of severity 
of conflicting requirements 

Interviews  

 
  Survey 

  Cost-benefit analysis  
  Cross tabulation 
  Content analysis based on survey and 

interview data 

92 

 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

 

Extent to which these 
conflict 

  Whether coherence with 

  Rating scale of coherence vs 

  Consultation / 

  Qualitative time series analysis 

other EU legislation has 
been maintained over time 

non-coherence 

Interviews / survey 

  Document review 

 

Extent of overlap with 
other EU legislation (e.g. 
Radio Equipment Directive 
2014/53/EU (RED), 
2018/1139) and impact on 
administrative burdens 
faced by economic 
operators. 
  Degree to which 
administrative 
simplification has avoided 
duplication of 
requirements (e.g. 
between the EMC and the 
RED)  

  Main products where there 

are discrepancies. 

  % of products that have to 
comply with the essential 
requirements relating to 
electromagnetic compatibility in 
the RED instead of the EMC, 
since they contain radio 
functionality 

  Comparison of evolution over 

time compared with 10 years ago 
  Additional expenditure related to 

additional legislation  

  Number of products removed 
from the market subject to 
product regulations requirements 
that have similar objectives / 
overlaps / complementarities  

EU added-value: What is the additional EU value added of the current EMC directive? 

93 

  Consultation / 

Interviews / survey 

  Cost-benefit analysis  
  Descriptive statistics analysis 

  Data from MSAs 

  Analysis based on feedback from MSAs 

 
 
 
 
 
Question 

Judgement criteria 

Indicators 

Sources of evidence 

Assessment methods 

14.  What is the additional 
value of EMCD for 
stakeholders, and 
compared to what could 
have been achieved at 
national level?  

 

Extent to which there are 
foreign companies that 
consciously decide to 
choose to use the EU 
regime for the certification 
of their products. 

  Assessment of the extent 
of European value added 
for manufacturers of 
following regulatory 
requirements at EU rather 
than national level. 
  Assessment of the extent 
of European value added 
for consumers. 

  Estimated costs saved by 

  Survey of economic 

  Qualitative assessment of EU value 

complying with a harmonised 
regime over several national 
regimes. 

  Estimated reputational benefits 
  Estimated savings for national 
authorities from common 
requirements and EU wide-
withdrawals of non-compliant 
products 

operators  

added  

  Quantitative assessment of estimated 

cost savings 

  Contextual analysis of the rationale for 
manufacturers selecting different 
conformity assessment modules 
(including Module A internal 
production control involving self-
certification). 

94