Keith's 77th Blog: No tests are required for CE-marking to the EMCD

Keith's 77th Blog: No tests are required for CE-marking to the EMCD image #1

11 Jan 2024

by Keith Armstrong

Relevant for…

  • Manufacturers
  • Authorised Representatives
  • Importers
  • Distributors

I couldn’t believe my eyes when I saw a recent article falsely claiming that EMC testing to EU Harmonised Standards was mandatory for compliance with the European Union’s (EU's) EMC Directive 2014/30/EU (EMCD).

Passing tests to harmonised standards has always been entirely voluntary for compliance with the EMCD since its first edition, 89/336/EEC, in 1989. Just like it always has been for the LVD, and still is even when the product falls under the RED (2014/53/EU)

I’ve selected the most important statements on this from official EMC documents and copied them in my blog:

Yes, passing tests to all relevant EMC Harmonised Standards achieves a ‘presumption of conformity’ with the EMCD, but:

  • It is only a presumption for the purpose of CE marking for crossing national boundaries within the EU;
  • CE-marked products with a genuine ‘presumption of conformity’ that are found to be non-compliant with the EMCD’s Essential Requirements when used in real life, may be banned from the entire EU, with some Member States also insisting on mandatory recalls;
  • The EMCD allows a wide variety of other ways to legally affix the CE marking to products that have not (or only partially) been lab-tested, for example:

– because they are too large;
– because they are only assembled at their end-user’s premises;
– to reduce financial costs and risks (helpful to start-ups),
– and any other reasons.

However, EMC verification testing is very important during product design and development, and also for quality control in manufacturing. To help improve both time-to-market and international competitiveness, EMC verification testing should be quick and low-cost.

To discover what is best for you and your products, meet the EMC compliance and testing experts at EMC+CI 2024 at Newbury Racecourse on May 23-24 2024,

Editor’s note:

To keep up to date with press material, opinion-focused blogs, and case studies from EMC & Compliance International 2024, visit  

About EMC and Compliance International 2024:

This public event is a collaboration of industry experts Keith Armstrong of Cherry Clough Consultants Ltd,  and Dr Min Zhang of Mach One Design; the owners of EMgineering Ltd and  

It is a re-branding and re-launching of the very successful EMC-UK annual events held at Newbury Racecourse for many years pre-Covid. aims to be the definitive global web portal for information on EMC and other technical compliance issues, to encourage the design and development of better, more profitable electronic products, equipment, and systems, by the use of very practical methods that are well-understood and well-proven in real life.

For further information:

Yinan Yang
EMC Standards
30 Dunnock Close
Bicester, OX26 6WZ, UK
Phone: +44 (0)7562 183 109

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