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the Science in Low Frequency Emissions Regulation?
of Arts Project
Professor Keith Bovetti
paper was researched and written to fulfill the M.A. project requirement for
completing the Monterey Institute of International Studies’ Master of Arts in
Commercial Diplomacy. It was not commissioned by any government or other
organization. The views and analysis presented are those of the student alone.
purposes of this project, I assume the fictitious role of a consultant who has
been hired by a group of information technology companies to 1) analyze the
problems associated with the European Union’s soon to be implemented harmonic
emissions standard (EN 61000-3-2); and 2) develop a strategy for delaying
implementation of the standard. As part of this work, I propose the development
of a fictitious coalition, the Coalition on Harmonic Emission Issues (CHEI).
express my deepest gratitude to the following people for assisting me as I
developed, researched and wrote this project:
S. Bermange, Xerox
but not least, I thank Timothy Bennett and Jennifer Guhl of the American
Electronics Association for introducing me to this topic
Table of Contents
On January 1, 2001, the European Union will begin
requiring all electronic/electrical equipment sold in the EU market to conform
to its low frequency emissions standard, European Norm (EN) 61000-3-2. The
standard will cost the electronic/electrical industries billions of dollars, yet
there is no scientific evidence that the standard is necessary.
purpose of EN 61000-3-2 is to limit the harmonic or low frequency emissions (LFE)
of electronic/electrical products and to ensure that these products are
acceptably immune to such emissions—emissions that can, at least in theory,
create disruptive noise on the power lines.
All electronic/electrical products are covered by the standard (e.g.
computers, audio and video equipment, light dimmers, fluorescent lights, air
conditioners, refrigerators, etc.).
total, the low frequency EN standard is expected to cost worldwide
electronic/electrical equipment manufacturers $50 billion by 2001—an increase
in production costs of 2.5 to 1,000 percent. The information technology (IT)
industry alone will pay an estimated $3.4-$5.6 billion annually by 2001 to
conform to the standard. Consumer prices for electronic/electrical equipment are
expected to rise three to five percent as a result of the standard.
costs are unjustified because there is no scientific evidence that demonstrates
the need for a standard that covers all electronic products. Indeed,
there is no data or record of complaint from European or American utilities to
show that harmonic signals have in fact been disruptive. The costs of EN
61000-3-2 are yet less justifiable because the International Electrotechnical
Commission (IEC) recently decided to rewrite the IEC standard on which EN
61000-3-2 is based, and the European Committee for Electrotechnical
Standardization (CENELEC) is currently reviewing, and potentially revising, the
standard itself. It simply does not make sense to require manufacturers to come
into conformity with EN 61000-3-2 by January 1, 2001 if the standard is likely
to be changed soon thereafter.
scientific justification, EN 61000-3-2 violates Article 2.2 of the World Trade
Organization Agreement on Technical Barriers to Trade. Moreover, it will have a
strong negative impact on manufacturers:
The IT industry must:
detailed strategy for achieving these recommendations is laid out in the final
section of this paper.
As international agreements chisel away at tariff
barriers to trade in information technology (IT) products, significant,
potentially devastating, non-tariff barriers are emerging. The most important of
these emerging barriers are standards-related barriers, which are proving to be
very costly for producers of computer hardware, software, and telecommunications
Indeed, intense competition has already shortened the economic life cycles of
high-tech products and left companies with little time to recover research and
development (R&D) costs. Requiring companies to spend extra time and money
ensuring that products conform to technical regulations only exacerbates this
The impact of technical, standards barriers is
particularly detrimental to the competitiveness of industries within the United
States and European Union, which share the largest two-way trade and investment
relationship in the world.
Approximately 22 percent of all U.S. goods and services exports (approximately
$110 billion in merchandise) go to the European Union (EU) every year,
and a full fifty percent ($66 billion) of these exports require some form of EU
certification in addition to any U.S. domestic certification requirements.
The heterogeneous standards and duplicative regulatory requirements on both
sides of the Atlantic increase the base cost of exports by up to 15 percent.
Since the early 1990s, the European Union
has attempted to impose EMC standards on electronic/electrical products
sold in the Union. One of these standards, and the focus of this project,
is European Norm (EN) 61000-3-2.
EN 61000-3-2 is designed to limit the low frequency emissions
of electronic/electrical products and to ensure that these products
are acceptably immune to such emissions.
The IT industry must be fully compliant with this standard if
it wishes to sell its products on the EU market after January 1, 2001,
the implementation date for the standard.
The product limitations created by EN 61000-3-2 will
impose great costs and severe product-design restrictions on manufacturers,
which in turn will increase costs for consumers. The electronic/electrical
industry estimates that the low frequency emissions standard (EN 61000-3-2) will
increase worldwide manufacturers’ costs by an estimated $50 billion
annually—a little less than half of which would be borne by U.S. manufacturers
(see Commercial Analysis for greater
Yet there is no scientific evidence to show that the standard is necessary. In theory, harmonic emissions can reduce the quality of publicly distributed electric power. However, strong scientific data suggests that harmonic distortion caused by electrical products has not had a significant impact on EU power supply systems. Accordingly, EN 61000-3-2 will create a significant, and unnecessary, trade barrier.
The following project begins with an in-depth history of
the problem and then analyzes the issue from five perspectives: commercial,
economic, legal, policy, and stakeholder. (The macroeconomic analysis is
included in Appendix A illustrates the importance of the high-tech sector to the
overall U.S. economy—although the macroeconomic impacts of EN 61000-3-2 are
expected to be negligible.) The final sections provide recommendations and an
The final outcome of this project should be a clear presentation of the issue, a solid groundwork of facts in support of the U.S. industry position, and the development of a strong U.S. plan for action. The project’s ultimate goal is to provide a means of working towards a satisfactory solution to the harmonic emissions problem before it escalates into a trade war or WTO dispute settlement. By addressing the problem early, the U.S. and EU may be able to avoid a debacle like the banana and beef hormone trade disputes.
compatibility (EMC) has been a concern ever since the first volt of electricity
lit a light bulb. However today’s rapid proliferation of sensitive electronic
devices has greatly increased the possibility of electromagnetic feedback
problems, which in extreme cases might cause overheating, shortened equipment
lifetimes, or catastrophic failure of equipment connected to the power lines.
As a result, nations have created various standards to control harmonic
defined by the U.S. Department of Commerce, electromagnetic compatibility is:
. . the condition which prevails when telecommunications equipment is performing
its individually designed function in a common electromagnetic environment
without causing or suffering unacceptable degradation due to unintentional
electromagnetic interference (EMI) to or from other equipment in the same
environment. It is also the ability
of systems, equipment, and devices that utilize the electromagnetic spectrum to
operate in their intended operational environments without suffering
unacceptable degradation or causing unintentional degradation because of
electromagnetic radiation or response.
modern electronically controlled equipment creates harmonic signals that are fed
back into the power lines to which they are connected. These signals, also
called low frequency emissions (LFE), can appear as noise on the power lines and
may be problematic when utilities begin using their lines for purposes other
than power distribution (i.e. sending voice, video, or data). LFE or “noise”
may limit such capabilities.
Europeans adopted EN 61000-3-2 in an attempt to regulate the amount of harmonic
signals that feed back into power lines—although a survey conducted by the
Information Technology Industrial Council and IBM shows that U.S. and European
utilities have little problem with these signals.
Overview of U.S. and EU EMC Regulations
nations have developed standards and regulations to protect
electronic/electrical products and utilities from electromagnetic distortions
and to prevent those products from creating such interference.
the United States, the Federal Communications Commission requires
electromagnetic (EM) compliance to the following two international standards:
International Electrotechnical Commission (IEC) 950 and International Special
Committee on Radio Interference (CISPR) 22.
Most U.S. efforts to regulate electronics are sponsored by the Institute
of Electrical and Electronics Engineers, Inc. (IEEE) and the American National
Standards Institute (ANSI). Regulations generally focus on “…installations
and facilities, large point source loads, and, more recently, on smaller loads
with large aggregate impact on the network.” (For a greater
explanation of U.S. standards development policy, see Policy
the EU, the development of electromagnetic compatibility (EMC) regulations is
guided by the Council Directive 89/336, the “EMC Directive.” The majority of
the European Union’s EMC standards are adopted wholesale from the IEC. The EU
began regulating low frequency emissions (LFE) with the standard IEC 555-2,
which covered only household appliances. In
1995, the EU replaced IEC 555-2 with IEC/EN 61000-3-2, which expanded coverage
to include all electronic/electrical equipment. (See Standards
Setting in the U.S. & E.U. for more information on the European
Union’s standard setting process.)
EMC Directive 89/336
EMC Directive was adopted by the European Council of Ministers on May 3, 1989. A
“new approach” directive, it laid down apparatus protection requirements and
left it to standards, primarily European harmonized standards, to define
technical specifications for achieving those protection requirements.
On July 1, 1991, the EMC Directive became national law, thereby replacing
all national EMC standards. Its provisions have been in effect since January 1,
EMC Directive is designed to guarantee the free movement of “apparatus”
and to create an acceptable electromagnetic environment in the EEA territory.
Its specific goals are:
the EMC Directive seeks to ensure that EM phenomena do not affect how
appliances, installations, and systems function. If an apparatus, when used as
intended, does not degrade the performance of other apparatus in its EM
environment, both present and foreseeable, it should be considered to be in
compliance with the emission requirement of the directive.
EMC Directive has been amended by the following directives:
second of these, Council Directive 92/31/EEC, gave manufacturers three and a
half years (until December 31, 1995) to implement the EMC Directive. During this
transitional period, manufacturers had the choice of placing on the market
and/or putting into service:
of January 1, 1996, all member states should have abolished national regulations
concerning electromagnetic compatibility and applied the provisions of the EMC
Directive for all apparatus. Also,
as mandated by Directive 92/32/EEC, many of the harmonized standards derived
from the EMC Directive should have taken full effect. One exception to this is
The History of IEC 61000-3-2
1973, the International Eletctrotechnical Commission (IEC) established Technical
Committee (TC) 77 to begin the process of defining harmonic emissions standards.
 The committee was to consider the following
aspects of EMC:
1981, TC77 established sub-committee (SC) 77A,
to focus on standardization in the field of EMC with regard to low frequency
phenomena (ca. <=9kHtz). SC77A/WG1 published its first harmonic emissions
standards in 1982. These were IEC
725, which set references for impedance levels, and IEC 555-2 (first addition),
which covered equipment for household and similar usage. In 1985, SC77A/WG1
amended 555-2 to add special limits for television receivers. This was a
precursor to Class D
limits for all electronic equipment and the beginning of standards that address
1986, the IEC SC77A began writing a standard that expanded IEC 555-2 by limiting
allowable harmonic feedback currents for all
products that connect to the electric utility power lines. Published in 1990,
this new standard (61000-2-2) set the compatibility levels for public
distribution systems. At that time, the information technology industry had
little interest and no representation in committee SC77A, and therefore minimal
input in the development of IEC 61000-2-2.
61000-3-2 further expanded the IEC’s harmonic feedback standard to include all
electronic/electrical equipment. This standard was published in 1995, but the
IEC recently decided to rewrite it. Best estimates are that it will take the IEC
three to five years to rewrite the standard.
EN 61000-3-2 and the
Role of the European Committee for Electrotechnical Standardization
official European standards-setting body for electrotechnical products is the
European Committee for Electrotechnical Standardization (CENELEC). This
standards body works closely with the IEC. In fact, CENELEC often adopts
standards directly from the IEC. Within the regulatory framework of the EMC
Directive, CENELEC and the European Commission turn many of the IEC low
frequency emission standards into European Norms, such as IEC/EN 61000-3-2, IEC/EN
61000-3-3, and IEC/EN 61000‑4‑7.
published EN 61000-3-2 in 1995,
thereby turning the voluntary IEC standard into a mandatory European Union
standard. However the standard was amended in 1998 to allow for a delay in its
implementation. EN 61000-3-2 is now scheduled to take full effect on January 1,
2001—this despite that the IEC is rewriting its counterpart standard and that
CENELEC recently decided to review the European standard.
Review of the EMC Directive
to the numerous concerns raised by the EMC Directive, the European Commission
sent the EMC Directive to be reviewed by the Simpler Legislation for the Single
Market Initiative (SLIM) team. The result was a number of recommendations that
have received strong support from many companies and trade associations within
the IT industry. However, the SLIM report did essentially nothing to change the
low frequency emissions standard EN 61000-3-2.
SLIM team did recommend that “EMC legislation should not result in added costs
for consumers due to unique requirements where this cannot be appropriately
justified as being essential for the European Market only.”
But the European Commission still has not decided how to implement this
recommendation in the context of the forthcoming revision of the directive and
harmonized standards. There is only limited indication that the EU might change
the harmonized standard (EN 61000-3-2).
U.S./EU Mutual Recognition Agreement
U.S. and the EU recently negotiated mutual recognition agreements (MRAs) on
conformity assessment. These
agreements took effect on December 1, 1998 and cover recreational craft,
telecommunications equipment, and products that must be inspected for
electromagnetic compatibility. They included a two-year phase-in period for IT
products to allow time for mutual acceptance of U.S. and EU test data.
After the two-year phase-in, each country will recognize the certifications of
designated laboratories, inspection bodies, and conformity-assessment bodies
within the other country.
result of these MRAs is a reduction in the cost of such assessments and the time
needed to bring new products to market. However,
the Mutual Recognition Agreement for products that must be inspected for EMC
does nothing to resolve the conflict over the regulations themselves.
U.S. Lobby Efforts
to EN 61000-3-2
huge costs for complying with the EMC Directive’s harmonic standards,
U.S. trade associations and companies have actively lobbied against
these standards for years. The largest amount of work was done prior to
the second implementation deadline of February 1998, however the IT
industry continues to actively monitor the activities of the EU
legislature and continues to pressure the European Commission and
standards-setting bodies through letter writing, etc.
The IT industry’s ultimate goal is to persuade IEC/SC77A to
rewrite IEC 61000-3-2, and to get the Europeans to follow suit.
the EU adopted EN 61000-3-2 as a precautionary standard to protect against
the potential threat of harmonic feedback, EN 61000-3-2 actually creates
a technical barrier to trade. If this barrier is not addressed now, before
it takes effect, it will likely be addressed before a World Trade Organization
(WTO) dispute settlement panel.
 Office of Industries, U.S. International Trade Commission, Global Assessment of Standards Bariers to Trade in the Information Technology Industry, November 1998, p. iii.
 TABD, Mid Year Report, May 10, 1999, p. 4.
 USITC, Global Assessment, p. iii; USTR, European Report 1998 www.ustr.gov.
 Paula Stern, “The Transatlantic Business Dialogue: A New Model for Trade Expansion and Regulatory Harmonization,” 1999.
 James McKim, “An Examination of the Rationale for Limiting Harmonic Emissions from Low-Voltage Equipment,” 1999.
 Harmonics are signals that are multiples of a base frequency or vibration.
 Department of Commerce: http://glossary.its.bldrdoc.gov/fs-1037/dir-013/_1932.htm.
 IEC 555-2 is the predecessor to IEC/EN 61000-3-2. It was used for many years and enforced as a mandatory requirement in Europe. The standard covers domestic appliances, includes a simpler measurement system than IEC/EN 61000-3-2, and applies to ITE, TV and other electronic equipment marketed to use in the home. According to a fact sheet presented by Girtz Zeidenbers of IBM at the June 17, 1999 LFEIC meeting, it has not been shown that the accumulation of small equipment has caused increasing harmonic distortion prior to and while IEC 555-2 has been in effect in Europe.
 European Union, Council of Ministers, Guidelines on the Application of Council Directive 89/336/EEC of 3 May 1989 on the Approximation of the Laws of the Member States Relating to Electromagnetic Compatibility, Brussels, 1997.
 As defined in Article 1.1 of 89/336/EEC: all electrical and electronic appliances together with equipment and installations containing electrical and/or electronic components.
 Article 1.2 of 89/336/EEC defines electromagnetic disturbances as any EM phenomenon that may degrade the performance of apparatus. An EM disturbance may be an EM noise, an unwanted signal, etc.
 The International Eletctrotechnical Commission was founded in 1906. Today, it prepares and publishes international standards for all electrical, electronic, and related technologies. Over 50 countries, including the world’s major trading nations and a growing number of industrializing nations, are participating members of the IEC.
 Working groups within TC77 are WG 1—Terminology; WG 13—Generic EMC standards; WG 14—EMC and functional safety; and WG 15—Measurement methods for EMC phenomena.
 This standard is intended to establish uniform requirements for the radio disturbance level of the equipment contained in the scope, to fix limits of disturbance, to describe methods of measurement, and to standardize operating conditions and interpretation of results.
 Working groups included in SC77A are WG1—Harmonics and other low frequency disturbances; WG2—Voltage fluctuation and other low frequency disturbances; WG 6—Low frequency immunity tests; WG8—Electromagnetic interference related to the network frequency; and WG9—Power quality measurements methods.
 Class D products are those that currently consume between 75W and 600W and have harmonically rich current waveforms of the type typically produced by rectifier circuits. James McKim, James, “How to Read and Use EMC Standards,” Test and Measurement World, August 1998.
 The full title of the EN 61000-3-2 is “Electromagnetic compatibility (EMC) – Part 3.2: Limits for harmonic current emissions (equipment input current up to and including 16 A per phase).”
 SLIM Report
 USITC, Global Assessment, p. 2-23.