We get asked about if E-mark and e-mark testing or CE mark testing is required for automotive products often. The general question we get asked asked is “What standards are used for testing an aftermarket automotive product”. All after-market electronic products are termed ESAs which is a three letter abbreviation for ‘Electronic Sub Assembly’. Examples of an Electronic Sub Assembly “ESA” would include digital tachometers, digital gear shift, automotive racing electronics and electronics that are wired directly into the vehicles harness or CAN BUS. In addition consumer electronics such as cigarette lighter socket powered plugin electronic products. The applicability of directives, standards, testing and the required accreditation/certification depends upon the products intended normal place of operation and how it affects driver safety and other road users to some degree.
What is e-marking?
The e-mark is an EU mark for approved vehicles and vehicle components sold into the EU. It is a type approval mark given by a certifying authority such as in the United Kingdom (UK) by the Vehicle Certification Authority (VCA) other countries have different certifying bodies. You cannot self-declare and affix an e-mark, the certifying body will issue an e-marking certificate after inspection and approval of compliance. The directive for e-marking is the “Commission Directive 2004/104/EC, 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”. You cannot self-declare compliance to 2004/104/EC.
What is E-marking?
The E-mark is a United Nations mark for approved vehicles and vehicle components sold into the EU and some other countries under UN-ECE Regulation 10. Regulation 10 replaced the ‘Automotive Electromagnetic Compatibility Directive’ 2004/104/EC (AEMCD) in November 2014. Intended to promote free trade throughout the European Union and the wider EEA. Any original or aftermarket ESA or a part of the vehicle needs to be approved before it can be sold. The regulation contains a flow diagram to help determine if the ESA falls within its scope. Entirely passive devices such as spark plugs, cables and passive antennas are excluded. In addition equipment which only operates when the vehicle is immobilized i.e. stationary vehicle with the handbrake on, are also exempt. Typically products that do not connect to the vehicles wiring are generally excluded, along with items that connect via a standard already approved interface. Rechargeable Electric Energy Storage Systems’ (REESS) or more commonly known as charging systems intended to provide energy for electric propulsion of the vehicle are also within the scope of the regulation.
What is the e-Mark logo and what is the number after the logo
EU certification (referred to as EC), the e-Mark: e-Mark is based on EU Directive and is a safety certification mark which the European Commission require that member states apply it on motor vehicle, parts and systems. The e-Mark logo is a rectangular frame. The number is the EU country or state number that granted the approval. If one state grants approval then it is deemed sufficient for all other member states. The country/state codes are as follows: e1 – Germany, e2 – France, e3 – Italy, e4 – Netherlands, e5 – Sweden, e6 – Belgium, e7 – Hungary, e8 – Czech republic, e9 – Spain, e11 – United Kingdom, e12 – Austria, e13 – Luxembourg, e17 – Finland, e18 – Denmark, e19 – Romania, e20 – Poland, e21 – Portugal, e23 – Greece, e24 – Ireland, e26 – Slovenia, e27 – Slovakia, e29 – Estonia, e32 – Latvia, e34 – Bulgaria, e36 – Lithuania, e49 – South Cyprus, e50 – Malta.
What is the E-Mark logo and what is the number after the logo
Certification of Economic Commission for Europe (referred to as ECE, United Nations agency), the E-Mark: E-Mark is the regulations issued by the Economic Commission for Europe (referred to as ECE). E-Mark logo is a circular frame. The number is the EU country or state number that granted the approval. If one state grants approval then it is deemed sufficient for all other member states. The country/state codes are as follows: E1 – Germany, E2 – France, E3 – Italy, E4 – Netherlands, E5 – Sweden, E6 – Belgium, E7 – Hungary, E8 – Czech Republic, E9 – Spain, E10 – Yugoslavia, E11 – United Kingdom, E12 – Austria, E13 – Luxembourg, E14 – Switzerland, E16 – Norway, E17 – Finland, E18 – Denmark, E19 – Romania, E20 – Poland, E21 – Portugal, E22 – Russian Federation, E23 – Greece, E24 – Ireland, E25 – Croatia, E26 – Slovenia, E27 – Slovakia, E28 – Belarus, E29 – Estonia, E31 – Bosnia and Herzegovina, E32 – Latvia, E34 – Bulgaria, E37 – Turkey, E40 – Macedonia, E42 – European Community, E43 – Japan, E45 – Australia, E46 – Ukraine, E47 – South Africa.
Does my product need CE and e-marking/E-marking?
Only if the product falls within the scope of 2004/104/EC or Regulation 10 and also CE applicability. Products that can be used outside the vehicle require CE testing (unless exempt from CE EMC testing). The classic example of this situation would be that a mobile phone car charger and mobile phone. The mobile phone is not specifically intended to be used in a car, requiring CE testing under the RE Directive (RED) only, whilst the car kit is intended for normal use in a car and may require EN 50498 testing or even e-marking or E-marking if it can affect the drivers control of the vehicle or other road users, through the vehicles electrical systems.
If the product is already CE marked can we comply with 2004/104/EC or Regulation 10?
If the product is already CE marked (to the correct listed applicable directives such as the EMC, R&TTE or RE Directive) and the product is not safety related it may allow you to self-declare it for fitting in a vehicle. For e-marking please refer to clause 3.2.9 of 2004-104-EC. However you still cannot e-mark the product, this only done by a certifying body as mentioned previously. For E-marking please refer to Regulation 10 (version 10.5), section 3.29 this clause states “Components sold as aftermarket equipment and intended for the installation in motor vehicles need no type approval if they are not related to immunity related functions (see paragraph 2.12. of Regulation 10 (version 10.5).
What defines safety related in respect ESA’s?
Essentially the product cannot affect the drivers control of the vehicle or other road users, refer to paragraphs 6.5, 6.6, 6.8 and 6.9 of Annex I of 2004-104-EC or UN-ECE Regulation 10, section 2.12 (in version 10.5 of UN-ECE Regulation 10).
What if your product is safety related?
Additional immunity testing an also full e-marking or E-marking type approval if the ESA fitted to a vehicle can affect the driver’s control of the vehicle. Thus a self declaration based upon non safety related ESA does not apply. Types of affects that may cause the driver to have impaired control of the vehicle may include; ABS braking, brake lights, Headlights, indicators, visual or audio impairment such as loud alarm noises, flashing dash board lights or indicators etc.
Safety related product testing for e-marking
In order to get e-mark testing for safety related systems the testing MUST BE CERTIFIED. Firstly determine if E-mark and e-mark testing or CE mark testing is required. In order to proceed, you will need a Test Plan, this should be submitted to a certifying body such as the VCA etc. The test plan should include the worst case selection to try reduce the testing along with standard EMC Test plan information. After approval of the test plan then testing can be performed. Whichever laboratory you choose they will need to be either certified to perform the testing or have a certifying body representative such as a VCA authorized person witness the testing. If testing is performed at EMC Basywater this can usually be arranged by us or the testing laboratory.
What CE standards apply to automotive products that don’t fall under the scope of e-marking or E-marking?
If the product is not categorized as e-marking or E-marking then it may be applicable to apply EN 50498: 2010, Electromagnetic compatibility (EMC) — Product family standard for aftermarket electronic equipment in vehicles. In addition if the product contains any wireless communication devices then the Radio Equipment Directive (RED) may apply.
UN-ECE Regulation 10 – RCM compliance for Australia
As per the accepted mandated ACMA EMC standards list for Australia, UN ECE R10 – Uniform provisions concerning the approval of vehicles with regard to electromagnetic compatibility is now listed (Row 60). So this standard could be applied if justifiably applicable. As per may EMC standards, applicability is determined through primary function of the product and intended environment of use. For Australia, immunity testing and Harmonic and flicker testing is not required.
The Vehicle Certification Agency is a UK Government agency which enforces the Regulation and has a great website with lots of further information. For further information regarding automotive and OEM specific EMC Testing the please visit our ESA Automotive component EMC testing page.