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The New EU Automotive EMC Directive 2004/104/EC

The New EU Automotive EMC Directive 2004/104/EC

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This is the area that OEM suppliers’ products and aftermarket automotive systems have to comply with to be sold as suitable for vehicle fit within Europe. Components and sub-systems are still referred to under the generic description Electronic Sub-Assembly ESA.

An area where suppliers in certain EU markets should gain more access is the restriction to interpretation of the directive. For example the German market currently interprets 95/54/EC to prevent any aftermarket electrical product fit with or without e-marking without the vehicle manufacturers written confirmation that the product does not invalidate the vehicle type approval. This is effectively a restriction of trade for non-OEM approved products. The new directive does not allow manufacturers to restrict aftermarket products, with the exception of a general statement for radio equipment.


Products that are not permanently wired to the vehicle harness and can be removed without specialist tools, or are technically restricted to operation while the vehicle is stationary, will no longer have to prove compliance to the Automotive EMC directive once 2004/104/EC comes into effect. Such products can be CE marked if necessary and obtain a Declaration of Conformity via the generic EMC directive 89/336/EEC processes, this includes self-certification and technical construction file TCF routes to compliance. The same situation is applicable for R&TTE products e.g., mobile telephony and radio equipment where meeting the R&TTE directive is determined as adequate for vehicle fit given the above provisos.

This change to the automotive EMC directive provides a method for some suppliers to reduce their testing by self certifying products CE marking based on "use of known good circuits" and TCF. However, there may be a commercial imperative to retain "e"-marking on some products to maintain credibility in the automotive marketplace. There could also still be the dictated requirement from aftermarket product retailers, forcing "e"-mark testing on the product by otherwise threatening to remove from their sales portfolio. It is highly unlikely that automotive OEMs will approve products for fit to their vehicles e.g., at franchised dealerships, even as aftermarket items, if "e"-mark certification is not obtained as a minimum.

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