Testing radiated emissions (RE) for the North American market is a problematic topic in the lighting industry. Right now, it’s possible to bypass RE testing and still sell LED lamps in North America – but that may soon change. Lighting manufacturers should consider pre-emptively testing their products – and they need to be aware of potential re-testing of inventoried merchandise that may be coming soon.
Similar Products, Different Standards: Leads To Confusion
In Industry Canada’s ICES-003, products can achieve EMC via several different compliance paths; but only one includes ANSI C63.4, the North American standard referenced in Section 6 of ICES-003. This route does not require RE measurements for devices that generate or use RF below 1.705MHz, which is typical of LED lighting. Choosing this compliance path means that some manufacturers do not perform RE testing on their LED devices.
However, there’s another compliance path defined in ICES-003 that requires the use of CAN/CSA CISPR 22—and that route does not offer the 1.705MHz exclusion. For manufacturers, that discontinuity has caused a lot of confusion. One route allows for LED lighting to skip RE tests, but another technically regulates that LED lighting should be tested. In addition, some labs are testing LED Lighting to a different ICES standard since the title and scope of ICES-003 would appear to exclude LED Lighting – and there’s no clear right or wrong answer.
Bypass The RE Test: How It’s Handled In The USA
In the United States, the FCC only requires radiated emissions testing on digital devices with an operating frequency greater than 1.705MHz. Since most LED lamps sit below that level, they only perform a Conducted Emissions (CE) test – manufacturers can legally bypass the RE test altogether. Because Canada’s standards are generally unclear, those products are handled the same way as those under FCC regulations.
Possible RE Test: Canada To Adopt International Standards?
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While it’s unclear how Canadian standards will change in the future, many expect them to align with international standards in part. The international standard CISPR15 includes a section devoted to LED lighting; there is no exemption for emissions tests, no matter the operating frequency. If Canada follows suit, adds LED Lighting to the scope of ICES-005, and remodels its ICES-005 regulations according to international standards, LED manufacturers may have to re-design their products to comply with radiated emissions requirements, even if they currently don’t have to.
Because of the likelihood that Canada will adopt standards similar to the international community and FCC will likely adopt the recommendations to require RE testing per draft KDB640677, it’s advisable for LED manufacturers who want to get ahead of the curve to consider RE testing as a preventative measure for the future. In all likelihood, it will soon become regulation – and when that day comes, manufacturers who want uninterrupted distribution to North America will be glad they prepared.