The Modular Approach

Last edit: 10/10/2023

THE DOUBT: in order to CE mark my distribution panel, shall I do EMC tests?


Consideration 1: In the 2012 edition of IEC 61439-1 there was this language contained in the Normative Annex J:

[IEC 61439-1: 2012] Annex J(normative) – Electromagnetic compatibility (EMC)

J.9.4.2 Requirement for testing

ASSEMBLIES are in most cases manufactured or assembled on a one-off basis, incorporating a more or less random-combination of devices and components.

No EMC immunity or emission tests are required on final ASSEMBLIES if the following conditions are fulfilled:

           9. the incorporated devices and components are in compliance with the requirements for EMC for the stated environment (see J.9.4.1) as required by the relevant product or generic EMC standard.

          10. the internal installation and wiring is carried out in accordance with the devices and components manufacturer’s instructions (arrangement with regard to mutual influences, cable, screening, earthing etc.)

In all other cases the EMC requirements are to be verified by tests as per J.10.12.

In essence, for Distribution Panels, no testing is required in case all components are CE marked, in compliance with the EMC directive and they are installed according to the Manufacturer’s instructions.

This approach is called the Modular Approach and is also found in the 2020 edition of IEC 61439-1.


Consideration 2: Since 2018, any technical standard that is required to be harmonised has to be approved by a so called HAS (Harmonised Standard) Consultant.

The HAS Consultants assist the European Commission in the implementation of Article 10(5) of Regulation (EU) No 1025/2012 on European standardisation. The HAS consultants has to assess conformity of harmonised standards with the standardisation requests and with the corresponding Union harmonisation legislation to allow the Commission services to verify and assess whether the conditions for publication of the references for such harmonised standards in the Official Journal of the European Union are appropriately fulfilled, in line with Article 10(6) of the Regulation.

In essence, the role of the consultants is to assess to which extent a new ISO or IEC standard comply with the Commission requests and to which extent they deal with and support relevant essential health and Safety Requirements set in the European Directives and Regulations.

The 2012 edition of IEC 61439-1 was listed in the OJEU without any HAS consultant approval. The 2020 edition was subject to an HAS consultant investigation who stated the “modular approach” was an issue. That is the reason why the 2020 edition is not yet harmonised!

Since 2 years, a working group is discussing how to modify the approach in order to keep the harmonisation. The work is nearly finished and we are reaching a good compromise. That means we will see a new edition of EN IEC 61439-1 in 2024 and that will swiftly be harmonised, finally replacing EN IEC 61439-1:2012.



If you are building a Distribution Panel or any panel in conformity with IEC 61439-2 (that refers back to IEC 61439-1) you do not need to do any EMC test provided you follow the approach stated in the Annex J of IEC 61439-2. That approach will be kept also in the new edition of EN IEC 61439-1, that will see the light in 2024 and will be harmonised soon after.

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