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The international strategy has two parts: 1) ensuring U.S. participation in IEC SC77A as the subcommittee rewrites IEC/EN 61000-3-2; and 2) gaining Japanese government and business support for the postponement and redrafting of IEC/EN 61000-3-2. Ensuring U.S. Participation in IEC SC77A The IT
industry needs to participate actively in IEC committees TC77and SC77A as they
prepare the revised version of EN 61000-3-2.
This is essential to ensure that the IT industry’s interests are not
ignored and that science is used as the basis for designing a cost-efficient
standard. CHEI members who
are appointed by the USNC to TC77 and SC77A need to attend all meetings of
relevance. The IT industry must
ensure representation at the following upcoming meetings:
Additionally, the United States National Committee (USNC), and particularly the U.S. Coordinating Committee on Electromagnetic Compatibility (USCCEMC), should continue to build support among other countries’ national committees and begin to put pressure on the IEC to draft responsible science-based standards and to balance out the utilities versus IT industry representation on IEC/TC77 and IEC/SC77A. (Exhibit 5 provides a sample letter expressing this view.) The USNC will also need to balance the various views of U.S. industry in order to achieve the most acceptable outcome. An immediate
opportunity for the USNC to push the IT industry’s concerns is at the IEC’s
Committee of Action meeting on May 25-26, 2000 in Geneva. This committee is
responsible for the management of the IEC’s standards work including the
creation, dissolution and scopes of the IEC technical committees. Frank K.
Kitzantides and Charles Zegers represent the U.S. in the Committee of Action.
Members of CHEI should inform these two of its position. The USNC should also consider building a stronger relationship with the IEC in order to tie American standards in more closely with international ones. Gaining Support of the Japanese Government and Business Japan is the second largest exporter of information technology (IT) equipment to the European Union. Therefore, postponing the implementation of EN 61000-3-2 will be of interest to Japan. The following organizations may be able to help the coalition. Keidanren.
The Japan Federation of Economic Organizations, known as the Keidanren, is a key
nationwide trade association in Japan. Its membership includes 1,009 of
Japan’s leading corporations (including 63 foreign firms), as well as 119
industry-wide groups representing such major sectors as manufacturing, trade,
distribution, finance, and energy. It should be asked if it will help pressure
the EU to change its LFE requirements and postpone the implementation of EN
61000-3-2. American
Electronics Association Japan. The American
Electronics Association (AEA) has a branch office in Japan that could be used to
solicit the support of the Keidanren. This
office could also be used as a base from which to ask Japanese businesses and
government officials to send letters to the DG Enterprise and CENELEC in support
of the IT industry position. American Chamber of Commerce - Japan. The American Chamber of Commerce - Japan (ACCJ) provides another source of contacts who might be able to solicit the support of the Japanese government and businesses. If the above strategy fails, it may be
necessary for the U.S. government engage DG Enterprise in negotiations to
resolve the issues raised by EN 61000-3-2. The following negotiation strategy
should be implemented. The greatest amount of attention will be placed on the
analysis stage. The analysis
section describes in detail the interests, options, objective criteria, and best
alternatives to negotiated agreement (BATNA) of all the key players and
interested parties in the negotiated outcome (see Appendix D). ANALYSIS Objective:
To convince the European Commission that implementation of EN 61000-3-2
needs to be postponed until the IEC and CENELEC finish rewriting and reviewing
the standard. Preferred outcome The European Commission postpones
implementation of EN 61000-3-2, adopts revised IEC/CENELEC version of the
standard (when finished), and allows an acceptable amount of time for companies
to conform to the revised EN 61000-3-2. Who
Negotiates Catherine Novelli, Assistant United States Trade Representative for Europe and the Mediterranean and Charles Ludolph, Deputy Secretary for Europe of DOC, will carry out the negotiations for the IT industry. Their counterpart will be Directorate-General Erkki Liikanen of DG-Enterprise within the European Commission. Allies
Objective
criteria
See
chart for a detailed account (Appendix D).
BATNA File a complaint within the WTO against
the EU. Negotiation tactics USTR
needs to clearly present its case giving all the facts and evidence available to
it. It
will be important to describe the costs of EN 61000-3-2, as well as present
scientific evidence that the standard is unnecessary. USTR should show openness
to a negotiated solution and approach the negotiation as a group effort to fix a
common problem and not as one group trying to triumph over another.
Since there may be some truth to the European Union’s theory, the U.S.
should work with the EU to negotiate a more acceptable standard; possibly one
that adjusts to future changes.
EXHIBIT
1
Charles T. Zegers, SecretaryUSNC/IEC,
TC77A Dear
Mr. Zegers: The
Coalition on Harmonic Emission Issues (CHEI) would like to solicit your support
in ensuring that the rewritten International Electrotechnical Commission (IEC)
standard 61000-3-2 adequately accounts for the information technology (IT)
industry’s interests. This standard is of grave concern to the IT industry
because, despite its many flaws, the European Union has adopted it wholesale in
its standard EN 61000-3-2 and is requiring that all products comply with it by
January 1, 2001. IEC/EN
61000-3-2 lacks reproducibility in measurement, its language is ambiguous, and
most importantly, there is no scientific evidence or record of the low frequency
emission problem the standard is designed to address. For all of these reasons,
the IEC recently decided to rewrite the standard.
CHEI
and the electronic/electrical equipment manufacturers need your help in ensuring
that the rewritten standard adequately addresses the IT industry’s concerns.
When
IEC Sub-Committee (SC) 77A drafted the original standard, the IT industry had
limited to no input; the European utilities industry dominated the process. It
is of utmost importance that the USNC and the IT industry have a strong showing
within SC77A during the re-drafting process. We need to make sure that the
revised IEC/EN 61000-3-2 is based on science and that cost-effective means are
prescribed to remedy whatever problem is reflected by this science. Members
of CHEI would like to meet with you and members of the U.S. Coordinating
Committee on Electromagnetic Compatibility (USCCEMC) to discuss our concerns and
solicit your input on how to go about participating in the re-drafting process.
CHEI is already requesting that members of the IT industry be appointed by the
USNC to serve on SC77A and its working groups during the redrafting process.
By
coordinating our efforts with the USNC and USCCEMC we are certain that this
standard can be revised to efficiently resolve all of its current problems.
Thank you for your time and for considering our concerns. We look forward to meeting with you soon. EXHIBIT 2CENELEC Dear
Mr./Ms. ___________: On
January 1, 2001, EN 61000-3-2 is to take full effect. This standard has many
flaws. It lacks reproducibility in
measurement, its language is ambiguous, and more importantly, there is no
scientific evidence or record that the problems the standard is designed to
address actually exist. There are
many other flaws in EN 61000-3-2, so many that the organization that developed
the standard, the International Electrotechnical Commission (IEC), recently
decided to rewrite it. It
simply does not make sense for CENELEC and the European Commission to continue
with its intended plans to implement EN 61000-3-2 on January 1, 2001 given the
IEC’s decision to re-write its standard. Implementing EN 61000-3-2 will only
create a situation where governments and companies expend resources conforming
to a standard that is only going to change in a few years when the IEC finishes
rewriting IEC 61000-3-2. In
order to prevent unnecessary expenditures of government and company resources,
the European Commission and CENELEC should postpone implementation of EN
61000-3-2 until the IEC completes the new version of 61000-3-2.
Upon completion of the rewritten version, CENELEC should properly review
the revised standard within its committees—taking particular care to ensure
that the information technology industry and all other interested parties are
fairly represented in the review process. Indeed, everyone knows that power
suppliers and distributors are over-represented on CENELEC’s low frequency
emissions committee. The
IT industry commends the work CENELEC has done to harmonize standards throughout
Europe and wishes to offer its support in preparing standards that facilitate
the free flow of goods. Sincerely, European
Commission, DG Enterprise Rue
de la Loi, 200 B-1049
Brussels Belgium Dear
Mr./Ms. ____________: We
the undersigned trade associations and companies that are involved in the
manufacture of electronic/electrical products and components are writing to
express our concerns about the negative effects that the EMC Directive will have
on the electronics/electrical industry.
Of particular concern is standard EN 61000-3-2, which addresses low
frequency emissions created by electronic/electrical products.
The
saga of developing a low frequency emission standard began in International
Electrotechnical Commission Committee SC77A, which produced IEC Publication 555.
This Publication specified the permissible harmonic emission levels for
household/consumer equipment.
As is normal for the EU standard setting body, CENELEC, this standard was
readily adopted by the corresponding CENELEC BTTF TF68-6. Shortly afterwards
this standard was listed in the Official Journal. More
recently this standard was developed further by the IEC Committee and
re-designated as Publication 61000-3-2.
The most important change to this standard was to increase its scope to
include all electronic/electrical equipment below 16 ampere, which includes
information technology equipment (ITE).
What
concerns us, is the fact that the ITE industry was never consulted on this
standard and that it was almost immediately adopted by CENELEC, which is
comprised of the same Europeans that sit on IEC SC77A—a group that is
dominated by the utilities industry and has little to no representation from the
ITE industry. Fortunately,
the protests of the ITE industry did lead to a delay of the original
implementation deadline until January 1, 2001.
But the extension did little to solve our concerns. It did nothing to
alleviate the increased costs the ITE industry will incur in redesigning
products to meet the standard. Nor did it do anything to address the limitations
it will place on technological development. The
fact is that EN/IEC 61000-3-2 is based on concerns over a potential problem
rather than sound science. No other place in the world enforces a similar
standard. The
IEC recently decided to rewrite IEC 61000-3-2.
In light of this fact we implore the European Commission to consider
postponing the January 1, 2001 implementation date for EN 61000-3-2 until the
IEC completes its rewrite. Otherwise, the ITE industry will have to revise its
products to conform with EN 61000-3-2, and then a few years later, when the IEC
finishes its rewrite, the ITE industry will have to revise its products yet
again. Additionally,
we would like to call your attention to the need for greater ITE participation
in the standards development process. As noted above, all of the committees
involved in drafting IEC/EN 61000-3-2 are dominated by the power supply
manufacturers industry, and as a result, standards have been developed that
account solely for the interests of this industry. Indeed, IEC/EN 61000-3-2 does
not require the utilities industry to do anything to clean up problems that may
contribute to harmonic emissions feedback. The cost of dealing with any
potential problems is placed entirely on the electronic/electrical equipment
manufacturing industry—despite the fact that the total cost impact of this
solution on the eventual user will be much greater than a solution that would
require utility companies to clean up their lines. The
standards development processes in the IEC and the EU should account for all
costs in the most efficient manner possible. Additional
problems are created by the close link between the IEC and CENELEC.
This link means that voluntary IEC standards very quickly become
mandatory CENELEC regulations. The result is that the IEC appeals process does
not function properly because the IEC is divided between the views of European
and non-European member countries. We would be pleased to see the European Union
should undertake a careful review of the process by which CENELEC adopts IEC
standards. Thank
you for considering our concerns.
Please do not hesitate to call me if you have any question. Sincerely, Base
Letter for Key Members of the U.S. House of Representatives: Dear
Representative, We
the undersigned U.S. trade associations and companies that are involved in the
manufacture of electronic/electrical products and components are writing to you
to voice our concerns about a European Union low frequency emission
standard—European Norm 61000-3-2. This
standard is designed to prevent electronic equipment, such as computers, from
emitting low amounts of electromagnetic interference back onto the power lines
from which they get their energy. It is set to take full effect on January 1,
2001, although there is no scientific evidence or record of complaint from
European or local energy providing companies to justify such a standard.
Conforming
to this standard is expected to cost the U.S. electronic/electrical industry $25
billion dollars by January 1, 2001. This estimate is based on the fact that,
more likely than not, all production facilities will have to be altered since it
is not feasible to differentiate production by end-product destination. For
certain electronic/electrical products, manufacturing costs are expected to rise
from 2 to 1000 percent. In either case, consumer prices will rise, and U.S.
exports of electronic/electrical equipment will be hurt.
The information technology industry will be hit particularly hard.
We
are writing to you for two reasons: (1) to inform you of this very serious
problem and (2) to request your assistance.
Your ability to create greater awareness of this problem cannot be
underestimated.
(Place company name here if going to a specific district
representative, otherwise use “We are”) is relying on your support.
Thank
you for your time and for considering our concerns.
If you have any questions please notify _______________.
Sincerely, IEC
Committees TC77 and SC77A: We
the undersigned would like to commend IEC committees TC77 and SC77A for deciding
to rewrite IEC 61000-3-2. The standard is fundamentally flawed and would cost
the information technology industry billions of dollars, despite the fact that
there is no scientific evidence that the standard addresses a real problem.
Nonetheless,
we remain concerned that the re-written standard will have its own flaws if TC77
and SC77A do not change the way they go about drafting standards. Specifically,
the committees need to ensure that: 1.
There is scientific evidence of the need for the standard (e.g.,
statistically valid field data and technical studies). 2.
The standard accounts for cost-benefit factors, businesses needs, market
impacts, and product feasibility considerations for all industries concerned.
3.
All affected industry sectors are adequately represented and all industry
concerns are adequately addressed during the re-drafting process. 4.
The re-written standard does not inappropriately address regional
standards issues instead of global issues. Respectfully, |