Besides the fact that this standard unnecessarily impedes trade, it also violates Article 2 paragraph 2 of the WTO TBT Agreement.  In simplest terms, this Article states that technical regulations must be designed based on scientific evidence.  As I mentioned in the beginning, the European utility industry dominated committee drafted this standard based on theory, and more specifically based on a precautionary theory. 
     No scientific or technical data or evidence was used in developing this standard.  In fact, since 1992 industry has requested a complete and detailed scientific rational for the standard, but none has been provided. 
       Instead, the IT industry has evidence that refutes the theoretical basis of IEC/EN 61000-3-2.  In 1998, the Information Technology Industrial Council in cooperation with IBM conducted a survey to determine if there truly was a problem.  This survey was conducted in 57 ITE manufacturing sites, 26 of which were in Europe, with some plants containing 22,000 personal computers, more than one hundred servers and several mainframes.  The result of this survey: not one of the European locations had been approached by the utility companies indicating that low frequency emissions from those sites were causing them concern or problems.  Also, within the United States, there is no record of complaint from the utility industry. 
    Finally, I would like to point out that nowhere else in the world, besides Europe, is there a regulatory standard like EN 61000-3-2. 
     However, I do have some good news.  Very recently the IEC has decided to rewrite 61000-3-2 and CENELEC has very recently placed the standard under review.  This means that a significant amount of our work has already been completed, but, the problem is not over. 
     Therefore, it is vital that we act immediately to take advantage of this fact.