Electromagnetic Compatibility (EMC) for Gas Appliance Regulation (GAR)

The guide to EN298:2022 transition

In November 2022, the European standard EN 298:2012 was superseded and replaced by EN 298:2022. This transition brings about a significant change in the “state of the art” pertaining to automatic burner control systems.

Manufacturers are advised to be aware of the background of this issue to ensure compliance and understand the implications for their products. This guidance aims to provide clarity and insights into the transition to EN 298:2022, enabling you to navigate the changes effectively.

Also essential is to be aware of the technical changes introduced in the 2022 version of EN 298. While it is recommended to review the new standard directly to ensure a comprehensive understanding, we have highlighted the most significant changes for your convenience:

  • EN 298:2022 incorporates important modifications to align with EN 13611:2019 and introduces the concept of high-temperature operation (HTO). These changes are reflected throughout the standard, particularly in relation to performance tests and instructions.
  • Section 6.6.1. Specific design and construction requirements have been outlined. Additionally, a notable software clause, Annex H.11.12.4, referencing EN 60730-1:2016, has been introduced to address remotely actuated control functions.
  • Section 6.6.3 Reset Function: Formerly marked as N/A, this clause has now been designated as a requirement for Class B, necessitating the inclusion of a Reset function.
  • Section 6.6.4 Class C: The evaluation of software has been revised to align with EN 60730-1:2016 Annex H.11.12 for Class C products.
  • Section 7.8 Data Exchange: A new requirement has been introduced regarding data exchange.
  • Section 9.3 Voltage Dips and Interruptions: Tests have been added to assess voltage dips and interruptions at a 30% decrease for durations of 1.5, 25, and 50 cycles.
  • Section 9.5 Surge Immunity Tests. The surge immunity testing has been updated as follows:
  • A test of the power supply cable at 2kV LN-LN has been added (previously marked as N/A).
  • The test for control cables/balanced circuits LN-GND has been increased to 1.0 and 2.0 kV, up from the previous levels of 0.5 and 1.0 kV.
  • Section 9.8 Immunity to Radiated Disturbances Induced by Radio Frequency Fields: The standard now includes a bandwidth of 2.0-2.7 GHz. Additionally, there have been changes and additions made to the 6 x ISM, GSM, and DECT spot frequencies.
  • Section 9.11 Harmonics and Interharmonics Including Mains Signaling at AC Power Port: Low-Frequency Immunity Tests – A new clause has been added to address low-frequency immunity tests related to harmonics and interharmonics, including mains signaling.

What is meant by “state of art”?

The term “state of the art” refers to the collective understanding of technical and scientific knowledge and expertise at a specific point in time. It encompasses the minimum requirements necessary to achieve a level of safety or performance that meets the expectations outlined in a directive or regulation.

The “state of art” is mentioned in the GAR in:

  • Recital (30);
  • Annex I: points 2 (preliminary observation) and 3.5 (rational use of energy);
  • Annex III, point 1.7 – responsibility of Notified Bodies.

Please, refer to the original Guidance Document: Questions & Answers on the transition from the Gas Appliances Directive to the Gas Appliances Regulation and on the GAR implementation which provides a detailed explanation of the meaning of “state of the art”.

Is it necessary to upgrade burner controls to EN 298:2022?

In short, yes. The introduction of EN 298:2022 has revised the definition of the “state of the art” within the European Commission’s Blue Guide. According to section, ‘essential requirements are based on the assumption that harmonized standards reflect the generally acknowledged state of the art’. Additionally, section emphasizes that manufacturers should stay informed about changes in the state of the art, assess the impact on superseded standards, and take appropriate action if necessary.

Under the Gas Appliances Regulation, gas appliances and controls must meet legal requirements and be deemed “safe.” Complying with EN 298:2022 is a reliable method of demonstrating adherence to these legal obligations. It’s important to note that compliance with European Standards remains voluntary, and there may be alternative standards or documents that can equally establish compliance. In such cases, manufacturers should consider the “state of the art” referenced in EN 298:2022.

Ultimately, upgrading burner controls to align with EN 298:2022 is a recommended approach to ensure compliance with legal requirements and stay up-to-date with the evolving state of the art in the industry.

Deadlines by when burner controls should be upgraded to EN 298:2022

LabTest advises manufacturers to conduct a thorough review of EN 298:2022 and develop an action plan to ensure ongoing compliance with the updated “state of the art.” To validate conformity with the new requirements outlined in EN 298:2022, an application must be submitted to LabTest for certification update.

Considering a reasonable timeframe, we recommend completing the upgrade to the new standard before 30 November 2024, which marks two years after the publication of EN 298:2022. Beyond this date, our auditors will identify non-conformities if a burner control is certified under the earlier version of EN 298.

By proactively addressing the upgrade to EN 298:2022 and adhering to the suggested timeline, manufacturers can ensure continued compliance and align their products with the latest industry standards.

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Do I need to retest my burner controls previously tested to EN 298:2012?

According to the Gas Appliances Regulation (GAR), there are no specific requirements for retesting controls due to the change in standards. Control manufacturers have the flexibility to review the design themselves and provide evidence that their burner controls continue to comply with EN 298:2022. Alternatively, manufacturers may choose to engage a Notified Body like LabTest Certification to conduct an independent review. Our expertise in both versions of the standard can expedite the process significantly.

If, as a result of the review, any retesting is deemed necessary, we would focus solely on the clauses that involve new requirements specifically applicable to your burner controls. This targeted approach minimizes the scope of the required testing.

In the event that the manufacturer determines modifications are needed to meet the new requirements, the modified control would need to undergo testing to validate these modifications.

By conducting a thorough review and, if necessary, engaging in targeted retesting or modification, manufacturers can ensure that their controls comply with the latest EN 298:2022 standard while maximizing efficiency and time savings.

Key Takeaways for Manufacturers:

After reviewing this guide, manufacturers should consider the following action points:

  • Producing Evidence of Compliance: Manufacturers should gather and provide evidence demonstrating that their existing controls already meet the additional requirements outlined in EN 298:2022. This evidence serves to confirm ongoing compliance and alignment with the updated standard.
  • Committing to Replacement or Redesign: In cases where existing controls do not meet the new requirements, manufacturers should make a commitment to replace or redesign these controls within an agreed timeframe. This commitment should be reasonable and feasible, allowing for a timely implementation of necessary changes.
  • Manufacturers of appliances should ensure that their suppliers are also aware of and responsive to this change, as their compliance plays a crucial role in maintaining overall product conformity.

By taking these steps, manufacturers can demonstrate their commitment to compliance, ensure the continued quality and safety of their products, and maintain a collaborative relationship with LabTest Certification and other stakeholders in the industry.

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