C-Tick/RCM for EV components.

Technical discussion on converting internal combustion to electric
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Post by TooQik » Fri, 09 Aug 2013, 00:40

I've been trying to do some research on compliance with the radio frequency emissions for my EV conversion and I'm hoping someone here can shed some light on what individual components need to either have a C-Tick/RCM or meet the equivalent overseas testing for RF interference.

I've noticed that the Tritium Wavesculptor sports a C-Tick but I've been unable to find any other motor controller with one.

Is anyone able to help shed some light on this please?

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Post by acmotor » Fri, 09 Aug 2013, 01:40

It has to be said that any 'box of electronics' that is to be RF interference tested needs to be 'installed' and with its expected power source and load and the associated cabling (and operating at expected power levels).
In an EV case that means the complete battery pack and emotor in an EV.
So it is not just the 'box of electronics' but the 'antenna array' that is connected to it that should pass a C-tick test.
I think this topic came up before but went quiet after this obvious point was made.

A manufacturer can make good practice filtering and bypassing on the equipment terminals along with attention to switching times etc.
To be smart they can nominate cable sizes, run, shielding, connection method to shielding etc (most industrial VFD manufacturers do this) but the end result in a conversion is outside the 'electronics box' manufacturer's control.

A C-tick is a good sign, but the Chinese cut and paste use of it hasn't helped. Also, considering the above points, the manufacturer's installation guidelines wrt RFI should be followed. If there are none then the C-tick may be of limited value.

Given that a typical EV has a metal body (nice RF shield, with the addition of a few straps) and most componenets are metal housed and bolted to the vehicle body, RFI is typically not an issue to surrounding vehicles but AM radio in the EV may suffer. The emotor cables being potentially the worst offenders.

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Post by TooQik » Fri, 09 Aug 2013, 03:27

Thanks for the reply acmotor.

What you've said regarding the testing of the components as a whole system is in line with my reading today from a number of sources. I read that for EMC compliance testing a vehicle with an electric motor needs to have the motor run up to a speed that equates to a vehicle speed of 40kmhr. NCOP14's reference to RF devices and compliance threw me though as to meaning individual components had to meet the requirements, hence my confusion.

Does this mean that a converted vehicle must be tested for RFI as a whole and receive a C-Tick/RCM? If this is the case I would expect that EV's being sold in Australia to have a C-Tick/RCM on them somewhere. Does your iMiev sport a compliance mark somewhere?

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Post by TooQik » Fri, 09 Aug 2013, 03:39

For anyone who's interested, this is one of the URLs I was reading today in this regard:

C-Tick Requirements for Vehicles

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Post by TooQik » Fri, 09 Aug 2013, 04:34

TooQik wrote: I would expect that EV's being sold in Australia to have a C-Tick/RCM on them somewhere. Does your iMiev sport a compliance mark somewhere?
Just done some further reading and to answer my own question (again...lol) an iMiev does not need a C-Tick/RCM as Mitsubishi are a member of the Federal Chamber of Automotive Industries and as such are exempt as long as the vehicle meets the requirements outlined in the FCAI's code "Voluntary Code of Practice for Electromagnetic
Compatibility (EMC) of Motor Vehicles".

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Post by BigMouse » Fri, 09 Aug 2013, 04:40

When I was reading about C-tick compliance and testing requirements a while back, I noticed a stipulation that devices which are battery operated may not need to be tested.

Somehow I doubt an EV would qualify ;-)

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Post by acmotor » Fri, 09 Aug 2013, 05:26

iMiEV C-tick compliance ? Can't find any information on that. edit: Oops, you've covered that. Image

I refer to AM radio interference as a really good test of RFI as it covers the typical problem frequencies (hundreds of kHz to a few MHz). Just put an AM radio off station and explore the potential interference source. Amplitude modulation radio is the most sensitive mode for RFI detection. Frequency Modulation is inherently less sensitive to RFI by a few orders of magnitude and the domestic FM band 88-108MHz is well above typical power switching equipment induced RFI.

As a matter of interest I just did that AM radio test with my i.
Inside a metal shed in the country so almost nothing from radio stations getting through.

At around 800kHz there is a steady tone at a few kHz with about 3dB signal to background noise (i.e. very little RFI) when the i is in ready mode in R, D, B, C. not P or N (i.e. emotor pulling).
RFI (what there is of it) is stronger at rear and underside of vehicle.
Once radio was moved away a few metres the tone disappeared in the background static.

Lights, aircond, heater etc all gave no signal on AM radio.

Turning on laptop, or shed lights (CFs) all gave considerably more RFI. Mostly broadband hash.

The i's own NAV AM radio could just hear the tone when off station around 800kHz (though with even less SNR as its antenna is roof mounted on the i).

I'd conclude from that basic but real world test that RFI has been well addressed in the iMiEV !!

A comparative test on a conversion should satisfy any NCOP or the like RFI requirement without the need for compliance testing.

edit: typo.
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Post by TooQik » Fri, 09 Aug 2013, 06:32

BigMouse wrote:I noticed a stipulation that devices which are battery operated may not need to be tested.
I noticed that too and got my hopes up, only to be dashed again when I read that the battery has to be fixed to the device and anything that connected to either the vehicle's 12 volt battery or plugged into a battery charger failed to meet the definiton of "battery powered". Image

Another interesting point I found out in my reading today is that anything that runs off 600VAC or 1000VDC is also exempt from this testing. Maybe a good reason to up the voltage on my conversion. Image
acmotor wrote:I'd conclude from that basic but real world test that RFI has been well addressed in the iMiEV !!
Thanks for the testing acmotor. Very interesting results.

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Post by coulomb » Fri, 09 Aug 2013, 13:50

acmotor wrote: At around 800kHz there is a steady tone at a few kHz with about 3dB signal to background noise (i.e. very little RFI)

Isn't that the NNR (Noise to Noise Ratio)? Image

The confusion arises because the Radio Frequency Interference is an unwanted noise, but so is the background random radio radiation, which is also called noise. But you want to measure how strong one noise (the RDI) is against the background noise.
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Post by acmotor » Fri, 09 Aug 2013, 18:46

Image yes, you are right. Unwanted is the key word.

RFI can of course be any unintended/unwanted transmission. (like some FM radio stations Image) It may well be a clearly identifiable signal as in this case.

I did separate the observation of 'a few kHz tone at 800kHz' i.e. a carrier frequency of 800kHz amplitude modulated by a few kHz waveform, from the 'broadband hash' (more white noise like without dominant carrier). This may prove useful in tracing the source of that particular RFI signal. The former clearly a signal with ratio to the background noise. The latter, just increased noise level.
Perhaps a combination of the VFD switching frequency and the dv/dt rise time of the VFD/cables/emotor setup ?

A 3dB SNR is the minimum level at which a signal clearly stands out from the background noise and its frequency and waveform starts to be identifiable, at least in my hearing.
True RFI measurements would of course be measuring the radiated RF power level in a Faraday cage, not an SNR. However, measurement wrt background is what really matters. If you can't detect RFI wrt background, you should stop worrying about it !
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Post by Richo » Fri, 09 Aug 2013, 20:46

TooQik wrote: I've been trying to do some research on compliance with the radio frequency emissions for my EV conversion and I'm hoping someone here can shed some light on what individual components need to have a C-Tick/RCM testing for RF interference.


All electronic parts bought/sold in Australia should be compliant.
If you buy something from overseas for you own personal use you use it at your own risk.
If you sell something as a product you are required to be compliant.
TooQik wrote:I've noticed that the Tritium Wavesculptor sports a C-Tick but I've been unable to find any other motor controller with one.


Most other controllers are imported.
It is up to the importer/distributor to have the product tested.
They become liable if there are problems and there is no compliance.
The importer/distributor could negotiate with the manufacturer to have it tested to comply for use in Australia.
Either way someone pays to have the c-tick logo on parts otherwise they could pay more later in fines etc...
TooQik wrote: what individual components need to ... meet the overseas testing for RF interference.

Unless you plan to export eV's(parts) ignore what the rest of the world wants and just focus with our standards as they are comprehensive enough.


Summary:
Buying electronic parts from overseas does not guarantee it is complaint in Australia.
If you intend to sell electronic parts it must be compliant or have an exemption.
If you buy stuff for yourself it's your own risk.

So the short answer is NO but the long answer is YES.
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Post by celectric » Fri, 09 Aug 2013, 21:27

To come back to TooQik's original question about EMC standards relating to EV conversions...

NCOP14 section 4.5 (RF Remote Controls) states that, "Builders or modifiers must ensure that any RF devices they manufacture or use are in compliance with the ACMA requirements and are appropriately labelled." Note that this is specifically in reference to RF devices, i.e. "intentional transmitters" such as remote controls, WiFi or Bluetooth modules, etc.

The ACMA states that
The use and (sometimes) possession of radiocommunications equipment not specifically designed to comply with Australian standards may be illegal. There are penalties for operation, possession for the purpose of operation and supply of radiocommunications equipment that does not comply with applicable Australian standards.

For equipment that is not for radiocommunications, the ACMA page on vehicles and accessories refers to "suppliers in Australia" and the C-Tick page linked earlier also refers to "suppliers marketing electric or electronic products to the Australian or New Zealand market place". This is why Tritium is required to have a C-Tick marking on their product to sell it in Australia, but an overseas manufacturer is not since it becomes the responsibility of the importer to ensure compliance with the Australian regulations - the ACMA defines 'suppliers' as "manufacturers, importers and their agents".

If you are importing for your own use, or building your own electronics, provided it is not radio- or telecommunications equipment and you are not going to sell it, then the regulations are much less clear. Certainly if you are interfering with a licensed spectrum holder (TV, mobile phones, military, emergency services) then they can lodge a complaint and you will be required to stop using your equipment unless you can eliminate the issue. On the other hand it is probably unnecessary (and likely to be prohibitively expensive) for you to get a compliance certificate for a one-off conversion.

My advice would be to make sure that any radiocommunications equipment is designed to meet the Australian regulations, and to follow the installation instructions for all other equipment, since they will have been tested in a representative configuration according to how they are designed and documented.

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Post by acmotor » Fri, 09 Aug 2013, 22:31

celectric wrote: .....
My advice would be to make sure that any radiocommunications equipment is designed to meet the Australian regulations, and to follow the installation instructions for all other equipment, since they will have been tested in a representative configuration according to how they are designed and documented.


That sums it up !
'Follow the installation instructions for all other equipment.' in the case of a motor controller there must therefore be installation instructions that refer specifically to the RFI / EMC practice required to meet the C-tick status. The controller itself cannot be C-ticked to anything more than 'if you install it like this' it will be compliant.
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Post by TooQik » Fri, 09 Aug 2013, 23:06

celectric wrote:On the other hand it is probably unnecessary (and likely to be prohibitively expensive) for you to get a compliance certificate for a one-off conversion.
Have got a rough quote of around $2200 to certify the whole vehicle as EMC compliant. I've also shot an email off to ACMA to see what feedback they can supply in regards to one-off conversions and compliance. I'll update if/when I get a reply.

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Post by Richo » Mon, 12 Aug 2013, 21:02

Unless you intend to go into production with your ev "conversion" your wasting your time.

OK that $2,200 will be if the car complies.
Unless you have paid real attention to all parts it's unlikely to pass first time.
You can easily spend another $1k on tests prior to spending $2,200 on the compliance report.
AND that is assuming when there is a problem YOU know how to fix it.

Perhaps set aside $10k - but don't worry you'll re-coupe that in production right Image
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Post by TooQik » Mon, 12 Aug 2013, 21:42

Richo wrote:Unless you intend to go into production with your ev "conversion" your wasting your time.
I hear you, but I'm trying to determine what is required to actually comply with NCOP14 in regards to EMC.

I appreciate everyone's comments here but unfortunately no-one seems to have a definitive answer.

NCOP14 says to comply with ACMA. ACMA regulations state you have to comply with CISPR12. CISPR12 means whole vehicle testing for EMC compliance.

The grey area in all this is one off conversions as the ACMA wording points to importing and resale, not personal use. The engineering firm I got the rough quote from told me to go back to ACMA for clarification on personal, one-off conversions, as they don't even know. Hopefully they (ACMA) come back with some answers which I can then share.

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Post by TooQik » Mon, 12 Aug 2013, 23:44

Ok, I received a reply from the ACMA.

The guts of it is; as long as the device is not a radio communication transmitter or telecommunications interface, it does not cause interference (knowingly or recklessly) to radio communications and will be used solely for personal use (i.e. not for supply to any others), then the device does not require a C-Tick or RCM compliance label if it's purchased from overseas or made by yourself in Australia.

Note that personal use means you can not re-sell, sell, loan, rent, lease or even give away the device, as if you do this you are now deemed a supplier to the Australian Market and then need to have the device tested and labelled.

As a disclaimer, I'm providing the above information from my personal understanding of the information supplied to me by the ACMA, so use it at your own risk and don't hold me accountable if it's incorrect.

If anyone is interested, I can post the reply I received if it's not in breach of any forum rules.
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Post by BigMouse » Mon, 12 Aug 2013, 23:47

NCOP14 wrote:Builders or modifiers must ensure that any RF devices they manufacture or use are in compliance with the ACMA requirements and are appropriately labelled.
As the vehicle, controller, and components aren't "RF devices" by definition, I don't think NCOP14 has anything to say about them. I believe this note was put in at the end to state that non-compliant RF devices aren't considered to be compliant simply because the vehicle in which they are installed gets signed off as roadworthy. This would be so that the engineer can sign off an EV conversion and not worry about getting in trouble for the owner's non-complaint remote locking system bought from eBay when the ABC comes knocking because every time he unlocks his car it blows up a satellite.

Unless the engineer is asking for it, don't worry about EMC. If you push the topic, he may reconsider, making your sign off (and everyone who follows you) more expensive as a result.

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Post by TooQik » Tue, 13 Aug 2013, 00:11

BigMouse wrote:As the vehicle, controller, and components aren't "RF devices" by definition, I don't think NCOP14 has anything to say about them.
The problem with NCOP14 is that is doesn't actually define what a RF device is. On the other hand, the Radiocommunications Act defines a device to include any other thing any use or function of which is capable of being interfered with by radio emission, which now brings the devices you've mentioned into consideration.
BigMouse wrote:Unless the engineer is asking for it, don't worry about EMC. If you push the topic, he may reconsider, making your sign off (and everyone who follows you) more expensive as a result.
Agree with you 100%. I haven't actually spoken to my EV engineer about this, I'm simply trying to get a firm understanding of what is required before hand.

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Post by BigMouse » Tue, 13 Aug 2013, 01:00

Anyone on there who's gotten a signoff since the latest version of NCOP14 came out should know if it came up during the process. Surely not all of them used the Tritium with its C-tick.

It'd be nice to hear from some of them.

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Post by Richo » Tue, 13 Aug 2013, 04:33

Sorry you making it too hard for yourself.
An eV conversion is an "engine change" nothing more nothing less.
NCOP14 are "guidleines" they are not hard rules.

I agree that the NCOP14 could be a little more clear on this issue by defining RF as an intentional radio transmitter ie RFID, Remote immobilisers etc
Even if you had make your own RFID kit for keyless entry what's the worst that can happen - they make you take it out?!?

No one in Perth has had an issue with it in the last 2.5 years.

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So the short answer is NO but the long answer is YES.
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Post by TooQik » Tue, 13 Aug 2013, 06:13

NCOP14 are indeed guidelines, but the last section of the document contains a check list against which the vehicle is assessed. One N check box ticked and the vehicle won't be allowed to be registered from my reading of the document. All I'm trying to do is make sure I understand what is required for each section to ensure I get the Y or NA check box ticked.

I'm not actually trying to build a bridge as you suggest, rather I'd like to be prepared if I find a bridge in my path. Image

I'm really glad to hear that no-one in Perth has had any issues. I too hope to pass with flying colours.
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Post by Tritium_James » Tue, 13 Aug 2013, 15:44

All of our EV conversion customers in Europe (Netherlands, Germany for certain) have had to have their vehicles EMC tested to be able to get them registered. Probably only a matter of time before it's required here too...

Bigmouse, an "RF device" as far as the EMC regs go is anything capable of emitting RF, even unintentionally. So this includes pretty much any piece of modern electronics. There's some exemptions for low power devices (can't remember the threshold but it's something like <5mW) and also for very high power industrial equipment, which has to be tested on site once installed.

As a small comment, $2200 for EMC testing an entire vehicle is cheap, that's a really good price! I think there's only one EMC chamber in Australia capable of fitting a car.

Also, passing EMC doesn't mean no interference on the radio - the C-tick (and CE, for Europe) test bands only begin at 30MHz. So your motor controller, DC/DC converter, etc could spray crap all over your AM radio (~1MHz) and the regulatory authorities don't care. If you're hearing it on FM (~100MHz) then it's likely to be a problem.

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Post by Johny » Tue, 13 Aug 2013, 15:54

BigMouse wrote: Anyone on there who's gotten a signoff since the latest version of NCOP14 came out should know if it came up during the process. Surely not all of them used the Tritium with its C-tick.

It'd be nice to hear from some of them.
My engineer signed off in February 2013 and the subject didn't come up. If it doesn't have a check-box in NCOP14 then most likely the engineer won't care.

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Post by Johny » Tue, 13 Aug 2013, 16:17

Tritium_James wrote:As a small comment, $2200 for EMC testing an entire vehicle is cheap, that's a really good price! I think there's only one EMC chamber in Australia capable of fitting a car.
Yes, it can fit a Rail Locomotive and is here in Melbourne (Keilor Park). When I enquired about the cost it was $3000-$5000 a day. I didn't mention EVs - not wanting to stir the nest. The ACMA rep. on our staff prefers not to hear too much about my EV - plausable deniability - maybe.
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