Q&A; applicability of EMC directive to SIM (subscriber identity module)

Question:

Application of the EMC Directive to SIM.

“Does the EMC Directive apply to smart cards, SIM cards and other contact cards? If so, what do you think are the applicable standards?”

Answer:

My understanding is that the common SIM requires an external power source and data interface to function, so assuming the SIM card performs no independent intrinsic function, and thus is not considered an "apparatus", but rather a "component" or "Sub-assembly" and must be paired with a device designed to operate with it, the EMC directive is not independently directly applicable to the SIM.

However, the SIM will be subjected to the same environment the intended host is subjected to, so it should be capable of compliance under such conditions, and with whatever directive(s) the host, or hosts, are governed by, and should not compromise the compliance of any given host. However, testing in one configuration considered "Typical" does not automatically guarantee compliance in all use cases.

Testing to a given set of harmonized standards is one of the tools used to assess compliance with the essential requirements of a given directive, but is not a requirement in and of itself, nor does it guarantee compliance with the essential requirements.

The broader the use case, the broader the assessment needs to be. Consider mobile phones, medical devices, information technology equipment, etc...

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Note the “Answer” to the question presented is only opinion, but based on extensive knowledge of the applicable EMC requirements. The responsibility for compliance with any requirement rests with the given product manufacturer.