Frequently asked Questions
- Do I need to re-test my product if the standard is updated?
The magic words are ‘due diligence.’
If a product only conforms to the old standard then you need to quote the old standard, you can't quote them as conforming to the current standard unless they do conform to that standard.
Remember that the directive says to "apply" the standard not "test to" the standard.
SO, if you want to show compliance to the new standard you do not necessarily need to retest to the new standard to show compliance to it, if you are confident enough that the product conforms to the new standard.
The level of confidence would be high if a new test requirement just clarified an old one or, changed a requirement that did not apply to your equipment but, may not be so high if a new standard added a higher immunity test level, for example a 4kV electrostatic discharge was increased to 8kV. In which case, testing the equipment with an 8kV discharge would be a good idea.
Annoyingly, customs officers appear to be taking a rather simplistic view of
"New Standard GOOD, Old standards BAD" - so rather than risk product getting stopped and having to explain to someone who doesn't understand, why your Declaration of Conformity is actually OK, it is much easier to keep Technical Files and Declaration of Conformities in line with current Harmonised Standards.
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A Chinese import has a CE mark on it.
CE also means Chinese Export and some products have been marked with this.
Many correctly tested products have just got the CE mark wrong so, part of your due dilligence would be to ask the manufacturer for extra documentation:
The declaration certificate or even the test report.
If they can't provide it be suspicious.
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What about the American UL approval and the Canadian CSA approval ?
In the UK we have the British Standards Institute, America has the Underwriters Laboratory and Canada has the Canadian Standards Authority.
To get BSI approval (or the kite mark) one has to use the BSI and be BSI accredited and regularly audited. Similarly to be approved to UL or CSA one has to use the same approach with UL & CSA accreditation and regular audits.
However.
Just a quick history of standards:
In the old days each country had their own standards.
To make things easier it was decided to join the standards together. (Harmonise)
For electronics, the International Electrotechnical Commision (IEC) https://webstore.iec.ch/home made standards to encompass all the different ones for a particular type of equipment. Identified by an ‘IEC’
These were then adopted by CEN-CENELEC https://www.cen.eu/Pages/default.aspx and identified by an ‘EN’ at the front.
Great Britain uses these standards and puts BS (British Standards) at the front.
So one gets ‘BS EN’
As an example. EN61010 for Measurement Control & Laboratory equipment
the American standards authority http://ulstandards.ul.com/standard/?id=61010-1 has now adopted the same standards. Identified with a ‘UL’ at the front.
The Canadian Standards Authority (CSA) have also adopted the same methodology. http://shop.csa.ca/en/canada/measurement-control-and-signaling-apparatus/cancsa-c222-no-61010-1-12/invt/27020962012
This means BS EN61010 = EN61010 = UL61010
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What is CB approval ?
This scheme was set up between the big international test houses such as UL, BSI, TUV etc. and the idea is that they each recognise test reports issued by one another.
Like CE marking, the scheme is based on the use of international (IEC) Standards but if some member's national standards are not yet completely harmonised with IEC Standards, national differences are permitted if clearly declared to all other members.
The CB Scheme utilises CB Test Certificates to attest that product samples have successfully passed the appropriate tests and are in compliance with the various requirements of the relevant IEC Standards used during CE testing but with the declared national differences of various member countries.
This is particularly useful when dealing with some of the more restrictive markets such as Argentina or Australia where a mandatory safety approval is required before the product can legally be sold.
You can take your product to a local test house such as BSI, get them to test it to the IEC standard
and issue a CB report, and then take this report to (say) IRAM (the Argentinian state testing
authority) in Argentina. They will then recognise the test work which UL has done and will only do
additional tests where there is a difference between the tests which were done by BSI and the ones which are required for Argentina (the differences are known as "special national conditions"). The CB report route is more expensive than getting a basic CE approval on your product but assists in the more obscure regions of the world.
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I have a large range of similar products. Do I have to test each one?
It is common practice, when considering systems like this , to test the worst case condition or the most typical setup.
One has then performed ‘due diligence’ to gain a level of confidence that the system is compliant.
Many systems are connected to third party products and it is true that the ‘new’ whole system could be tested. But, if the third party item is electrically simple, a motor for example, falls within the original system specifications and is connected as shown, say, in the installation manual, one would have a good level of confidence that the whole system would comply because of the original due diligence.
If the connected item is complex; digital electronics or power supply, then the level of compliance confidence may be lower and due dilligence by testing will increase the confidence level.
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Who draws up (signs) the CE declaration?
The European Directive 2014-30-EU (EMC for electronic products) clearly states that the responsibility of compliance with the Directive falls with the manufacturer or their representative, an importer.
In Summary: When importing a product into the European Union one does not need a member of the European to sign the CE declaration.
"Taken from the Directive"
Article 9
Obligations of importers
1. Importers shall place only compliant apparatus on the market.
2. Before placing apparatus on the market importers shall ensure that the appropriate conformity assessment procedure referred to in Article 14 has been carried out by the manufacturer. They shall ensure that the manufacturer has drawn up the technical documentation, that the apparatus bears the CE marking and is accompanied by the required documents, and that the manufacturer has complied with the requirements set out in Article 7(5) and (6).
5. CE marking and EU declaration of conformity
5.1. The manufacturer shall affix the CE marking to each individual apparatus that satisfies the applicable requirements of this Directive.
5.2. The manufacturer shall draw up a written EU declaration of conformity for an apparatus model and keep it together with the technical documentation at the disposal of the national authorities for 10 years after the apparatus has been placed on the market. The EU declaration of conformity shall identify the apparatus for which it has been drawn up.
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