Many manufacturers in Europe (EU) have expanded their delivery area in recent years and have started to internationalize or globalize their business.
The manufacturers are sometimes hampered by previously unknown challenges.
If the placing on the market of electrotechnical products in the EU was regulated uniformly by the guidelines that apply throughout the European Union, the challenges in other countries are diverse.
This begins with the fact that, unlike in the EU, there is a so-called mandatory certification in many countries and the previously known manufacturer’s CE declaration of conformity is not recognized.
But even in countries or economic areas such as the EAEU (Eurasian Economic Union), which are based on the rules of the EU, a mandatory mark (EAC mark) is required on the products, which may only be issued by accredited organizations. However, it is based exclusively on tests in an accredited test laboratory. Test results from a manufacturer laboratory that is not accredited according to ISO 17025 cannot and must not be used.
Within the EU there is no provider of testing and certification services that would be able to independently award the EAC mark. Due to legal requirements, a certification service provider based in the EAEU must always be involved. Depending on the requirements, test reports can be used for this, which were created by European test laboratories accredited according to ISO 17025 (if necessary, of course, by corresponding test laboratories outside the EU). However, it may also be necessary in exceptional cases to use a laboratory in the EAEU (e.g. for radio products).
Note: Since the market is in the Eurasian Economic Union is a very important market for many manufacturers, I will make my own contribution to it.
In other countries, separate symbols or certifications are required for safety and EMC. A typical country for this type of approach is Korea. For the EMC area, in Korea the RRA (National Radio Research Agency). This in turn has 2 different processes, which are used depending on the product. Products that do not contain radio components are only registered with the RRA. For this purpose, valid EMC test reports that reflect the national conditions (e.g. 60 Hz tests) are essential. This works in an uncomplicated way when choosing the right inspection service provider, since in the EU some of them are entitled to inspection reports for the RRA via a so-called MRA (Mutual Recognition Agreement) between the EU and Korea Registration to create. However, this only applies as long as the manufacturer and the manufacturing facility of the electrotechnical products are in the EU. As soon as the headquarters of the manufacturer or the production facility are outside the EU, the MRA no longer applies. Other paths must then be taken here. One of these is the issuing of a so-called CB test report (more on this later under the topic “IECEE CB Certification Agreement”). For products with radio components, on the other hand, there is one Certification required by the RRA. Here it is usually necessary to have test reports drawn up in Korea. An MRA, which would allow European test centers to create corresponding test reports which are recognized in Korea, does not (yet) exist between the EU and Korea.
South Africa also has this separate certification from different organizations for safety and EMC. A special feature here is that only certain test laboratories are approved for the EMC area, while in many other cases in the international certification business via international agreements (e.g. the ILAC MRA or the EA), the recognition of EMC test reports from European test laboratories is possible. Overall there are z. Currently only 50 laboratories, of which only 2 are in Europe (as of January 2021), which are recognized by the South African authorities. All others are in Asia or the USA. This ensures busy laboratories and, if necessary, longer test times, which must be taken into account when launching the international market in South Africa.
It should also be noted that a product may have to be viewed differently in different countries with regard to the certification requirement. Often there are special lists or categories of products that are considered to be subject to certification. You have to strictly adhere to these.
On the other hand – China is a typical example of the complexity – the same product can be subject to certification as well as exemption from it. What’s the difference? The question of whether the product is used exclusively for commercial purposes or whether it can be bought by “average consumers”. So it partly even depends on the sales concept in the respective country in which you want to sell your products. In case of doubt, an exemption from the certification requirement can also be confirmed in writing in some countries for presentation to customs. This is a paid service that can save an entrepreneur high certification costs and follow-up costs for factory inspections. This may also work if you are not sure about a certification requirement for a certain product.
A special feature should be noted with regard to the North American market, i.e. USA and Canada. These two countries have different security standards than most of the rest of the world. While in the so-called “IEC world” the standards have a very strong focus on avoiding or preventing electrical hazards (among others), many standards in North America are still strongly focused on fire hazards. The requirements therefore differ greatly from the standards that are known in Europe. Even if more and more standards are being harmonized with those of the IEC world in the USA and Canada, the requirements for fire protection are often added to the national deviations. The testing institutes located there also ensure that individual components are also certified by the certification body. If not, there is a risk of high costs for the co-assessment of such components in the course of certification.
Finally, on a topic that is an important building block for many companies on the way to international marketing, the so-called CB procedure .
In principle, the CB procedure is about the fact that test results created by a test laboratory form the basis for certification in a target country. For this purpose, a so-called CB test report for the product is created by a test laboratory, the associated certification body (Body A) creates a so-called CB certificate for this purpose. With this CB certificate and the associated CB test report, the product is submitted for certification at the local certification body (Body B) in the destination country. Usually without further tests, the local certificate of the target country is then issued based on the test report submitted. However, the procedure may also allow the certification body to request one or more test samples.
However, this implementation process is linked to a number of conditions that are not always easy to see through. I would just like to point out the most important ones here:
- Both the initial testing body and the certification body issuing the CB certificate (Body A) must be listed for the product itself or the associated security standard in the CB procedure as “issuing / recognizing = I / R”. In the target country, the certification body must at least be listed for the product as “recognizing = R” in the CB procedure. It is therefore not sufficient for the testing center and the certification body to participate in the CB procedure as such. This basic requirement must first be checked when selecting the test laboratory.
- It must be checked whether there are so-called national deviations from the standard applicable to the product for the target country. If necessary, these must also be checked and documented by the laboratory carrying out the tests.
- For components that are safety-relevant (e.g. power switch, power cord, power plug and other components in the so-called power circuit, which is directly connected to the supply network) and are used in the product to be certified, separate CB certificates and corresponding test reports must usually be available.
- Special features with regard to the different mains voltage and / or mains frequency in the target country may have to be taken into account during the tests by the first test laboratory. The countries Japan, Korea and Saudi Arabia (this is not an exhaustive list) are to be viewed particularly critically. There it is required that certain tests are carried out with the mains voltages and mains frequencies prevailing there.
If these conditions are not met, the submitted documents may be rejected or so-called supplementary tests in the target country or by the laboratory that created the original test report are necessary. Both are associated with additional costs and, in some cases, considerable loss of time in the market launch.
In general, it can be said that many certification bodies want or have to carry out a so-called factory inspection at the manufacturer’s production sites on a regular basis after they have been awarded their own certification mark. This ranges from once a year to four times a year. This is partly also dependent on the product itself or the experience of previous factory inspections in the production facility.
If you take a look at this brief overview of the international certification world, you can see that it can be worthwhile to entrust an expert who is familiar with these challenges with obtaining international certificates.
Of the Author of this article knows all these aspects from more than 30 years of activity in these areas.
If you have any questions or need support with your international approval projects, please do not hesitate to contact him.
Author: Heiko Sattler