Product certification for export

By Jack L. Andrews, Compliance Consultant, Andrews and Associates

Although the United States has no legal requirements for product safety, codes in some larger cities allow only listed products to be used in some jurisdictions. Such requirements are likely to increase now that the federal government and OSHA have approved the National Recognized Testing Laboratories (NRTL) as an alternative to Underwriters Laboratory (UL). Indeed, if you ask UL or one of the NRTL laboratories if your product needs to be approved, they will almost always say yes.

Most companies seek approval for their products to meet liability concerns or satisfy their market. Europe and Canada, for example, require product safety testing and marks on products made or sold there, and any company wanting to export goods to those markets must comply. With increasingly fierce competition, companies can no longer rely on reputation or unsupported claims.

The Certified Body (CB) scheme is a program for recognizing results of testing to specific safety standards for electrical equipment. A National Certification Body accredited by the international Electrotechnical Commission (IEC) can provide a CB Certificate and a 35-page CB Report that addresses the concerns of most countries. The CB test report must be completed by a laboratory that is recognized as a certified body by the European Union. More than thirty countries accept the CB scheme as proof of a recognized testing method. Additional requirements for other countries will be minimized. Many testing laboratories belong to the National Certification Body. Among them are Underwriters Laboratory, Factory Mutual, and Edison Testing Laboratory.

European Union requirements

European regulations governing the free circulation of products among the member states of the European Union are based on directives that must be incorporated by individual states into their national legislation. These directives are established by the European Union and serve as overall guidelines for the national legislation. The directives that are required for information technology equipment include the following:

  • EMC Directive
  • Low Voltage Directive
  • Medical Directive
  • Machinery Directive

These all apply to equipment not covered by a specific product directive (for example, medical devices) and include requirements relating to EMC as well as safety (low-voltage directive) and machinery. To market and ship products to Europe you need to comply with three elements of the directive:

  • Verify product compliance with these directives
  • Conformit'e Europe'en (CE) Mark to the product
  • Issue a declaration of conformity.

There are two routes to verifying that your product complies with these directives:

  • You can test and self-declare that you are in compliance, but here the issue is credibility. To ensure that the testing is done correctly you may elect to use a recognized testing laboratory.
  • The other option is to complete a technical construction file on your product and send the file to a certified body for approval. Either route will yield a CE mark.

Costs for certifying a product are as follows:

  • EMC testing: $6,000 to $10,000
  • Product safety: $6,000 to $8,000
  • Technical construction file: $10,000 or more

To perform the testing may require several months because of long waits at the laboratories; once scheduled the EMC tests should be completed in three or four days. For product safety allow 60 to 90 days for completion. The technical construction file also takes 60 to 90 days to complete.

To affix the CE Mark is very straightforward. In most cases, the mark goes on the product label; some companies also add it to the shipping container. You must use the approved mark of the European Community. The correct artwork for the Mark is identified in the directives.

The declaration of conformity is the final stop in this process. This document needs to identify the manufacturer, the product, the directives, and the test standards and include the signature of an officer of the company. The declaration of conformity needs to be given to your importer. Some companies choose to place the declaration in the user's guide or include it with the shipping documents.

Mexico's requirements

Mexico does not recognize any product safety approvals other than its own. Only Mexican corporations may receive product safety certifications, or NOM (Normality of Mexico) certificates. NOM certificates are not transferable.

A company wanting product certification in Mexico has several options:

  • Establish an operation in Mexico
  • Select a master distributor that will sell to others in Mexico
  • Select several distributors, each of whom will require their own test reports and certificates
  • Have a Mexican company act as your agent.

To achieve certification in Mexico, you need to follow these steps:

  • Establish a NOM certifying agency in Mexico to complete the testing
  • Select the products to be tested. One certificate can cover up to eight model numbers within a family of products.
  • Ship two of each product to the testing agency. Products and their documentation must be identical; prototypes are not permitted. The model number must be clearly identified on the product and all documentations needs to refer to the same model number. You will have to obtain a broker to clear customs. Allow two days to clear customs.
  • Allow 14 to 21 days for testing.
  • Submit an application for certification to your selected NOM agency. It usually takes them 2 to 4 days to process your application. You must have a country of origin certificate or a NAFTA certificate.
  • Allow 10 to 14 days for certification approval.
  • Begin shipping products to Mexico.

You will need the following documentation:

  • User manual: send one original and two copies; they need to be in Spanish.
  • Power schematic for each product to be tested; three copies.
  • Catalogs, brochures, pictures: three copies.
  • Declarations paperwork.
  • Safety approvals: UL, CSA, or other product safety approvals. These are not required.

Costs will include the following:

  • Importation into Mexico, tariffs, taxes, broker's fee: 10% of declared product value.
  • Testing: $1,000 per test.
  • NOM certificate: $800
  • Follow-up inspections: $400.

Mr. Andrews is a private consultant specializing in the area of product safety. He has 35 years of experience in the electronics industry in the areas of service, research and development, and compliance testing. He has obtained product safety approval for products around the globe. For more information, contact Mr. Andrews by phone at (319) 364-1723 or by fax at (319) 362- 2036.

CIRAS News, Vol. 31, No. 3, Spring 1997