The average consumer product today has a dozen safety and certification marks, stamps, or seals that most consumers do not understand. These marks, when appropriately used, can indicate a great deal about the quality and safety of the product; they show that the product has been independently tested to verify its conformance to industry standards and regulations. Some markings are voluntary while others, in certain cases, are mandatory. Even if they are not mandatory, they can make the difference between acceptance and rejection when going through customs. A great deal of the success of your product can be contingent on the certifications it has. However, knowing which of the certifications you need and the process to receive them is imposing and can seem overwhelming at first.
During product design, one of the first steps should be researching and working toward compliance with these certifications. It is much simpler to start from the ground up while keeping certain criteria in mind than it is to try and change or retrofit the project after the fact. Once the product has been defined with an established objective in mind, you should already be working with the appropriate agencies to start the process. This article will elaborate on some of the more well-known certifications, what they represent, and in what countries they are accepted.
Underwriter Laboratories
One of the most widely known and respected marks is that of Underwriter Laboratories, or UL. UL was established in 1894 to test products that were being developed to find out if they were safe, which remains their primary goal to this day. They have expanded into many different fields, ranging from consumer products to construction, but their focus is still safety in each of those fields. UL can certify products at the component level, which is given the “Recognized Component Mark” and indicates that the component is UL certified but not necessarily the end product. This is important as PCB manufacturers are often UL certified and will stamp their PCBs with the “Recognized Component Mark,” but this does not mean that the overall project is UL listed. Near any UL mark is a number which is searchable in the UL database.
Before working with UL, review the different fields and decide which one fits your product best. This may change once you start the process, but it will help you get a better idea of how they divide their fields and helps give a feel of what UL will be looking for. After contacting UL, you will be assigned an account manager who will help you step through the process. One of the first questions that a UL account manager will ask is where the product will be marketed. UL has collaborated with similar safety certifications around the world and can provide special markings to indicate that your product has been certified in the U.S., Canada, or China, as well as a variety of countries in Europe and South America. Once these items have been established, the account manager will discuss the product with you to create an overview of the process and what will come next. At this stage, you are provided a cost estimate for the process and the decision is made whether or not to continue in the certification process. Once you commit to the process, you will be helped every step of the way to make sure that your product reaches the standards set forth by UL. You can expect to have at least one physical visit from a UL representative to view your facilities to make sure that the entire process is being followed according to their requirements. In the end, you will receive certification as well as a number that end users can find on the UL website to confirm that your end product is legitimately UL certified.
While UL is a non-profit organization and a Nationally Recognized Testing Laboratory (NRTL) by OSHA, it is not a government agency, which means that certification is not mandatory. Although this testing is not mandatory in general, there are certain markets, organizations, and even municipalities that require a UL mark on selected product categories to be installed in homes or businesses. If your product deals with hazardous energy in any way—whether it is electricity, gas, or steam—it is more likely that a UL listing will be required or strongly recommended.
Conformité Européenne
The CE mark, or mark of the Conformité Européenne, is not an organization but simply a mark that indicates conformance to European Union (EU) standards and limits. Depending on the type of product, these standards could be for safety, environment, or even health related certifications. Perhaps the most famous directive, “Restriction of Hazardous Substances” (RoHS) is one of the many directives that fall under CE. If a product falls under one of the CE directives, it is required to meet the EU standards before it can be distributed within the European Economic area, which includes the European Union and other countries, such as Turkey and Norway, that have adopted the CE mark and made it a requirement for certain imports.
Many products do not need external review but can bear the CE mark after internal processes confirm conformance. As there is no independent review and no way to verify the legitimacy of the self-certified marks, CE cannot be depended on as a mark of safety like UL. The products that do require external review will have a “notified body” which will independently test and decide whether or not it conforms. It should be noted that UL is one among many testing agencies considered one of these notified bodies. If the product passes, then the notified body will provide an identification number that will accompany the mark that can be verified online.
With either the internal or external review, manufacturers and distributors need to maintain the paperwork that indicates that due diligence was taken. This needs to be provided upon demand and, if it is found that the product does not actually qualify, the penalties can include civil and criminal charges against the company and its officers.
With the CE mark, the first steps are the simplest. Search for the different directives and note if your product fits under any of the categories. For electronics manufacturers, it is guaranteed that at least the RoHS 2 directive will be applicable, with the low-voltage directive and the electromagnetic compatibility (EMC) directive most likely being applicable as well. Once all of the applicable directives have been identified, you will then look to see if a notified body must be involved in the certification or if you can self-certify. Even if you are permitted to self-certify, you can use a notified body to perform an external certification. If self-certifying, the next step is to confirm that your product conforms to the applicable directives, and if not, then make the appropriate changes. Once the product is in conformance, you will then document the conformance using the EC Declaration of Conformity along with any technical reports to support the declaration. Once these steps have been completed, you can place the CE marking on the product itself or its packaging. It is in your best interests to make the marking as visible as possible in order to reduce the amount of packaging that customs will need to remove in their inspections. Once approved, it is recommended to put the marking on both the final product and the packaging.
Reduction of Hazardous Substances
“Restriction of Hazardous Substances 2” (RoHS 2)—the 2011 update of the original 2003 Reduction of Hazardous Substances—sets limits on the amount of certain substances in electronics. RoHS is frequently referred to as the “lead-free directive” as the move to lead-free solder is the most apparent change in the certification. However, this is inaccurate as the directive covers several other hazardous materials as well. Besides lead, RoHS limits the amount of mercury, cadmium, hexavalent chromium (to enhance corrosion protection of solder), polybrominated biphenyls (a flame retardant used in PCBs), and polybrominated diphenyl ether (another flame retardant used in PCBs). There are a multitude of exceptions to this directive, the largest being lead-acid batteries. Fluorescent bulbs are also exempt since they require mercury. All medical devices were originally exempt, but with RoHS 2, the exemption has narrowed, and now only certain types of medical devices are exempt. It is a good idea to check to see if your product fits under one of these exemptions, and if it doesn’t, you must take care to properly conform as breaking the threshold of any of these substances will close off practically the entire European market. Oddly enough, if your product qualifies as an exemption, it can still bear the RoHS mark as it is technically in compliance.
When the RoHS directive was implemented, many engineers and designers simply switched to RoHS-compliant equivalent parts without changing their designs. However, all of these hazardous substances were included in printed circuit boards (PCBs) and solder to improve performance, and their removal has, in most cases, reduced that performance. When planning on RoHS compliance, it is necessary to use not only RoHS-compliant parts and manufacturing processes but to also analyze the effects of these changes in performances and temperatures. There may be more subtle changes in component selection and mounting to ensure that the PCBs are still structurally and electrically robust.
Electrical Testing Laboratories
The ETL listed mark was originally a mark of the Electrical Testing Laboratories, founded in part by Thomas Edison in 1896. Over the years, it has absorbed many different testing laboratories and is now called the Intertek Group, a worldwide testing company based out of London. Also a Nationally Recognized Testing Laboratory by OSHA, Intertek specializes in testing consumer goods and performs a wide variety of tests. These tests are not mandatory but are performed to ensure the highest quality and safety of a product. In general, an ETL mark can be accepted as equivalent to a UL mark, but its comparative renown can be debated.
The steps to ETL certification are extremely similar to UL. Upon contacting Intertek Group, you will work with an account manager who will help you through the process of certification. There are variations of the ETL mark dependent on the anticipated country in which your product will be marketed. As mentioned previously, the CE mark is not a guarantee of safety or quality, whereas the ETL-EU mark verifies that a product has been officially tested and deemed safe and in conformance with EU laws. The serial number associated with the mark can be verified either online or via a telephone hotline that Intertek has set up. Intertek can also be used as a notified body for the CE mark.
Canadian Standards Association
The Canadian Standards Association (CSA) is similar in setup to UL and Intertek Group in that it performs tests and certifies that products meet those tests. Created originally to define standards after World War I due to interoperability issues among different systems used in the war, CSA still fills this role. Like other certifiers, CSA has expanded in its scope beyond its original wartime-specific goals and now covers a variety of fields from consumer products, to industrial equipment, to environmental standards. CSA has also expanded out of Canada and is recognized in several countries in the Americas, Europe, and Asia.
While preeminently focused on safety, CSA also tests product quality and even electromagnetic interference. As with UL and ETL, CSA serializes its products, and a product can be verified as truly CSA certified via an online form.
Federal Communications Commission
Besides the large quantity of safety or health certifications, there are also several certifications specific to the emissions of electromagnetic energy. Foremost is the Federal Communications Commission, a government organization dedicated to making wired and wireless communication available to all those living in the U.S. As a small part of this overall goal, they organize the wireless spectrums to reduce overlap and make sure that unauthorized devices are not creating too much spurious radio frequency (RF) energy in the wrong spectrum bands. To ensure this, the FCC requires electromagnetic compatibility (EMC) testing. For certain items, such as cell phones, the FCC mark is required before they are able to hit the market. However, any item that has communication lines or traces that go above 9kHz are expected to be tested, though this is not enforced unless the product is causing electromagnetic interference issues and is reported to the FCC.
The inspections for compliance are done by accredited third-party vendors who will perform tests on the devices under a variety of different settings to make sure that maximum thresholds are not exceeded. If the device passes these tests, the device can bear the FCC mark and will be listed as compliant. If the device surpasses the maximum threshold, then you will need to have discussions with the testing agency to devise a way to reduce emissions.
Voluntary Control Council for Interference by Technology Equipment
Japan has a voluntary EMC testing and compliance mark called the VCCI, which is similar in intent to the U.S. FCC mark. While legally and technically voluntary, it has become a de facto requirement for entrance into the Japanese market. The VCCI mark is unique in that it is required to work for both voltages and frequencies that are used in Japan. As Japan is divided with 100VAC/50Hz on the eastern half of Japan and 110VAC/60Hz on the western half of Japan, certification has to be completed with both inputs to receive certification.
C-Tick
Australia’s and New Zealand’s equivalent to the FCC emissions standards is the C-Tick, a mandatory requirement for all products covered by Australia’s EMC regulatory arrangements. The C-Tick is only authorized for manufacturers who are based out of Australia or New Zealand or who use authorized agents. Testing under C-Tick is also run at the standard voltages that are operated in Australia and New Zealand, namely 230VAC/50Hz.
Bureau of Standards, Metrology, and Inspection
Taiwan’s Bureau of Standards, Metrology, and Inspection sets the EMC standards for Taiwan, which are similar to FCC’s, in part due to the similar voltages of the U.S. and Taiwan. Taiwan accepts the results of testing facilities outside of the country, making it considerably easier for you to perform the testing. Due to Taiwan’s rising prominence in the high tech industry, this mark is becoming more prevalent and necessary.
Korean Certification
The Korean Certification (KC) mark was changed as of January 2011 from the Korean Communications Commission mark. The requirements for this certification are very similar to those in Europe but are performed at 220VAC/60Hz in accordance with South Korea’s electrical infrastructure. Previously, the KC or KCC marks required in-country testing, but it has expanded to allow testing centers outside of Korea to certify products.
This is merely a small sample of the very large world of regulatory testing and certifications. While there is a great deal of overlap between many of the certifications, it is still imperative to anticipate the market of your product. Whether you anticipate your products in the Americas, Europe, Australia, or Asia, you must make certain that you both design and certify for that market. You will save yourself time, money, and many headaches by starting early instead of retroactively trying to incorporate the standards. Finally, the value of being able to easily and legally spread your end product across the globe could make the difference between success and failure of your product and your company.
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