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Achieving universal standards compliance for electrical and electronics products

Any supplier today must ensure that their products are safe, legal for their target market territory, and carry certification to prove it. This article looks at these realities, with particular reference to how they affect electrical and electronic goods suppliers.

One early question that often arises relates to whether achieving compliance is worth the cost and effort required. After all, a 2012 survey of electronic products in Europe found that, from a sample size of 10,000, approximately two-thirds were non-compliant with the rules in some way. This included both technical and documentation requirements. Nevertheless, non-compliance can cause serious consequences, in a couple of ways. Firstly, if a consumer or competitor lodges a non-compliancy complaint against a product of yours, you run the risk of fines, product recalls and shipments being held at the border. Alternatively, if your product is found to be unsafe in some way, and actually causes damage or an accident, you can be prosecuted accordingly – at which point you will no doubt be glad to have a test certificate proving you addressed safety compliance with due diligence.

For suppliers that seek to abide by the rules, the exact certifications needed for a product depend on its functionality, how it will be used and where it will be sold. However, the major applicable standards can be summarised as CE, WEEE, RoHS and REACH in Europe, and FCC and UL Safety in the US/internationally. In addition to conforming with safety requirements, all electrical and electronics products must operate within strict electromagnetic interference limits.

We will start with a review of the CE mark, because it’s an essential requirement for all goods entering the European market – and its coverage includes specifications for EM emissions and susceptibility performance standards applicable particularly to electronic and electrical equipment. RoHS, WEEE and REACH are included as part of the CE discussion. We next look at the FCC mark, which specifies electromagnetic interference limits for products manufactured or sold within the US, and then the US-based, international UL safety standard marking.

CE Marking

The CE marking is a mandatory conformity marking for certain products sold within the European Economic Area (EEA) since 1985. It certifies that the products have met EU health, safety and environmental requirements that ensure consumer and workplace safety. Product legislation for CE has been aligned under a New Legislative Framework (NLF) which was adopted in 2008. This is a package of measures that aim to improve market surveillance and boost the quality of conformity assessments. It also clarifies the use of CE marking and creates a toolbox of measures for use in product legislation.

Manufacturers in the EU and abroad must affix the CE marking to those products covered by the new legislative framework directives to market their products in Europe. Once a product receives the CE marking, it can be marketed throughout the EU without having to undergo further product modification.

The CE Marking Is required only for the following types of products:

Toys
Machinery
Electrical equipment
Electronic equipment
Personal protective equipment
Pressure equipment
Medical devices
Active implantable medical devices
In vitro diagnostical equipment
Radio and Telecommunications terminal equipment
Simple pressure vessels
Gas appliances

Lifts
Recreational craft
Equipment and protective systems for use in explosive atmospheres
Non-automatic weighing instruments
Cableways
Construction products
Explosives for civil use
New hot water boilers
Measuring equipment

CE marking is not required for items such as:

Chemicals
Pharmaceuticals
Cosmetics and foodstuffs

There are over 20 directives setting out the product categories requiring CE marking. The essential requirements that products have to fulfil, for example safety, are created at EU level and are set out in general terms in these directives. Harmonised European standards are issued with reference to the applied directives and express the essential safety requirements in detailed technical terms. Suppliers only need to comply with the directives that are applicable to their product. If your product passes all the tests outlined in the relevant harmonised standards, then it is said to have a ‘presumption of conformity’ with the directives.

Fig.1: CE mark – Image via Pixabay

CE and electrical/electronic goods

For CE compliance, electrical and electronic goods must be certified according to the LVD, WEEE, RoHS and REACH safety standards as described below. However, they must also comply with EMC requirements.

Within the NLF environment, there are at least two key Directives – Electromagnetic Compatibility and Radio Equipment – that are relevant to EMC issues, although further Directives (such as the Low Voltage Directive) may also apply. Additionally, there can be other applicable industry-specific legislation.

Electromagnetic Compatibility Directive

The Electromagnetic Compatibility (EMC) Directive 2014/30/EU applies to all electrical and electronic equipment, irrespective of whether it has an intended wireless function. Its aim is to ensure that such equipment does not generate, and is not affected by, electromagnetic disturbance.

Note that Europe has the additional criteria of ‘immunity’ testing compared to the US’s FCC requirements which only specify emissions limits.

Radio (RF Transmitters)

The R&TTE Directive 2014/53/EU (the Radio Equipment Directive as of June 2016) applies to all radio equipment and to telecommunications terminal equipment intended to be connected to public telecommunications networks. It covers the radio characteristics and frequency allocation of wireless transmitters in Europe. A point to note is that if your equipment falls under the R&TTE directive, then different EMC standards are usually called out instead of those used for unintentional radiating devices which fall under the EMC directive. This is because the standards for wireless transmitters in Europe also cover emissions and immunity performance specifically for transmitters.

LVD – Low Voltage Directive

The LVD which is a safety directive applies to all electrical equipment designed for use with a voltage rating of between 50 and 1000 VAC and between 75 and 1500 VDC. The lower voltage limits are removed for wireless devices, which essentially means every wireless device sold into Europe, even if it’s a tiny 5VDC, 1 mW Bluetooth transmitter, needs to be tested for safety. However, even if the LVD is not applicable to your product, the EU rules clearly state that a product must still be ‘safe’. Other directives such as the GPSD (General Product Safety Directive) may still apply.

Environmental – Waste of Electrical and Electronic equipment (WEEE) and Restriction on the use of Hazardous Substances (RoHS) directives

Waste of electrical and electronic equipment (WEEE) such as computers, TV-sets, fridges and cell phones creates one the fastest growing waste streams in the EU, with some 9 million tonnes generated in 2005, and expected to grow to more than 12 million tonnes by 2020.

WEEE is a complex mixture of materials and components that, because of their hazardous content, and if not properly managed, can cause major environmental and health problems. Moreover, the production of modern electronics requires the use of scarce and expensive resources (e.g. around 10% of total gold worldwide is used for their production). To improve the environmental management of WEEE and to contribute to a circular economy and enhance resource efficiency the improvement of collection, treatment and recycling of electronics at the end of their life is essential.

To address these problems two pieces of legislation have been put in place: The Directive on waste electrical and electronic equipment (WEEE Directive) and the Directive on the restriction of the use of certain hazardous substances in electrical and electronic equipment (RoHS Directive).

The first WEEE Directive (Directive 2002/96/EC) entered into force in February 2003. The Directive provided for the creation of collection schemes where consumers return their WEEE free of charge. These schemes aim to increase the recycling of WEEE and/or re-use.

In December 2008, the European Commission proposed to revise the Directive in order to tackle the fast-increasing waste stream. The new WEEE Directive 2012/19/EU entered into force on 13 August 2012 and became effective on 14 February 2014.

Manufacturers (referred to as a ‘producer’ for the purposes of this directive), have obligations under this directive. Those obligations may include:

Marking equipment with the WEEE logo
Joining a PCS (producer compliance scheme) – this is to finance the collection and recycling scheme.
Providing information to a PCS on items such as product sales

Fig.2: WEEE mark – Image via Wikipedia

Restriction of Hazardous Substances: EU legislation restricting the use of hazardous substances in electrical and electronic equipment (RoHS Directive 2002/95/EC) entered into force in February 2003. The legislation requires heavy metals such as lead, mercury, cadmium, and hexavalent chromium, and flame retardants such as polybrominated biphenyls (PBB) or polybrominated diphenyl ethers (PBDE) to be substituted by safer alternatives. In December 2008, the European Commission proposed to revise the Directive. The RoHS recast Directive 2011/65/EU became effective on 3 January 2013 (more information about RoHS is available here).

The 2013 RoHS directive requires most electronic equipment to be compliant with the rules. Some examples of the concentration level limits, based on weight within homogeneous materials are:

Lead: 0.1 %
Mercury: 0.1%
Cadmium: 0.01%

This has a real effect on electronics manufacturers for the components and technology they choose to use. For example, lead free solder is now widely available, but it can be extremely difficult to work with.

Fig.3: RoHS mark – Image via Wikimedia Commons

The REACH Directive is a European Union regulation concerning the Registration, Evaluation, Authorisation and Restriction of Chemicals. It came into force on 1st June 2007 and replaced a number of European Directives and Regulations with a single system.

REACH has several aims:

To provide a high level of protection of human health and the environment from the use of chemicals.
To make the people who place chemicals on the market (manufacturers and importers) responsible for understanding and managing the risks associated with their use.
To allow the free movement of substances on the EU market.
To enhance innovation in and the competitiveness of the EU chemicals industry.
To promote the use of alternative methods for the assessment of the hazardous properties of substances (e.g. quantitative structure-activity relationships (QSAR) and read across).

Scope and exemptions

REACH applies to substances manufactured or imported into the EU in quantities of 1 tonne or more per year. Generally, it applies to all individual chemical substances on their own, in preparations or in articles (if the substance is intended to be released during normal and reasonably foreseeable conditions of use from an article).

Impact on electronic and electrical product suppliers

An article as defined above – also known as a product – is an object which during production is given a special shape, surface or design, which determines its function to a greater degree than does its chemical composition. Examples of articles are a car, a battery and a telephone.

Electrical and electronic equipment items are therefore defined as articles within the meaning of REACH. Thus, every company can be affected by REACH, whether as a manufacturer, importer of equipment from the EU area or as a manufacturer/importer of products. Also, distributors of products are not exempt from REACH obligations.

Take-e-way, a company specialising in providing services related to WEEE and other environmental legislation for small and medium companies, describes how products have a special status under REACH . There are certain conditions for producers, suppliers and users of products under REACH such as information and notification requirements and the obligation to register substances. The product itself need not be registered. However, the conditions include the registration requirement for substances manufactured or imported into the EU in quantities above 1 tonne per year. This figure includes the total amount of the substance in all products of the importer or producer. The total amount is composed of that released and of the amount that (still) remains into the product.

Companies that produce or deliver products also have notification and information obligations to the customers, distributors, users or consumers of their products. In certain cases, there are also obligations towards the European Chemicals Agency (ECHA). The information requirements apply to those producers, processors and importers which use products containing substances of very high concern (SVHC) or deliver such products to a purchaser or consumer. Those substances may have carcinogenic or mutagenic characteristics or may be toxic to reproduction.

In the case of products containing more than 0.1 percent of SVHCs, the supplier provides the recipient of the article with information about the safe use of the article or, as a minimum, the name of the substance. The same information has to be provided to the consumer, but only upon their request. The information must be passed in an appropriate form to the customer. The transmission of information is usually done on paper (e.g. in the official language of the destination country). However, it is possible to publish additional information on a website or to provide it via email.

Federal Communications Commission (FCC)

The FCC is an independent agency of the US government that was created by Congressional statute to regulate interstate communications by radio, television, wire, satellite, and cable in all 50 states, the District of Columbia and US territories.

Fig.4: FCC Mark – Image via Wikimedia Commons

The FCC label or FCC mark is a certification mark needed for electronic products that are manufactured or sold in the US. This mark indicates that the electromagnetic interference from the device is within the limits approved by the FCC.

While the FCC mark is only required within the US, it is also found on products sold outside the US territory. These products have either been manufactured in the US and then exported, or they are also intended for sale within the US.

FCC regulations apply to electronic products that may produce radio frequency pollution. These are divided into two types: Intentional Radiators and Unintentional Radiators.

Intentional Radiator

Intentional radiators are devices that broadcasts radio energy (not infrared or ultrasonic energy) to perform their function. Examples include cell phones, CB radios, walkie-talkies, wireless connections, Bluetooth connections, short-range broadcast equipment and wireless key-access systems.

These devices intentionally use the radio spectrum and therefore always require FCC equipment authorization.

Unintentional Radiator

Unintentional radiators are electronic device producing radio signals as an unintended by-product of their normal function that are broadcast through space, or conducted along power lines. Devices that receive radio waves can also unintentionally radiate radio waves.

Unintentional radiators are common everyday electronic devices such as television sets, computers, electronic games, digital cameras, and other devices containing chips and digital circuits.

The USA Regulation 47 CFR 15.3(k) defines an unintentional radiator as a device with electronics operating at over 9000 pulses per second (9 kHz) and using digital techniques.

FCC regulations also apply to phones, modems, faxes and anything else that connects to the telephone network.

UL safety

UL is a global independent safety science company offering expertise across five key strategic businesses: Product Safety, Environment, Life & Health, Knowledge Services and Verification Services.

The UL Mark indicates that UL has tested representative samples of the product and found it to be compliant with the applicable standard or other requirements with respect to its potential risk of fire, electric shock and mechanical hazards. The UL Mark on a product is the manufacturer’s representation of continued compliance with the applicable standard.

The most common UL Marks are the UL Listing Mark, the Recognised Component Mark and the UL Classification Mark.

The UL Listing Mark is one of the most commonly used UL Marks. If a product carries this mark, it means UL found that a representative sample met UL safety requirements and the manufacturer is representing that the product continues to meet those requirements. These requirements are based on UL’s own published standards for safety. This mark is seen on appliances, computers, furnaces, heaters, fuses, electrical panels, smoke detectors, fire extinguishers, sprinklers, life jackets and bullet-resistant glass as well as thousands of other products

The Recognised Component Mark is rarely seen by consumers. It is used for components that are part of a larger product or system. These components may be restricted or incomplete in construction. This mark is found on switches, power supplies, printed wiring boards, industrial control equipment and thousands of other parts. Given that a Recognised Component is an incomplete product it has conditions of acceptability.

The UL Classification Mark appears on samples of products that UL has evaluated with respect to specific properties, a limited range of hazards or suitability for use under special conditions. Typical products classified by UL are building materials and industrial equipment, immersion suits, fire doors, protective gear for fire fighters and industrial trucks.

Fig.5: UL Listing Mark examples - Image via Wikimedia Commons

Example UL standard – UL 60950-1 Standard on Information Technology Equipment Safety

UL publishes an extensive list of standards covering all electrical, electronic and other product categories. A typical example is the UL 60950-1 Standard on Information Technology Equipment Safety.

The UL 60950-1 standard is applicable to information technology equipment designed for use as telecommunication terminal equipment and network infrastructure equipment, regardless of the source of power. The UL 60950-1 standard and tests consider not only normal operating conditions of the equipment but also likely fault conditions, consequential faults, foreseeable misuse and external influences such as temperature, altitude, pollution or moisture, as well as overvoltages on a mains supply, telecom network, or cable network.

The UL 60950-1 standard is also applicable to components and subassemblies intended for incorporation into information technology equipment. It is not expected that such components and subassemblies comply with every aspect of the standard, provided that the complete information technology equipment, incorporating such components and subassemblies, does comply.

The UL 60950-1 standard specifies requirements intended to reduce risks of fire, electric shock, or injury for the operator and layman who may come into contact with the equipment and, where specifically stated, for a service person. User is the term applied to all persons other than service persons. Requirements for protection should assume that users are not trained to identify hazards, but will not intentionally create a hazardous situation. Service persons are expected to use their training and skill to avoid possible injury to themselves and others due to obvious hazards that exist in service access areas of the equipment. UL 60950-1 verifies information about potential hazards is marked on the equipment or provided with the equipment, depending on the likelihood and severity of injury, or made available for service persons. In general, users shall not be exposed to hazards likely to cause injury.

Application of the UL 60950-1 Standard

Application of the UL 60950-1 standard is intended to reduce the risk of injury or damage due to the following conditions:

Electric shock
Energy related hazards
Acoustic shock at communication receivers
Fire
Heat related hazards
Mechanical hazards
Radiation
Chemical hazards

Conclusion

Ensuring that your product is entirely safe and compliant in terms of its functionality, the materials it contains and the territories it will be sold into can be a challenging business. Suppliers like Farnell can reduce time and risk on projects by providing advice and reference information on these topics, along with the components that will be susceptible.