Reconcilable Differences

An endless tunnel of compliance marks and schemes. Sometimes it seems that way.

the great thing about a standard is…that there’s so many?

If you’ve been involved in Product Safety testing and certification, you may have noticed references to “National Differences.”

“Wait, National Differences? Weren’t we certifying to a harmonized global product safety standard?”

Well, yes you are and no you aren’t. Trust me, this makes more sense as we go along.

First, a quick overview on how major product safety regulations are harmonized.

The World of Certified bodies

Electrical product safety is reviewed by the members of the IECEE, which creates global standards in 23 product categories. Standards are proposed, refined and approved by the IECEE’s member bodies which represent as of this writing 53 countries. As standards are approved and released by IECEE, National Certified Bodies (NCBs), test labs and other regulatory agencies usually adopt them into their own test and certification procedures. Test results and Certificates list the standards to show products have met internationally-recognized safety levels. IECEE member countries also have in place Mutual Recognition Agreements (MRAs), which allow test results and certificates obtained in one country to be accepted at face value in the other country(ies). The advantages of this “CB Scheme” include:

• Agreement on safety terms and limits. A product’s test results can immediately be understood by the member country without data translation or manipulation (e.g., pounds to kilograms). Note that while the test methods and results port over, language translation of the text may still be required;
• Minimize duplicate testing. If the destination country has the same test standard as the source country and the MRA, then product retesting is not required, saving time and costs;
• Non-member countries that do not have their safety standards will often adopt the IECEE’s standards to ensure that imported/exported products have some level of safety testing performed.

In short, the CB Scheme is an excellent way to ensure products consistently meet internationally-recognized safety standards. You can find out more details at IECEE’s site. In an ideal world, that’s all that would be needed. Now let’s meet Reality…

national differences

Despite international efforts to harmonize standards of testing and certification, many times there are additional requirements for products to meet before gaining market access to a country. These additional requirements are known as National Differences, and they are the result of various forces:

• New developments in test methods or safety data that were not captured during the last standards development cycle (it can take years for a standard to be developed or updated);
• The new version of a standard was not released in time to replace the expiration of the prior standard;
• A country implements its own safety or emissions requirements that don’t align with the IECEE standards;
• Member countries implements requirements that were presented but not approved or integrated into the standard;
• A country elects to maintain pre-existing national regulations that cover more aspects than the international standard, or provides national identity (e.g., the U.S.A.’s Energy Star program);
• Unique local logos, language translations of regulatory statements are deemed necessary by the destination country;
• Geopolitical changes negate prior regulatory agreements (e.g., Brexit);
• An existing MRA does not get renewed.

In between standards release cycles, IECEE and other technical organizations (e.g., ETSI, CENELEC, CISPR, ISO) develop interim standards which if accepted in the next standards cycle either get incorporated in the next standards update, or become new standards unto themselves. Meanwhile it is up to the NCBs to assess product applications and determine which interim standards to apply. The NCBs must be able to demonstrate how the selection addresses the safety of the product.

covering all the bases

Regulatory engineers and managers can save time and money by understanding National Differences and how they impact their product certification strategy. Make sure that the following areas are addressed during product regulatory assessment and lab and NCB negotiations:

• Determine whether the destination countries (where the product will be sold) have a) adopted the IEC or CB certification scheme as-is, or b) have transposed the IEC standard into a slightly-modified version, or c) have released their own unique national standard (For example, there are minor differences between IEC60950-1 and the EU’s EN60950-1. But testing RF to the US FCC CFR47 part 15 requirements do not include safety, while the EU’s Radio Equipment Directive (RED) requirements do include safety aspects).
• Most if not all NCBs have the ability to include testing of National Differences worldwide for modest fees. This is a great approach to take when your product’s destination countries require National Differences. Even if the countries don’t have unique requirements, it’s worth considering in case product sales are expanded to other countries later in production.
• During review of the lab and/or NCB’s test reports, ensure that the National Differences are referenced by regulation and country. The results of this testing are usually listed towards the back of the report; ensure that the results are included.
• Keep in mind that while pre-testing for National Differences saves time and money for destination countries, you will likely need to pay for processing and handling in order to get the destination countries’ certificates of compliance. Even so, the savings in test time and test fees is often worth the extra step of including National Differences testing at the start of product certifications.

While I’ve tried to be accurate in this overview, I’m sure there’s other folks who have their own tips and best known methods for handling National Differences; please feel free to share your tips and methods in your comments.

(NOTE: This article reflects my views and opinions and does not constitute legal advice. Always consult with the appropriate authoritative bodies for legal guidance when assessing your product needs and strategy.)