issue: December 2006 APPLIANCE Magazine
Quality & Testing
The International Certification Equation
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by Diane Ritchey, Contributing Editor
We asked the certifications agencies and appliance OEMs about the challenges of getting products approved for international markets.
Designing and manufacturing an appliance are only some of the segments of the appliance production equation. Getting an appliance tested and approved to many international standards is the only way a new toaster, washing machine or refrigerator will ever make it to market. Yet how easy or difficult is it to gain entry into the international marketplace?
We asked experts from some of the industry’s top testing agencies—CSA, UL and TÜV SÜD America—their thoughts on what appliance companies should know about international standards and some of the obstacles and challenges that await them in the future. We also spoke to international appliance OEMs about the challenges they face as they place their products into the international marketplace.
From The Testing Agencies
Q. What are five things that every manufacturer should know about international certification?
Randall W. Luecke
CSA International and OnSpeX
“In addition to the technical requirements for international certification, manufacturers should be aware of the legal requirements of the foreign market. For example, officers of a company exporting non-compliant products to the European Union (EU) Member Countries could be imprisoned and fined for non-compliance violations.
“The application of the CE Marking, confirming the product is in compliance to the applicable schemes, is mandatory in Europe for a manufacturer selling relevant products in the EU. More than one scheme may apply (e.g. Gas Appliance Directive). Some schemes—for example the Low Voltage Directive—would allow self-declaration by the manufacturer (often supported by third-party testing) that indicates the product complies with all the applicable EU directives. Others, such as the Gas Appliance Directive, would require the manufacturer to obtain third-party approval from a Notified Body in Europe.
“Manufacturers should be aware of differences in power sources in foreign markets. For example, in North America most of the electrical appliances operate at 120 V/60 Hz. In many other countries, electrical appliances operate at 240 V/50 Hz.
“International business knowledge, together with the country’s specific cultural and business etiquette is a must. A country may have specific cultural and/or architectural differences that should be understood and incorporated in products being marketed in that country. For example, houses and apartments in Asia and Europe are generally smaller compared to North America. Appliances with a smaller footprint would be more appropriate for these markets.
“It is important to know the specific certification requirement that exists for each country. Although a manufacturer can use the IEC CB Scheme to obtain the mark of a certification body in a participating country, there may be additional requirements specific to a country, called national deviations, that must also be met.
“Approval timelines may also vary from country to country, so it is very important for companies to plan their internal marketing timelines appropriately.”
North America Regional Manager, International Certification, Underwriters Laboratories (UL)
“Taking a proactive approach and considering international compliance issues well before the production phase is the key to success and can greatly reduce your costs and time to market. The following are some important considerations from best practices and lessons learned:
“Identify all target countries upfront and develop a compliance strategy and implementation plan for all desired certifications before starting the process.
“In sourcing components, select those that already carry the required certifications and/or meet IEC or other applicable standards requirements.
“Conduct a preliminary technical evaluation of the product against applicable IEC or other applicable standards requirements on an early prototype product to identify non-compliance issues that may require changes to the product design.
“Carefully consider and plan for the necessary time and sequence to compile/process all required documents/information for a ‘certification-ready’ package to be submitted to each applicable certification organization. For example, some countries require a local representative/importer to be designated before national certification may be granted and it may take some time to arrange for such a representative.”
Dr. Uls Schmidt
Director for Product Safety Services for North America and South America,
TÜV SÜD America
“The most important is communication to all parties involved, on a global basis. And this should be done as early as possible in the product development stage. Some companies have internal experts, but there are so many smaller companies that don’t have such experts, yet they want to sell the same product in 200 countries. You will save a lot of money and avoid making changes to your product if you are in constant contact with all of your suppliers and your testing organization right from the beginning.
“You should also be involved in Association and standards meetings, because it’s important that you have input into upcoming standard modifications. TÜV SÜD America is a member of numerous international associations and committees in order to help form regulations and fully understand the standards.
“Manufacturers should be involved in, or better, control the whole supply chain as much as they can. TÜV SÜD America can help throughout the supply chain with issues such as counterfeit products, product recalls or pre- and post-shipment inspection. We work with many global retailers where no container leaves a harbor in China, for example, until all of the container’s products are checked by our technical and quality experts.
“One of the most commonly overlooked aspects of product design is the product manual. Make sure that the product manual meets the requirements of the country where the product will be sold. Recently, more standards have been issued about how to write a product or user manual. A manufacturer could be held liable if the manual doesn’t meet the local safety standards.
“It is also important to understand the documentation required to ship product into different countries. Products can be stuck in customs for weeks if the proper documentation does not accompany it. Delays in shipments can be avoided by having an International Compliance Expert there to help every step of the way.”
Q. Where do the biggest obstacles and opportunities lie for an appliance manufacturer?
Luecke of CSA
“The major opportunities that exist for manufacturers lie with exporting their products to new or developing markets. For example, The Freedonia Group, a market research firm, reports that by 2010, China will overtake the U.S. as the world’s largest major household appliances market. There are significant opportunities in the Chinese market for appliance makers. Some of the challenges for exporters are: designing products to meet the technical and cultural requirements of the foreign market, deciding whether to export product to the country or establish manufacturing facilities locally, developing a distribution channel and after sales service network, obtaining the appropriate product approvals, promoting the products and brand name in a new market, and gaining acceptance in a new market.
“Non-Asian manufacturers will soon find themselves competing with Asia-based OEMs not only for market share but also for local talent. Regional manufacturers may have a better understanding of the affected markets and consumer requirements and will build their local brands to compete with the better-known international brands.”
Wolf of UL
“Some obstacles include:
“Keeping up with regulations and standards changes in the international certification arena and understanding if and how these changes impact your specific product lines is a daunting task that requires a lot of resources.
“Dealing with different compliance systems and processes across multiple certification organizations and countries makes it quite challenging to achieve on-time delivery of required certifications in advance of the product shipping schedules.
“Yet, opportunities lie within:
“Leveraging the CB Scheme for your compliance path. Even in countries that do not participate in the CB Scheme and/or those that have self-declaration type options, a CB Test Report can often be used as the supporting documentation for certification or self-declaration because it is widely recognized.
“Outsourcing international certification compliance to a conformity assessment service provider that best matches your needs can ultimately save your company money and get your product to the global marketplace faster.”
Schmidt of TÜV SÜD America
“A large obstacle and opportunity is setting your product apart from the competition. It is popular to focus on product performance, functionality or consumer usability. More companies ask us for Usability Testing, where we pick a sample of users and determine whether their product not only meets safety standards, but whether it also meets the standards of the end user. Product differentiation is where we increasingly see more requests for assistance. We are meeting that request with the TÜV-Mark called the High-Quality Mark, which we only issue if 80 percent of all of the main features of the product are better than the competition. Yet, we have issued a very limited number of High-Quality Marks this year; not everyone who asks for it will receive it. Our High-Quality Mark is issued to selected products only after passing rigorous tests. And it’s important to note that more manufacturers are requiring their suppliers to help them meet those goals of competitive differentiation.”
And from the Appliance Makers
Q. What are the challenges of getting your appliances approved so that they can be marketed and sold in the international marketplace?
Dyson Appliances, United Kingdom
“In the past, U.S. retailers have specifically insisted on having UL approval for products, but what they really wanted was third-party approval to UL standards. It is a lot like when people Hoover their carpet, when they are actually vacuuming their carpet; the brand has been associated with the task. ETL or CSA approval is equivalent to UL approval as they use the same UL standards. The more competitive approval market can only be a good thing for approval lead times meaning faster market access.”
Breville Pty Limited, Australia
“In Australia and New Zealand, our standards for home appliances are based on the IEC standards. So, compliance for Australia/New Zealand and Europe (for instance) can be achieved with one product version, having one operating voltage range, and needing only one submission for laboratory testing. Whereas for the U.S. a new version of the appliance is required for operation on the lower voltage and for compliance with the UL standards. The main challenge is identifying the key differences between the different standards, so that at the design stage the requirements for each region of the globe are clearly known.”
Development Manager, Indesit Company, Albacina, Italy
“The challenge that the new certification is showing is that the market need is evolving toward a safe, efficient and easy-to-use appliance.”
VP North America, Liebherr Refrigeration, Burlington, Ontario, Canada
“The major challenge is to develop and manufacture appliances that are suitable for different regions and markets. For that, you need to have in-depth knowledge of the required approvals and norms of every country.”
Q. Do you see global certification of appliances becoming easier or more complicated? How and why?
Dyson of Dyson Appliances
“European certification has become easier since the introduction of the CE marking directive within Europe that has removed the necessity of obtaining approval from each country’s certification body, more so now with the expansion of the EU community to include the Eastern European countries. The CB certification scheme is also now more widely recognized, which has made entry in to markets easier.”
Willmer of Breville
“The alignment of the Australian/New Zealand standards with those used in Europe has made certification for these markets of the globe easier. There are still national variations to the standards, but these are documented through the CB scheme, and a competent and well-informed laboratory can make the process of electrical safety compliance for these regions of the globe relatively straightforward. Compliance to the U.S. standards is another issue. The process starts again for the U.S., due to the UL standards in our product categories being different to our IEC-based standards. Even though some UL requirements are the same or similar to the IEC requirements, compliance must be established separately and completely through the process of UL testing and listing. And certification is not just to do with electrical safety; there is also EMC (Electromagnetic Compatibility), EMF (Electromagnetic Fields), RoHS, and WEEE. These are all European requirements but one in particular—EMC—also applies in Australia and New Zealand. So, one large complication is that there are numerous and varied requirements around the globe, and the challenge is keeping
up-to-date with the current specifications and their application in target markets.”
Giorgetti of Indesit
“Yes, I think that global certification of appliances is becoming more complicated, but in my opinion the reasons are clear and unavoidable. The customer’s needs are now more complicated. The global certification has to be in line with the new market request, and so we have this situation that will ultimately be positive for the future of appliances and our society.”
Perez of Liebherr
“Certification procedures are gradually becoming easier among the countries which base their technical safety requirements in the IEC standards. However, it seems that the certification of certain components and materials and Energy Labels is increasing.”
Q. What are five things that a new appliance manufacturer should know about international certification?
Dyson of Dyson Appliances
“1. There is more to global certification than just meeting safety and EMC standards.
“2. Many certification bodies now have mutual agreements with other certification bodies, and can assist in the approval of products through their positive relationships.
“3. Time can be saved by obtaining CB certification for products, even including country requirements that may not be an identified market at the time of product conception. If a product is good, it won’t be long before other markets are crying out for it.
“4. Even though third-party certification may not be mandatory in a particular country, it may be a consumer or retailer requirement, so check this out. In Germany consumers will avoid products that do not have the GS mark.
“5. Obtaining third-party approval is always beneficial even if not mandatory as the approval body will be able to assist in the identification of test requirements and help to defend liability claims.”
Willmer of Breville
“Five essentials for a new manufacturer looking at international certification include:
“1. Determine to establish compliance for your target markets at the design stage of your product development. Changes later are made expensively.
“2. If you are lacking in compliance expertise, commit resources to employing consultants that can guide you through the intricacies of international certification.
“3. Do not assume that compliance tomorrow is assured because your products are compliant today. Standards are constantly changing and this makes monitoring the process of standards development very important if you don’t want to be caught with non-compliant products or an urgent need to make changes.
“4. Seek to understand the essential requirements for certification for your individual target markets. Then investigate whether or not there are alternatives to achieving certification. Many times the same level of compliance assurance can be achieved through more economical means.
“5. Take compliance with the standards and requirements of your market seriously. Compromise at the design or production stage can be a very costly mistake from which your company may not be able to recover.”
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