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issue: July 2008 APPLIANCE Magazine

Certifying Appliances for Export to the USA

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by Giorgio Beretta, engineer and commercial manager of consumer products, Underwriters Laboratories

European appliance manufacturers and their engineers must understand the certification process in the United States in order to successfully export their products to the U.S. market.

Typically, European appliances need to be modified before they can enter the North American market. The primary concern regarding electrical safety is very different in the United States than in Europe. In Europe, the focus is on electrocution, whereas in the United States, the concern is fire, as many of the houses are constructed of timber. This is not to say that electrocution is not important, but the testing regime will be realigned to examine the fire risk in greater detail.

For appliances, the full certification process is intended to evaluate against:

  • Risk of fire.
  • Risk of electric shock.
  • Mechanical risks.

In order to successfully complete the certification process and receive the corresponding mark, there are several points that European quality managers, engineers, and R&D experts should be aware of, starting from the design of the product. Some of these important points are summarized as certifications at an early stage, choice of critical components, avoidance of common misconceptions regarding definitions, labeling and packaging, and follow-up services.

Certification at an Early Stage

Designing new appliances with safety certification in mind helps protect a manufacturer’s investment in product development, marketing, packaging, and distribution. But if manufacturers design new products without taking safety standards into consideration early in the design process, they may have to endure substantial revisions to the product design, making the product development process expensive and difficult to navigate. This can also result in lost revenue, missed product launch dates, and broken contracts with customers.

When attempting to be first to market with a new product or technology, manufacturers must begin considering safety certification well before the product is ready to be tested. However, many times manufacturers do not have the knowledge or resources required to anticipate potential certification concerns. By working with an organization that possesses the necessary expertise to bring new products to market, manufacturers can be confident that they will meet the requirements of customers, regulators, and retailers, and have their products accepted in their intended markets in a timely manner.

Choice of Critical Components

The critical components of an appliance play a major role in the certification process. Each critical component needs to be certified according to the corresponding UL/ANSI safety standard. The critical components for main appliance categories include:

  • Plastics.
  • Insulation systems.
  • Engines (impedance protection, thermal protection, fans, pumps, electric motors).
  • Switches.
  • Wires and cables.
  • Printed circuit boards.

The certification of a component differs from that of an end product. A certified component is called recognized. A recognized component means that the component has been tested and certified to function safely under certain conditions. These conditions are referred to as Conditions of Acceptability (COA). The COA specifies the conditions with which the component has to comply when it interfaces with other components. Having all components tested is necessary, but it does not automatically ensure that the end product is approved or in compliance with the end product UL standard. Also, components should be suitable for their intended use.

For example, UL-recognized relays for resistive loads are not suitable to drive a motor (inductive loads) without further investigation.

In order to find the certified components, engineers can:

  • Search for them in the directories of the certification bodies.
  • Look for the mark of a certification body on the product.

An example of a recognized component for the U.S. market will have the following mark on the product:

Avoidance of Common Misconceptions Regarding Definitions

Engineers also need to be careful to clearly understand certification definitions and standards. For example, Class 2 Circuit is not to be confused with the IEC safety class II. Class 2 Circuits are fed through:

  • Power adapters Class 2 Power Units, UL 1310; Class 2 transformers after Standard for Class 2 and Class 3 transformers, UL 1585; or
  • Power adapters after UL 60950, that are certified for class 2 output voltage (see Table I).

Correct Labeling and Packaging

Products adapted for the U.S. market will need to be marked and labeled with the correct electrical ratings and product safety marks. Also, instructions and installation guides will need to be rewritten, taking into account the technical and safety awareness issues for the American user.

Products adapted for the U.S. market will need to be marked and labeled with the correct electrical ratings and product safety marks, as shown in the picture.

Follow-Up Services

If the appliance meets all safety requirements, then a test report is issued, and it will be followed up by inspectors who will conduct investigations at the manufacturer’s premises in accordance with the applicable safety standards. Inspections are conducted not only on the end product, but also on the components and materials used in the product and marking.

Important safety tests are verified as well, depending on the requirements of the standard involved. Follow-up inspections are very important to guarantee the appliance will continuously comply with the certification requirements so it can enter the market seamlessly.

The following is a Follow-up Services Checklist:


  • The manufacturer of the appliance products must notify the applicant for the mark (distributor/agency) of any product changes and if any nonconformances are found.
  • Appoint and train at least one manufacturing representative to assist the field representative during inspections. This increases the efficiency of the inspection team.
  • If you are the applicant, notify the body of the proposed changes to a certified product and obtain the body’s authorization before implementing the changes.


  • Do not ship products with the certification mark on them until the product has successfully passed all the steps of the follow-up process.
  • Do not ship products that were found to be nonconforming until the field representative verifies that the affected product complies with the body’s requirement.
  • Do not manufacture products bearing a certification mark prior to having the body’s authorization for the factory location, under that specific file.

There are several consequences for not complying with the policies and requirements of a body’s follow-up services. For instance, it may increase the inspection frequency at a manufacturer’s facility to determine that sufficient and effective corrective actions have been implemented to eliminate future violations. Once an increased inspection program is instituted, a manufacturer is responsible for costs associated with all inspections above the normal inspection frequency. If you do not respect the body’s follow-up inspection rules, the consequences can go all the way up to the withdrawal of product certification.

About the Author

Giorgio Beretta is an engineer and commercial manager of consumer products at Underwriters Laboratories in Italy. If you wish to contact Beretta, e-mail tim.somheil@cancom.com.


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