EN standards and the Radio Equipment (RED) Directive 2014/53/EU and the Radio and Telecommunication Terminal (R&TTE) Directive 1999/5/EC

The Radio Equipment Directive 2014/53/EU, or RED, came into force in June of this year. This new Directive replaced the Radio and Telecommunications Terminal Equipment Directive 1999/5/EC for wireless equipment, also called the R&TTE Directive. There is a one-year transition period for the RED so until June 2017 you can choose an appropriate compliance path, or compliance module, from either Directive. There are a few changes with the new Directive that will be discussed in this article.

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First, let’s define the type of equipment that is within the scope of both Directives.

The scope and definitions of the R&TTE Directive 1999/5/EC is below.

R&TTE 1999/5/EC, Article 1 (Scope and Aim) (1.)

  • This Directive establishes a regulatory framework for the placing on the market, free movement and putting into service in the Community of radio equipment and telecommunications terminal equipment

R&TTE 1999/5/EC, Article 2 (Definitions) (b) & (c)

(b) ‘telecommunications terminal equipment’ means a product enabling communication or a relevant component thereof which is intended to be connected directly or indirectly by any means whatsoever to interfaces of public telecommunications networks (that is to say, telecommunications networks used wholly or partly for the provision of publicly available telecommunications services);

(c) ‘radio equipment’ means a product, or relevant component thereof, capable of communication by means of the emission and/or reception of radio waves utilising the spectrum allocated to terrestrial/ space radiocommunication;

Radio Equipment Directive 2014/53/EU, Article 1 (Subject matter and scope) (1.)

  • This Directive establishes a regulatory framework for the making available on the market and putting into service in the Union of radio equipment.

Radio Equipment Directive 2014/53/EU, Article 2 (Definitions)

(1) ‘radio equipment’ means an electrical or electronic product, which intentionally emits and/or receives radio waves for the purpose of radio communication and/or radiodetermination, or an electrical or electronic product which must be completed with an accessory, such as antenna, so as to intentionally emit and/or receive radio waves for the purpose of radio communication and/or radiodetermination;

From the outset, as demonstrated above, we can see that the R&TTE Directive covers radio equipment and telecommunications terminal equipment (read that as “wired”) while the RED us for radio equipment, only. There are three other ‘major differences’, please read on.

The second big difference between the R&TTE is the lowering of the frequency limit. The R&TTE applied to radio equipment from 9 kHz to 3,000 GHz (see 1999/95/EC, Article 2 (d)) while the RED applies to radio equipment operating below 3,000 GHz (see 2014/53/EU, Article 2 (1. (3)).

Thirdly, the R&TTE Directive allowed the manufacturer to choose to comply with either the R&TTE Directive or the Low Voltage Directive and the EMC Directive, as long as the radio module used in the device was suitably approved to the R&TTE Directive (see Article 10 (2.)). What this means is that if your product incorporated a wireless module that was already tested, evaluated, found to be compliant, and had a CE marking with a claim to the R&TTE Directive then you could follow the conformity modules available in the Low Voltage Directive and the EMC Directive instead of the R&TTE Directive for the overall apparatus. This option is not available in the RED.

Finally, the RED has a new requirement for the registration of products that fall into a product type that is commonly non-compliant. See Article 5 below.

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There are other changes and some differences not addressed in this article. Many are the same changes in the other NLF Directives. Another is the introduction of the simplified EU declaration of conformity. We will publish more articles regarding the new Radio Equipment Directive 2014/53/EU in the future and will discuss more changes brought in with the Radio Equipment Directive 2014/53/EU and others.

Before I close this article I want to discuss one more issue regarding the RED. That issue is the use of harmonized EN standards for the proof of compliance to the Directive. For now (as of September 15, 2016) there are only eight official, harmonized EN standards for proving compliance to the RED. By ‘official’ I mean they were published in the Official Journal of the European Union. That list is here: RED harmonized EN standards.

There are a number of harmonized EN standards that are applicable to the R&TTE Directive. The official list is here: R&TTE harmonized EN standards. We suggest you bookmark that link because the list has been removed and from the official European Commission  page for radio equipment. The R&TTE Directive is three months into its 12-month final tour and so the EU has removed reference to the R&TTE standards and replaced it with the list of eight RED standards. This is important because between now (September 2016) and the end (June 2017) the guidance we have received from the EU RED Notified Body we partner with for EU-type examinations (the formal review process for technical documentation and reports that is required for some radio products) is that you are able to use either the R&TTE standards or the RED standards to prove compliance to the RED. It is expected that the official RED list will be populated with most or all of the R&TTE standards by next June anyway.

F2 Labs is here to help.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 855-652-7281 and are here to help you.

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Posted in CE marking, R&TTE Directive 1999/5/EC, Radio Equipment Directive 2014/53/EU | Tagged , , , , , , , , , , , , , , , , , , , | Comments Off on EN standards and the Radio Equipment (RED) Directive 2014/53/EU and the Radio and Telecommunication Terminal (R&TTE) Directive 1999/5/EC

CE markings, Ex markings, and other EU markings claiming product compliance

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Manufacturers who build equipment for sale to customers in the European Union may spend a lot of time learning about and understanding the process that is required in order to sell their products with a CE marking on it.

Placing a CE marking on your equipment is your claim to the European Union that your product complies with any applicable CE marking Directive. This is an important point because there are many CE marking Directives and any that are applicable (meaning: your product is covered under their scope(s)) must be addressed and complied with. Neglecting to comply with a CE marking Directive because you did not know it is applicable to your product does not reduce or negate your obligations.

A list of CE marking Directives for which we provide technical and consultative support is below:

Radio & Telecommunications Terminal Equipment Directive 1999/5/EC

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There are many EU Directives and regulations that, although look like CE marking Directives, are not CE marking Directives. These may be laws and they must be complied with but they are not attached to your CE marking. The difference is that the non-CE marking Directives and Regulations make no mention or reference to the CE marking or the declaration of conformity. Some examples are below:

The WEEE Directive has its own mark:

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And so does Regulation (EC) 1935/2004:

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The General Product Safety Directive 2001/95/EC has no mark and compliance to it is not indicated by CE marking. It is implied simply by placing your product on the market in any of the EU member nations.

To top the above three examples, the ATEX Directive 2014/34/EU requires a CE marking and an Ex mark:

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The Ex mark is interesting because it is a mark that is required in addition to the CE marking. We do not see that in other CE marking Directives. The Ex mark is mentioned throughout the ATEX Directive 2014/34/EU.

Notably, see 2014/34/EU, Article 6, Obligations of manufacturers, (6.)

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See also 2014/34/EU, Article 38 (abbreviated), Formal non-compliance, (1.) (c)

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Finally, we see the requirement stated in 2014/34/EU, Annex II (1.0.5.) (6th indent)

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The Restriction of Hazardous Substances (RoHS) Directive 2011/65/EU is a CE marking Directive. This means that only the CE marking is recognized as showing that the product is in compliance with the RoHS Directive. Furthermore, if your product is within the scope of the RoHS Directive and you place a CE marking on it then that means that you are claiming that your product complies with the RoHS Directive 2011/65/EU – even if you did not even know that your product is within its scope.

See below RoHS 2011/65/EU, Article 16 (1.)

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The CE marking is the only marking that is the legal representation of RoHS compliance for your product. It’s interesting to perform a Google image search for “RoHS marking”:

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None of those RoHS markings mean anything legally. The EU RoHS markings are the result of marketing, drawn up by an artist and put on a product to convey RoHS compliance but they are not legal marks. Some of the other markings convey Chinese RoHS compliance, which is not related to EU RoHS compliance in any way.

The staff at F2 Labs can help you sort out these requirements, the markings you will need, and how to perform the necessary testing and evaluation required prior to the application of the correct markings.

We are here to help.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 855-652-7281 and are here to help you.

 

Posted in ATEX Directive 2014/34/EU, CE marking, EMC Directive 2014/30/EU, General Product Safety Directive 2001/95/EC, Low Voltage Directive 2014/35/EU, Machinery Directive 2006/42/EC, Medical Devices Directive 93/42/EEC, PPE Regulation (EU) 2016/425, Pressure Equipment Directive 2014/68/EU, Product Testing, R&TTE Directive 1999/5/EC, Radio Equipment Directive 2014/53/EU, RoHS Directive 2011/65/EU | Tagged , , , , , , , , , , , , , , , , , , , , , , , , , , , | Comments Off on CE markings, Ex markings, and other EU markings claiming product compliance

Harmonized EN standards, CE marking Directives and your European projects

Silently and slowly – but inexorably… the Directives and standards we use for CE marking are updated, revised, and replaced – and we must account for them. They must be correct when referenced on your declarations of conformity and that means that you have to check, once in a while, to make sure that the product you are sending to the EU was tested and evaluated using the current, relevant EN standards and claim compliance to the current Directive(s).  F2 Labs suggests that you check the status of your CE marking Directives and EN standards at least once per quarter if you are actively shipping products to the EU. We will show you how in this article.

There are two parts to the compliance of your product when you get it ready for the CE marking. The first is to determine which CE marking Directive(s) is (are) applicable. You must comply with whatever laws (CE marking Directives) apply to your product. The second part is to determine which standards you will use to prove that your product complies with the law(s). In other words: you comply with the Directives using the EN standards.

This means that you really need to check two things regarding the compliance of your product, from time to time, if you sell to the EU in an ongoing basis.

  1. The status of the CE marking Directives. These are the laws. They change from time to time.
  2. The status of EN standards. These are the technical requirements and testing used to prove compliance to the CE marking Directives. They also change periodically.

Fortunately, the EU puts this information at your fingertips on the world wide web. In this article we are going to work towards checking the status of EN ISO 13849-1, which was recently updated and replaced by a newer version of itself and we will detail how this will impact your project.

The European Commission has a page for all of the CE marking Directives. The page for the Machinery Directive 2006/42/EC is at this link. Looking at this page we first see the chart in the middle of the page which gives us some basic information about the Machinery Directive and some useful links.

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Scrolling down the page, we then get to the list of harmonized standards.  Before we look at this list let’s discuss the role of harmonized standards and your project….

Let’s take a quick time-out to ask and answer a very common question –

  • Question: “What does the term “harmonized standard” mean?”
  • Answer: Harmonized standards are the standards that have special status in that they confer, “presumption of conformity,” to products to which they are applied when used to prove that a product complies with a CE marking Directive to which they are harmonized (meaning, officially connected or attached).

…In other words, before you place a CE marking on your product it must be in compliance with any applicable CE marking Directives and in order to do so you need to show that you have selected appropriate harmonized EN standards and tested/ evaluated your product according to those standards.

Yes, the standards are voluntary, but they usually provide the quickest route to compliance. Any deviation from the application of a harmonized standard during the compliance process for machinery will require a full risk assessment for each Annex I Essential Health and Safety Requirement not covered by the applicable standard. The standards route is the way to go if possible.

Continuing, let’s take a look at the next part of the European Commission’s Machinery Directive page, the display of the harmonized EN standards.

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The link at the top of that screen-grab is to the official list of harmonized EN standards for the Machinery Directive. The list that follows (not in the above view) is taken from the linked list but only the list at that link is the ‘official’ list. I want to note that because sometimes, rarely, the list on the European Commission page we are discussing in this article is not identical to the official list. In order to get on the official list, and then published to the European Commission’s Machinery Directive page, it must first be published in the Official Journal of the European Union.

Below is the start of the list on the European Commission page. This is the page we at F2 Labs refer to for direction when selecting harmonized EN standards for consideration by our customers for their EU projects.

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Let’s take a very close look at this chart so we can understand the information that it is giving to us. First, notice the reference to ESO. This is for the European Standards Organization responsible for making the standard a ‘harmonized’ standard. Frequently these standards are taken from the IEC or ISO. Usually the standards are the same as the IEC or ISO versions – but many times they are not. This is why you must reference to the EN version of the standard. EN 60204-1 is not the same as IEC 60204-1, for the purposes of CE marking. The EU has committees of engineers who decide on the standards and these groups are CEN and CENELEC.

Moving right across the chart we see the reference to the particular standard. There are many, many standards on this list and the task for you or, better yet, your accredited 3rd party testing organization (for instance, F2 Labs) is to select the standards from this list that are applicable to your product and help to prove that the product complies with the Essential Health and Safety Requirements from Annex I of the Machinery Directive.

Next we see the reference to the first publication date and then the superseded standard, and finally the date of cessation of presumption of conformity for the superseded standard. These dates cause a lot of confusion, all the time.

Looking at EN ISO 12100:2010 we see that it was first published on April 8, 2011 (note: in the EU the month is listed second when looking at a date in the format dd/mm/yyyy). April 4, 2011 was the date that this standard was officially unveiled to the world as an acceptable standard to use for risk assessment for products falling within the scope of the Machinery Directive.

Then we see three other standards: EN ISO 12100-1:2003, EN ISO 12100-2:2003, and EN ISO 14121-1:2007. Looking to the right of those standards we see a date of November 30, 2013. That date, November 30, 2013, is the date at which a product could no longer claim compliance using those three standards. From that date forward only EN ISO 12100-1:2010 could be used as the risk assessment standard.

So, from April 4, 2011 until November 30, 2013 you could use either EN ISO 12100-1:2010 or EN ISO 12100-1:2003, EN ISO 12100-2:2003, and EN ISO 14121-1:2007 for the risk assessment for your machine. Starting on November 30, 2013 only EN ISO 12100-1:2010 was acceptable.

You may be asking yourself this after reading the above: “How does this affect my product if I used a third party (like F2 Labs) to test and evaluate a machine I built in 2012 and started shipping to the EU, and I am still shipping it to the EU?

That is a good question and the purpose for this article. Let’s say you manufacture a machine and have a few orders per year for the EU. Chances are your machine will be within the scope of EN ISO 13849-1, which is a B-type Machinery Directive 2006/42/EC EN standard. (B-type standards are, “family standards,” meaning they are likely applicable to a wide-range of products.)

See EN ISO 13849-1 as displayed currently on the previously referenced Machinery Directive site:

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EN ISO 13849-1 is a standard for control systems on machines – it is applicable to most types of machinery. Notice that it is also an ISO standard, ISO 13849-1. Note that for European projects you must reference the European version, EN ISO 13849-1.

Looking at the above graphic we see that there is a new version of the standard: EN ISO 13849-1:2015. Moving right, we can see that it replaced EN ISO 13849-1:2008, and the date of cessation of presumption of conformity for EN ISO 13849-1:2008 was on June 30, 2016.

Understanding what was written previously in this article we know that means that European machinery designed and evaluated using EN ISO 13849-1, could use EN ISO 13849-1:2008 until June 30, 2016. Starting on that date you must show that your machines complied with EN ISO 13849-1:2015. Therefore, on your declarations of conformity you must reference the 2015 version of the standard, if you used it, for shipments on or after June 30, 2016.

Just as important, you must be able to prove that you used that standard. It is not enough to list the correct standards. Behind the declaration of conformity, you should have a compiled Technical File to be able to prove to the European Authorities that your product actually complies with the current, relevant standards. Otherwise your product does not comply with the Directive.

The Technical File is your proof that the machine was actually compliant with the applicable CE marking Directives at the time you sent it to the EU. Further, you must be able to compile it and send it to the authorities, upon request, for ten years after you ship. Following is Annex VII from the Machinery Directive 2006/42/EC which is the Annex for the Technical File. Note in particular the highlighted sections.

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Without application and compliance with the relevant, current, harmonized EN standards your machine is not in compliance with the Directive – and that means that technically you are breaking the law.

How can this impact me? Good question. Let’s take a look at a hypothetical situation that can show the ramifications for taking short cuts.

Widget Machine Company builds an industrial press and sells it to a company in France. The French company uses it for seven years and then decides to upgrade its machine. In order to fund the purchase of the new machine they sell the Widget Machine Company industrial press and use an auction company to do it. The auctioneer sells it to a Romanian company and the machine is shipped to Romania from France.

No translations are performed on any of the manuals from French to Romanian and after a few weeks a worker decides to service the machine for some issue. He removes a guard and cannot figure out how to reattach it. The next shift starts, the guard is on the floor next to the machine, and a new worker crushes part of his hand. The authorities will be involved and will make contact with Widget Machine Company to make a request for the Technical File. This will come by court order.

It is at this point you will either be glad you followed the correct procedure, used the right standards, and put your Technical File together at the time you built the machine and kept it updated or you will be looking for a lawyer to represent you in a European court.

A quick search of the Official Journal of the European Union yields many examples of court cases involving companies that did not follow the correct procedure or were unable to prove that they did.

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Looking at the first case in that list (there are many, many more), we see it is titled Commission Implementing Decision (EU) 2015/1377. Opening that document and reviewing it tells us that a company in Sweden manufactured and sold log splitting equipment. It somehow came to the attention of the authorities and now the company is barred from placing a CE marking on the equipment… and barred from the entire EU.

Making sure that your equipment is appropriately compliant with the current Directives by using currently applicable harmonized EN standards will prevent this.

F2 Labs is here to help.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 855-652-7281 and are here to help you.

 

Posted in ATEX Directive 2014/34/EU, CE marking, EMC Directive 2014/30/EU, Low Voltage Directive 2014/35/EU, Machinery Directive 2006/42/EC, Medical Devices Directive 93/42/EEC, PPE Regulation (EU) 2016/425, Product Testing, R&TTE Directive 1999/5/EC, Radio Equipment Directive 2014/53/EU, RoHS Directive 2011/65/EU | Tagged , , , , , , , , , , , , , , , , | Comments Off on Harmonized EN standards, CE marking Directives and your European projects

The Radio Equipment Directive and the Simplified EU Declaration of Conformity

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I first read the new Radio Equipment Directive 2014/53/EU (aka the “RED”) in 2014 when it was published and noted its similarity to the other NLF Framework Directives as it pertains to the documentation compliance process and the conformity modules. Really, that is the point of the NLF: to make it easier for manufacturers to sell in Europe. The RED replaces the R&TTE Directive for equipment with radio communication ability and the new Directive offers an easier way to show compliance as pertains to the declaration of conformity.

In the other technical Directives we work with on a daily basis, there was no major change to the format or structure of the document. The RED is different because of the introduction of the simplified EU declaration of conformity.

A ‘simplified’ EU declaration of conformity? What is that?

To answer that question, let’s use the opportunity to briefly explain the concept of the declaration of conformity and what it is. A declaration of conformity is what sets the CE marking Directive apart from all other Directives, Regulations, and Decisions we see when understanding what our clients must do to send their products to the EU.

Broadly, if the Directive requires a CE marking, then it also requires that the product has a declaration of conformity. On the other hand, if an applicable Directive requires that the manufacturer must compile a declaration of conformity, then it will also make a requirement for a CE marking. They go hand-in-hand.

So, what is a declaration of conformity? A declaration of conformity is a one-page (usually) document that indicates at a minimum the name and address of the manufacturer, product information (model, description, serial number or range of serial numbers), the Directives complied with, the EN standards applied to prove conformity, and a sentence declaring sole responsibility by the manufacturer for the compliance of the product.

There is no mystery or magic to the declaration of conformity. The manufacturer even has a simple list to refer to in the Directive. See the RED 2014/53/EU, Annex VI.

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Please note that there is no place for a 3rd party lab to sign or stamp the EU declaration of conformity. There is instruction regarding indicating that a Notified Body has been involved, however, in those cases it would be unlikely that the 3rd party test lab would be the same as the Notified Body because of the inherent of conflict of interest. Indeed, involvement by a Notified Body is as much a check on the manufacturer as it is on the technical intervention of the test lab.

Looking at the document, it seems simple enough and if you were making only a handful of products it would be pretty simple to draft a declaration of conformity each time you make a product or a handful of products. But, what if you make a bunch of products and in high quantities? It might be more challenging to draft and sign the documents in those cases.

The simplified EU declaration of conformity can make that easier. In the RED 2014/53/EU we first see the mention of it in recital (31).

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It is mentioned again in Article 10 (9) and provides the instruction that it can be referred to by internet address.

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And, finally, we see in Annex VII it is listed on its own.

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This allows for a manufacturer to ease the compliance burden for a product by putting the declaration of conformity on the web, instead of printing it in a manual.  Additionally, we note that you can indicate a range of serial numbers on a single declaration of conformity. That means you can indicate, using one web address, the sole declaration of conformity to prove compliance for an unlimited number of products to which the declaration of conformity applies – and you can update the document to indicate new serial numbers and even new compliance methods (for instance new testing if a standard is revised, etc.).

I want to note that although I have known about the simplified declaration of conformity for two years it was not until I read a similar requirement in the new PPE Regulation (EU) 2016/425, recital (24) that I decided to point this new trend out in a blog article.

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You may consider it a good idea to adopt the simplified EU declaration of conformity format, even for products that don’t require it (for instance, medical devices, or products under the Low Voltage Directive) because it could ease the overall burden of keeping the document in order: One document in one place.

F2 Labs is here to help.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 855-652-7281 and are here to help you.

Posted in ATEX Directive 2014/34/EU, CE marking, EMC Directive 2014/30/EU, Low Voltage Directive 2014/35/EU, Machinery Directive 2006/42/EC, Medical Devices Directive 93/42/EEC, PPE Regulation (EU) 2016/425, Pressure Equipment Directive 2014/68/EU, Product Testing, R&TTE Directive 1999/5/EC, Radio Equipment Directive 2014/53/EU, RoHS Directive 2011/65/EU | Tagged , , , , , , , , , , , , , , | Comments Off on The Radio Equipment Directive and the Simplified EU Declaration of Conformity

What is IP testing?

At F2 Labs, our IP testing chambers are constantly filled with projects undergoing testing to IEC 60529. Since I work in the sales department at F2 Labs I field a lot of questions, every day, about IP testing, what it is, what we look for after the testing, and how the ratings work. This article will focus on these topics.

IP stands for ingress protection and tests the ability of your product to withstand everything from finger tips to a high pressure jet of high temperature water. The testing is by enclosure and your product does not have to be populated with the electronics in order to undergo the testing. However, it can be populated and we can test the functionality of the product, before and after the testing, by request.

You have probably noticed that there are two numbers usually displayed in an IP rating, for instance: IP65. The first number is for the ingress of solid foreign objects. This can be anything from finger tips to dust in a chamber. The second number is the water test.

The tests corresponding to the individual ratings for solid foreign objects are below.

Solid Foreign Objects

IP1X – objects ≥ 50mm
IP2X – objects ≥ 12mm
IP3X – objects ≥ 2.5mm
IP4X – objects ≥ 1mm
IP5X – dust protected
IP6X – dust tight

I walked out to our lab and took a photograph of our IP probes for the IP1X – IP4X tests.

Please see below, from left to right, IP4X, IP3X, IP2X, IP1X.

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IP5X and IP6X are different tests and require a higher degree of protection for your enclosure. Both ratings involve your product being placed in an airtight chamber and then subjected to circulating dust (talcum powder) blown over and on the product for hours. That is where the similarity stops.

The IP5X test may or may not require the installation of a vacuum barb. That is determined by the category in which your product falls. Category 1 enclosures do not require a barb while category 2 enclosures must have an installed barb for the IP5X test. The purpose of the barb is for the lab technician to connect an air hose to your product. That air hose is connected to a vacuum pump on the other end, outside the chamber, and we will try to draw air into the enclosure, pulling dust with it. Dust may enter the enclosure during the IP5X test but in order to pass there may be no dust on any conductive surface.

How are the categories defined? Category 1 enclosures are enclosures which may heat up during operation (for example: if electronic components are inside). Category 2 enclosures do not experience a temperature change.

I mentioned above that the similarity between the IP 5X and IP6X testing stopped at the dust chamber. That is because the IP6X test requires a vacuum barb and makes no distinction between category 1 or 2. Most importantly, the IP6X test allows for no dust to enter the enclosure. Simply, if dust is visible anywhere in the enclosure at the conclusion of the testing the product fails.

Before we proceed I want to show a picture of a vacuum barb because while everyone knows what they are my experience is that people refer to them differently.

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Many times I will discuss the vacuum barb issue with the customer and the need to install it. The standard calls for it if your product is an IP5X category 1 enclosure and any time you want an IP6X test. We are an A2LA accredited lab and follow the standard, directly. The test sample must come to us with the barb installed unless previously agreed upon. We can install the barb in your product for an additional fee but it is best for the manufacturer to provide the test sample to us in a state that is ready to immediately undergo the testing.

The second part of the testing is for the intrusion of water. The passing criteria for the water test is the same for all nine water tests: broadly, no water can settle on any conductive surfaces. We carefully open the product following the testing and take clear photographs throughout. We will see if water has entered your enclosure and determine the impact to your product. Our techs are extremely careful when opening the product because water can settle at the bottom and unless there are live wires or boards at the bottom, in water, your product may still pass the testing.

Water

IPX1 – Vertically dripping water
IPX2 – 75° to 90° dripping water
IPX3 – Sprayed water
IPX4 – Splashed water
IPX5 – Water jets
IPX6 – Powerful water jets
IPX7 – Effects of immersion
IP8 – Immersion, by agreement, must be more strenuous than IPX7
IPX9 – Increasing high pressure, high temperature water jetting

The tests listed above are self-explanatory but the IPX7, IPX8, and IPX9 testing merit further discussion.

IPX7 calls for your product to be immersed in a water tank for 30 minutes. The depth depends upon the enclosure size. Enclosures with a height less than 850 mm must have the lowest point of the enclosure 1,000 mm below the surface. For enclosures with a height equal to or greater than 850 mm the top of the enclosure must be 150 mm below the water surface. Note that the enclosure is measured in its working position and is situated in the tank in its working position as well.

The IPX8 test is the same as the IPX7 test except the depth and or duration of the testing is by agreement between the manufacturer and the testing laboratory. The testing must be more severe than the IPX7 testing. For instance, an IPX8 test for an enclosure may be for 35 minutes instead of 30 minutes and the depth may be the same as is called for in the IPX7 test. Or, the testing may be for 30 minutes but the depth for a product that is less than 850 mm may be 1,050 mm during the testing. We have performed testing at greater depths and for much longer periods of time. Let us know what you want – we creatively determine solutions on a daily basis.

IPX9 testing is the most strenuous of all. It requires that your product is sprayed with a high pressure stream of water (8,000 to 10,000 kPa) heated to 80° C. This testing is done at multiple angles (30 second dwell per position) on a turn table in our water chamber.

One question which is frequently asked by new customers is whether or not each test must be passed in succession in order to achieve a rating. For instance, to attain IP65 status does the product need to pass IP1X, IP2X, IP3X, IP4X, IP5X, IPX1, IPX2, IPX3, IPX4? The answer is no. In fact, passing IP65 allows the claim of all IP ratings below IP65. This question then, many times, leads to a discussion regarding how to plan this testing, since the manufacturer may not be confident regarding the ability of the product to pass. Some manufacturers ask us to start with lower tests and work up to the desired rating while others work from the toughest test and down. This is the decision of the manufacturer.

I hope this article has been helpful and we are at your service if you have additional questions or want to schedule IEC 60529 IP testing for your products.

F2 Labs is here to help.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 855-652-7281 and are here to help you.

Posted in IP Testing, Product Testing | Tagged , , , , , , , , , , , | Comments Off on What is IP testing?

FCC Labeling Requirements

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Recently the F2 Labs sales department was presented with a question from a call-in customer who wanted to know about the requirements from the FCC to label equipment. Specifically, she asked about e-labelling. She relayed that the FCC’s rules regarding this are not very clear.

You can read the FCC’s E-Label guidance here – Link – or you can do what we did – we asked F2 Labs’ Director of EMC & Wireless Operations and then read his response (below):

Here are the rules from the FCC:

(d) In order to validate the grant of equipment authorization, the nameplate or label shall be permanently affixed to the equipment and shall be readily visible to the purchaser at the time of purchase.

(1) As used here, permanently affixed means that the required nameplate data is etched, engraved, stamped, indelibly printed, or otherwise permanently marked on a permanently attached part of the equipment enclosure. Alternatively, the required information may be permanently marked on a nameplate of metal, plastic, or other material fastened to the equipment enclosure by welding, riveting, etc., or with a permanent adhesive. Such a nameplate must be able to last the expected lifetime of the equipment in the environment in which the equipment will be operated and must not be readily detachable.

(2) As used here, readily visible means that the nameplate or nameplate data must be visible from the outside of the equipment enclosure. It is preferable that it be visible at all times during normal installation or use, but this is not a prerequisite for grant of equipment authorization.

(e) A software defined radio may be equipped with a means such as a user display screen to display the FCC identification number normally contained in the nameplate or label. The information must be readily accessible, and the user manual must describe how to access the electronic display.

So in order for the display screen clause to be used, it has to be a software defined radio, and it must be on the actual equipment and not show up on the cell phone that is accessing it.

Subsequently I asked him if I could have the link to this rule on the FCC website. Below is the link

FCC Rule 2.925 (d)

This question is one of the reasons we started our blog. There are so many rules for manufacturers that identifying what your responsibilities are as pertains to the many rules that could apply can be a daunting task. We are making an effort to note some of these questions and offer guidance on our blog.

F2 Labs is here to help.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 855-652-7281 and are here to help you.

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The Pressure Equipment Directive and machine builders

The Pressure Equipment Directive 97/23/EC was recast in 2014 and the new Pressure Equipment Directive 2014/68/EU replaced the old “PED” on July 19, 2016. This revision to the Pressure Equipment Directive was part of the New Legislative Framework and was part of the EU’s effort to coordinate the requirements of different Directives – for example, declarations of conformity now all have the same format. We notified our customers regarding the updated Directives for which we provide technical support and services.

Most of the recast Directives make no new technical requirements and the new PED makes no changes to the requirements or the classification tables in Annex II.

One thing that did change is the classification of the fluid group. The way these fluids are classified is now governed by Regulation (EC) No. 1272/2008. I say “now” because that became effective in June 2015 and did not wait for the new PED to take effect.

Although the PED applies to any pressure equipment or assembly with a maximum allowable pressure greater than .5 bar, there are generous exclusions. We will look at a couple of them in this post.

Wait, did I just write that the PED applies to anything with a pressure greater than .5 bar? That’s only 7 psi! Yes – .5 bar… and keep in mind that if your product is within the scope of the PED, and the pressures are above category I limits, then you MUST work with a Notified Body to claim conformity. All paths through the available conformity modules for equipment above category I pass through a Notified Body.

Do I have your attention now?

However, there are many circumstances where you can calculate or justify your way out of applying Annex I of the Pressure Equipment Directive to your product.

canstockphoto13675847

The CETOP Position Papers are a good starting point for hydraulic equipment used in assemblies and machines. The European Fluid Power Committee, or “CETOP,” published two position papers elaborating their position regarding the PED and the Machinery Directive 2006/42/EC.

The position papers demonstrate exclusions to the PED in favor of the Machinery Directive and clarify other inclusions of hydraulic and pneumatic equipment within the scope of the PED. These position papers were written with the PED 97/23/EC in hand so we will refer to that, although the references are shuffled in the new PED 2014/68/EU.

Most notable is the reference to Article 1 (3.6) of the PED 97/23/EC (Article 1 (2) (f) of PED 2014/68/EU) which excludes equipment from the scope of the PED if:

  1. It is within the scope of any of the following Directives: Machinery, Low Voltage, Lifts, Medical Devices, Gas Appliances, or ATEX.

AND –

  1. piping and connecting devices for liquids of group 2 when PS  ≤ 10 bar, or *DN ≤ 200, or when PS ≤ 5,000 bar

OR –

  1. piping and connecting devices for gas of group 2 when DN ≤ 32 or  PS*DN ≤ 1,000

*Note that in the PED, DN is outside thread diameter in millimeter and PS is pressure in bar.

Broadly, Article 1 (3.6) means that if the equipment is below “category 1” levels (which are indicated in Annex II of the Directive) and the equipment is within the scope of one of the other indicated Directives then the equipment is totally excluded from the Pressure Equipment Directive… the PED can be ignored in these cases.

See 2014/68/EU, Article 1 (2.) (f) – the equivalent to 97/23/EC, Article 1 (3.6) –

2014.68.eu.article1.2

2014.68.eu.article1.2.f

There are other exclusions to the PED within the Directive. We will address more next week in a new post.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 855-652-7281 and are here to help you.

Posted in ATEX Directive 2014/34/EU, CE marking, EMC Directive 2014/30/EU, Low Voltage Directive 2014/35/EU, Machinery Directive 2006/42/EC, Pressure Equipment Directive 2014/68/EU | Tagged , , , , , , , , , , , , , , , , , , , , , , , , , | Comments Off on The Pressure Equipment Directive and machine builders

CE marking and the China Export mark

There are two commonly used markings on equipment that are very similar in appearance but mean different things.

The CE marking is a European compliance marking and indicates compliance to all applicable European CE marking Directives (like the Machinery Directive 2006/42/EC and the EMC Directive 2014/30/EU). This marking is placed on equipment by the manufacturer prior to placing in service in Europe. It does not refer specifically to export, instead it refers to the compliance of the equipment to applicable European laws.  The CE marking is specified for all CE marking Directives in the EU’s NLF framework regulation, 765/2008/EC, Annex II, and is below.

CE marking

Some Chinese products, manufactured in and exported from China, are designated with a similar marking. At first glance it looks identical, please see below.

Chinese mark
This appears to be a CE marking. It’s not. Some research into this matter has uncovered that not only is it not a CE marking but it is also not a “China Export” mark. There is no official “China Export” mark, It is fake, applied by unaccountable factories in China and is meant to put products on the market that have not had any type of safety evaluation, risk assessment, or testing. It is illegal.

See below both markings side-by-side for comparison.

CEvChineseCE

The European Parliament made a statement regarding this in 2008 and it is linked here.

Keep in mind that if you are building products for export to the EU it is you who will be responsible for the product’s compliance. That includes sub-assemblies and components with a false CE marking. A constructional review involving EN 60204-1, EN 61010-1, etc. will uncover these issues… before you build your products for sale.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 855-652-7281 and are here to help you.

 

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LED lighting and FCC requirements

Manufacturers of LED lighting sometimes assume that they are subject to FCC Part 18 requirements for lighting since LED’s are lights. Apparently this approach is so widespread that on June 17, 2016 the FCC posted clarification online that most LED lighting is in fact subject to FCC Part 15 requirements and not Part 18 requirements.

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LED lighting is designed so that it emits RF and is subject to FCC requirements, as stated. However, as detailed at the linked document, different LED products are subject to different FCC requirements. The FCC document states that lighting products for, “general illumination, traffic signaling, roadway lighting, manufacturing processes, agriculture, etc.,” are classified as unintentional radiators and must meet limits specified in section 15.107 and section 15.109 of Part 15.

The link for this FCC post is here and the link for the actual guidance available on the page is here.

We have linked the FCC Part 15 requirements – FCC Part 15.

Also linked are the FCC Part 18 requirements – FCC Part 18.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 855-652-7281 and are here to help you.

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The EMC Directive and “Fixed Installations”

A common discussion point with manufacturers is the notion of the “fixed installation”. Probably mostly due to recital (36) in the beginning of the EMC Directive 2014/30/EU:

2014.30.eu.recital36

Fixed installations are clearly defined in Article 3 (1.) (3.) of the EMC Directive 2014/30/EU:

2014.30.eu.article.3.1.3

Article 19 of 2014/30/EU specifies what is and is not required for EMC compliance for fixed installations. Mainly we see that Annex I (1.) General requirements are not applicable and that the requirements from Annex I (2.) are, and they are much more lax: “good engineering practices”. This is in stark contrast to the requirements in Annex I (1.). Of course it would be easier to comply with Annex I (2.) instead of Annex I (1.).

That “easier” compliance method coupled with the definition of a fixed installation listed in Article 3 (1.) (3.) leads some to believe that their industrial machine can benefit from the fixed installation “good engineering” practices. Unfortunately, it can’t.

One would think that a big, industrial machine which ships in pieces and is installed by professionals, and bolted to the floor is, “fixed,” but that is not what it means. To understand what is, we look to the guidance documents published by the European Commission in support of the law.

This guidance document references the now-expired EMC Directive 2004/108/EC: as of today there is no official guidance document for 2014/30/EU.

See the examples given for what a fixed installation is, insofar as the EMC Directive is concerned, in section 1.3 (1.3.1) (para 5) of the EMC guidance document:

emcguidelines.section1.3.para5

This suggests that a fixed installation is not only “fixed” but also, very large. As a result, industrial machines which are bolted to the floor are not considered “fixed installations” in the EMC Directive and do not benefit from the exclusion. Entire structures are considered as “fixed installations” but the equipment installed in it is not. This makes sense when you consider that it would be very difficult to proclaim an entire facility as compliant to the EMC Directive 2014/30/EU because testing the entire facility as one unit would be impossible. The component assemblies (i.e., the machinery and systems in it) can be tested.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 855-652-7281 and are here to help you. you.

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