The CE Mark: Impact on Low-Voltage Electrical Equipment and Components

Dubravka Kusmic and Michel Hodak
A clear path can now be set for achieving a CE mark on low-voltage products.

Photo by RONI RAMOS

With the advent of the CE mark, many North American original equipment manufacturers (OEMs) wrestled with compliance when attempting to export to Europe. They often inquired about CE marking on components that they had incorporated into or wished to incorporate into their finished product. Many OEMs often interpreted the impending requirements for a CE mark on the final assembled equipment to mean that the same requirements were applicable to its components.

This misinterpretation is understandable. Many were familiar with Underwriters Laboratories certifications, which require the use of UL-recognized components. Similarly, the Canadian Standards Association requires the use of CSA-listed parts. It followed that North American OEMs would assume that that a CE mark would be required on the components in order to obtain a CE mark on the final product.

However, CE mark documentation explicitly lists many component types that are not to bear the CE mark. In other words, putting the CE mark on certain components is actually not allowed, and not to be done. Unfortunately, many component manufacturers simply slapped the CE mark on their labels, products, and catalogs anyway.

The European Union (EU)

The EU expresses its rules in four ways: regulations, directives, decisions, and recommendations (opinions). A directive in the EU is a European law that is legally binding for every member state and is above the laws of the individual member states. A directive is not aimed directly at the citizens or companies in the member state. The member states as of January 2003 are Austria, Belgium, Denmark, Finland, France, Germany, Greece, Republic of Ireland, Italy, Luxembourg, The Netherlands, Portugal, Spain, Sweden, and the United Kingdom. There are numerous directives involved in CE marking legislation.

The CE Mark

CE stands for Conformité Européenne, a French term that can be literally translated into English as European Conformity. The foreword to CE Marking, The New European Legislation for Products, by Kluwer Business Information, states in bold as a first paragraph:

The CE Marking offers great advantages to trade and industry in the United States. The new European legislation has created a uniform market within Europe. Up to now, American manufacturers and exporters have had to deal with various sets of national legislation within Europe. Thanks to the introduction of CE Marking, the trade constraints between Member States of the European Economic Area (EEA) have disappeared. The CE Marking forms, as it were, the "trade passport" for products within the EEA.

The elaboration of risk assessment, the protection of the users, and the prevention of injury due to use, misuse, or abuse must be handled with due care. These steps require formalized recordkeeping, information dissemination, and optimized design practice respecting appropriate standards and regulations. Such due diligence involves the cognizance, evaluation, and optimization of health, safety, human, durability, regulatory, and environmental factors using accepted methods, guidelines, and laws.

Numerous directives have issued the CE mark legislation. See Table I for a list of EU directives taken from the Web site http://www.newapproach.org.

Directives

This article focuses on the Low Voltage Directive. However it is worthwhile to briefly discuss the Machinery Directive and the Electromagnetic Compatibility (EMC) Directive.

Machinery Directive. This directive is written so as to promote the design of machinery that is as safe as possible. According to the directive, "The result must be the safest possible machine in accordance with the current status of technological development." This directive applies to machines as per Article 1 Section 2 of the Machinery Directive. It also applies to separately marketed safety components. Machines are generally defined as devices with at least one moving part, containing actuators, control, and power circuits. The directive is concerned with safety, and it is not concerned with other aspects of performance.

Exceptions to the Machinery Directive are machines listed in Article 1 Section 3. Other exceptions include machines in which the main risk is of electrical origin; in that case, only the Low Voltage Directive would apply. Although in general the CE mark may be affixed to machinery by the manufacturer, manufacturer's authorized agent, or importer, there is a very important exception: machines with increased risk must be treated by a notified body as per Annex IV of the Machinery Directive. In general, this exception covers presses, cutting devices, lifting devices, vehicles, rolling machinery, and some other machinery and safety components. Because of their strength, mass, movement, squeeze points, or sharpness, such machines can injure people.

EMC Directive. This directive has also been written in such a way that it is the end result that is targeted and not the way to achieve this end result. According to the directive, "The EMC Directive sets the essential requirements for all electrical and electronic equipment that may interfere with other equipment or that may be interfered with by other equipment." The idea is that electrical devices transmit electromagnetic radiation into the environment. The intensity and reach of these emissions depend on the power levels, frequencies, and construction of these devices. As frequencies get faster, wavelengths get smaller and enclosures, cables, and circuits start to behave as effective antennas. High power levels, defective components, poor enclosures, and long cables also can cause interference.

Similarly, equipment can receive electromagnetic waves and, depending on the susceptibility of the device and type and intensity of the waves received, the device could malfunction. This is of particular concern to medical, communications, and other critical equipment. The directive states, "The result must be a device that cannot be disturbed by electromagnetic interference and that in itself limits the generation of interference in such a way that the other equipment is not disturbed by it. Moreover, the free movement within the European Union of products complying with the EMC Directive must be safeguarded."

Low Voltage Directive. This directive sets the requirements for electrical safety of electrotechnical products. It was written in a general way without elaborating technical details in the directive. The directive states, "The objective of the Low Voltage Directive is only to permit electrical material to be put on the market if it does not jeopardize the safety of persons, domestic animals and goods. The freedom of movement of safe electrical material within the Community must be safeguarded." This directive comprises a general introduction, 14 articles, and 4 annexes. Low voltage for the purposes of this directive is defined in Article 1 as any electrical equipment designed for use with a voltage rating between 50 and 1000 V for alternating current and between 75 and 1500 V for direct current, other than the equipment and the phenomena listed in Annex II. A product has been fabricated according to the rules of good craftsmanship if it complies with the appropriate European harmonized standards. What this means in practice is discussed later in this article.

Regulatory Bodies

The authors have had positive and effective experiences with all regulatory and testing bodies, including UL, CSA, VDE, SEV, and DEMKO, among others. Their experiences with testing agencies such as TÜV have also been positive. It is important to remember these bodies or agencies. They have offices throughout the world and often represent each other to execute various pertinent activities such as audits, product certifications, and testing.

European agencies such as VDE, SEV, and DEMKO are, in general, harmonized to EN standards, and EN standards are often similar or identical to IEC standards (chicken and egg story here). As such, the use of components (terminal blocks, connecting devices, switch and control gear) certified (listed or recognized) by these agencies greatly eases the process of CE marking an OEM's final product.

The two North American agencies—UL and CSA—often have agreements with European agencies to do European testing and CE marking under suitable mandates. Likewise, TÜV does this with its facilities located in North America, Europe, and worldwide. Although there is no obligation to apply standards, it is certainly better to do so. Not using standards creates an enormous amount of work. Without them, it must be demonstrated in the technical documentation that the product meets the requirements of the directive. It would be impractical to turn the CE marking of an appliance, instrument, apparatus, or machine into a testing program for individual components.

The best path is to use and correctly apply components that have already been tested to the appropriate EN standard by an agency that keeps records in Europe. The certifying inspector applying the CE mark would recognize these. Naturally, some components are more critical than others, so it is wise to expect the certifying body to place more-stringent demands on such components. Table II provides a list of some key standards as well as some of the testing and regulatory agencies and bodies.

This article reviewed the CE marking process in light of the authors' pertinent experiences involving the CE mark, the associated directives, and the regulatory, testing, or standards bodies involved. Knowledgeable experts are available to guide manufacturers and component suppliers through the process. Many resources are available to alleviate the fears of a few years ago.

Regulations and evaluation technologies are always in a state of flux, and most of the smoke seems to have cleared with regard to terminal blocks, components, and the Low Voltage Directive. The free movement of goods, the safety of people, and the issues of cost continue to be of interest.

Acknowledgment

The authors wish to thank SWBC, the Organization for the European Conformity of Products, and Kluwer Business Information, publishers of CE Marking, The New European Legislation for Products.