We are just starting to sell our machines outside of North America and we are confused by all of the different and often conflicting electrical and automation standards and regulations. For example, should we conform to the highest and most costly standards so that we can make one version of our machine, or should we have different machines for different jurisdictions? What are the European and Asian equivalents to UL, NEC, and NFPA? What about WEEE and RoHS? Where can we go for help?
--From February 2007 Control Design
One Way or Another, You Need Expertise
When considering markets outside North America, it always is a challenge to understand the different standards that apply. Europe, Asia, South America, and Australia all have rules that are generated for the protection of society, markets, or the power grid. Which standards that one strives to meet will certainly impact ones cost and profit margins.
Many countries do have unifying standards or recognize standards that exist in other countries. IEC (International Electrotechnical Commission) and CE have many standards that overlap. It always should be a goal to meet the standards of the country that the system is manufactured in, but will it be necessary to meet the standards of the country into which one sells?
UL and CE are the usual requirements for electrical components used in a machine. If the machine is manufactured and used in the U.S., you might be required to meet UL certification. Should the intended market be Europe, you likely will have to meet CE requirements, and perhaps some unifying IEC specifications. Some of the CE requirements for machines--like safety EN60204--might put a burden on the motor/drive combination in a servo-driven machine.
Selecting suppliers that meet the criteria of your market will ease the burden of documentation and testing. If you wish to sell to Europe, you either test to this criteria or use products that already are so marked. Care, however, must be taken to avoid the appearance or actuality of selling a machine that is inherently safer to another market than the domestic product. This can be perceived as a trade violation. If the machine meets EN60204 safety in its exportable format, then it likely needs to meet this domestically as well.
IEC standards are recognized by many of the countries to which a domestic manufacturer might be exporting. The problem is that many such standards exist and can be left to some interpretation. This is why having a supplier that meets and understands the standards, or having that expertise yourself internally, is vital. If you are interested in opening up your markets, you need to familiarize yourself with the governing bodies that control them.
A good place to start would be the information on CE requirements. This is required of all products sold within the European Union and includes most of the European Free Trade Agreement (EFTA) areas. RoHS, (Restriction of Hazardous Substances Directive) is being adopted by many countries. The first thought, of course, is lead, but this pertains to many substances deemed environmentally unsafe and is a way to restrict products manufactured without proper and equal compliance from entering the country.
It is not so much a deterrent as it is a leveling of the field. If a country is allowed to mishandle hazardous materials within its borders, it sometimes can manufacture cheaply with no environmental handling expenses. Eliminating these materials is both environmentally sound and prevents any advantages due to differing internal structures and laws in different countries.
Within the U.S., the UL and National Electrical Codes are the governing bodies. Should your desires remain stateside, compliance to these should suffice. Canada’s governing body is CSA (Canadian Standards Assn.) and compliance is required for entry into the Canadian markets.
To bite the bullet and take responsibility of these compliance requirements is a full-time task. Recordkeeping in the form of Technical Construction Files (TCFs) must be available for proof of compliance. There are electromagnetic directives (EMI), low-voltage directives (EN50178), safety directives, and others too numerous to list. There are levels of compliance to further complicate the process.
A department usually is required for the testing or supplying of materials to various licensed facilities to conduct the compliance tests and allow the placement of the CE mark. I reference the material in our own compliance department a significant number of times during the course of a year. When the information is asked for, it’s expected in a timely and organized format.
The decision to export requires compliance to regulations, and you can meet this requirement by undertaking the process yourself or by selecting vendors with compliant products. Either way it changes the way to do business.
Lee Stephens, systems engineer, Danaher Motion, www.danahermotion.com
Some Directives Have Limited Scope
Many people in industry and the industry press do not understand the limited applicability of the European WEEE (waste electrical and electronic equipment) and RoHS directives. Both directives specifically exempt “large-scale stationary industrial tools”. The UK’s “Government Guidance Notes” of November 2005 clarifies this category as “a machine or system, consisting of a combination of equipment, systems, products and/or components, each of which is designed, manufactured and intended to be used only in fixed industrial applications.”
In addition, "monitoring and control" electronics, whether installed in these "large-scale stationary industrial tools" or not, specifically are exempted from the RoHS directive.