Inspectors play a key role in the implementation of the North American Safety System and the job is not easy. In addition to being the enforcer of the electrical installation code, the inspector must also determine if electrical products are acceptable for use. To do this, the inspector typically relies on some method of conformity assessment. Recently, there has been a significant increase in questions from inspectors about CE Marking and its acceptability as a method of conformity assessment in North America. Typical questions include… What is CE? Is it like UL? Who is CE? Am I supposed to be accepting CE? The material in this paper is intended to shed some light on such questions.
OK, So what is CE?
Nineteen countries1 in Europe decided that in order to have “free movement of goods and to promote a common level of safety” among their countries, these goods must have a mark that indicates conformity to the “common level of safety.” This marking is the CE Marking. Keep in mind that this “common level of safety” is for these European countries and is laid out in the European Union (EU) Directives. The CE marking is also applied to products outside the electrical industry, including toys, furniture, etc. The CE marking has nothing to do with North America or the North American safety system.
Where is the CE lab located?
CE is not an entity, a mark of conformity to a standard, a quality mark, or a certification organization logo. It is a marking for the EU authorities. There is no laboratory, certification agency, etc., associated with CE Marking. It is simply a marking applied to indicate conformance to a common set of essential requirements for nineteen countries in Europe.
How does a product get a CE Marking?
In general, the manufacturer can apply the marking and by doing so is self-declaring that the product meets the essential requirements laid out in the EU directives. In essence, this is a form of supplier’s declaration of conformity (SDoC) to the directives. The process for the manufacturer to determine compliance can vary from one product to the next and can be complicated, depending on the product. There are many excellent documents available to manufacturers that discuss the specifics of this process.
How does the CE Marking impact products sold in North America?
It doesn’t. The existence of the CE Marking has no bearing on whether or not the product complies with the appropriate standards in North America. The marking only indicates that the product meets the essential requirements mandatory in the member states of the involved European Community and allows free movement in the community. There are many products that meet the appropriate North American standards and are listed by acceptable laboratories. These products may also carry a CE Marking. However, these are separate issues. The product must meet the appropriate North American Standards to carry the listing mark (UL, CSA, ETL, ANCE, etc.). Separate from that, the same product may also be designed to meet the essential requirements of the EU directives and would be permitted to have the CE Marking for that reason.
As an electrical inspector, should I be accepting CE Marking on electrical products as suitable for installation in North America?
No. Unfortunately, inspectors are being told differently in the field. Many are being told that CE Marking is equivalent to UL (or similar marks of conformity) and that they must accept that CE Marking on the product installed in North America. This has led to significant and varied discussions on the issue. The bottom line is that CE Marking means nothing for products installed in North America and statements to the contrary only add confusion. The inspector needs some method of assurance that the product meets the appropriate North American standards.
Since the product is acceptable in Europe, isn’t it acceptable in North America?
No. First, keep in mind that CE Marking only indicates that the product can move freely throughout the European Community, it does not guarantee that it will be accepted locally in those countries. Furthermore, the standards in Europe and North America are different. The approaches to an Electrical Safety System are also different. With different safety systems and different product standards being used, you simply cannot assume that a product installed in one system can be safely applied in the other.
What should I be looking for?
Inspectors should look for what they always have. Some method of conformity assessment that is acceptable to your locality and will provide you with the confidence that the product meets the product standards appropriate for North America. For many, the typical method of conformity is third-party certification (listing) by a certification agency accepted in your locality. By having products that meet the product standards accepted in the country where you are inspecting, you can alleviate much of your concern as to whether the product is compatible with the electrical installation code being enforced.
1 There are sixteen countries actually in the EU, but three additional countries (Iceland, Norway and Liechtenstein) have also agreed to the CE Marking scheme.