ITE Requirements Around the Globe

Sellers and importers of Information Technology Equipment (ITE) must comply with a vast array of hardware regulations when marketing their products in today’s world. The scope of hardware regulations includes the following basic disciplines:

• Product Safety
• Electromagnetic Compatibility (EMC)
• Homologation of wired and wireless telecommunication devices
• Environmental
• Chemical

Such regulations are established at many levels, including national, regional, state, province and even individual cities or towns. In many case, hardware regulations carry the force of law. Hence, a complete and in-depth understanding of the regulations applicable to any particular product is needed to avoid running afoul of the law. Being aware of all the regulations that apply to a product can be challenging enough, even before understanding all the details.

Regulatory Fundamentals

Regardless the discipline, all hardware regulations encompass a common set of basic elements.

• Technical evaluation (may include testing or engineering analysis)
• Documentation of results (test report)
• Conformity assessment procedures, including Declaration of Conformity (DOC), verification and certification
• Product and packaging marking
• Information to the user
• Market surveillance and on-going compliance

It should be noted that some regulations may not require explicit action on some of these elements. For example, certain regulations do not require a statement of compliance to be included in the documentation provided to the end user of the product.

The technical evaluation typically includes either testing a sample of the product against some defined standard or set of standards or an engineering analysis or assessment. Restrictions or rules on who can perform the testing or evaluation vary. In some cases, the test or assessment may be performed by the product’s manufacturer, while other regulations for the same basic discipline may require the use of an independent third party. If testing to standards is required, the lab performing the testing may need to be accredited by the regulatory agency or through a designated lab accrediting agency. With the wide possibility of requirements on who can perform the evaluation and what specifically is required or allowed, it is easy to see why an in-depth knowledge of the applicable regulations is essential for successful compliance.

Once the technical evaluation is completed, the results must be documented. The old adage of the work not being done until the paperwork is completed definitely applies in hardware compliance. Without adequate documentation of the evaluation, one cannot truly demonstrate compliance with the requirements. What product was evaluated? How was the evaluation performed? Who did the work, and were they properly qualified to do it? The list of content that must be included in a test report can be quite extensive. Consider the following example.

1. Test Report Cover Page stating the regulation the report encompasses
2. Test standard and test method that were applied and any deviations from the specified procedures
3. Classification of the product with respect to the regulation (for example, Class A or Class B for EMC emissions test results)
4. Description of the device being tested for approval, including marketing designation or model number
5. Product specification sheet describing its functions and capabilities
6. Functional block diagram
7. Specific identification of the device that was tested, including serial number and detailed list of all hardware content
8. Description of software used to exercise the unit being tested
9. Measuring equipment used in performing the test, including make, model, serial number and calibration details
10. Test results
11. Description of any changes made to the device during testing to meet the test limits
12. Photographs of the test setup
13. Photographs of the device being tested
14. Diagram of the physical arrangement and configuration of the unit tested
15. Drawing or photograph of the product label showing required marking(s) and location of label on the device

The conformity assessment procedures define the specific process steps that must be followed to satisfy the regulation and include things such as filing a report with an agency versus keeping it on file to be made available if requested.
These procedures can be placed into three basic categories:

• Certification
• Suppliers Declaration of Conformity
• Verification

Certification generally requires filing specific documentation (such as the test report) with the agency and receiving a certificate in return.

In a Suppliers Declaration of Conformity procedure, the supplier (typically the product’s manufacturer) completes a form attesting, or declaring, that the device complies with the required regulation. The method used for demonstrating compliance is often listed on the declaration. In same cases, the declaration is distributed with the product to the end user, while in other cases, it is kept on file to be made available upon request.

Verification is the simplest form of conformity assessment in which the supplier creates documentation to verify that the product meets the requirements. Typically, this documentation would be a test report that is kept on file and made available upon request.

Product marking involves placing a mark or statement on the product. Most often the marking is added to the product’s information label. Some regulations allow alternatives of placing the product marking on the packaging (such as the cardboard box) or in the user manual, but most require the marking on the product.

Information to the user is generally a statement that the product complies with the regulation. It may also include caution or warning statements describing types of locations where the device is, or is not, allowed to be used.

Market surveillance includes any activates undertaken by the authorities to verify that products being sold do, in fact, comply with all applicable regulations. These activities include checking products at retail outlets to ensure proper labeling as well as testing samples acquired from manufacturers, importers or retail outlets. Compliance verification by Customs officials at the time of importation is another form of market surveillance and typically involves document inspection to see if all the paperwork accompanying a shipment is in order.

EMC

Let us now explore EMC regulations around the globe.

A device’s ability to exist in its intended operating environment without causing electromagnetic interference with other electronic equipment (emissions) or without suffering undue interference from other equipment (immunity) is regulated in some 50 countries.

Fortunately for manufacturers, importer and other responsible parties, these regulations reference a much smaller set of common standards, as shown in Table 1.

Table 1: Common standards serve as the basis for global EMC regulations

This referencing of common standards substantially reduces the testing burden, although changes and revisions to the reference standards are not always adopted on uniform schedules by the various regulations. A recent example of the variations that can happen in adoption is the roll out of the CISPR 22 limits on radiated emissions between 1 and 6 GHz. Compliance with these limits became mandatory in October 2010 for the Republic of China (Taiwan), in March 2011 for the Peoples Republic of China, and October 2011 in Australia, the European Union and Japan. Now that the new CISPR 32 standard for emissions from multimedia equipment has been published, it will be interesting to see how the various jurisdictions incorporate the standard into their requirements.

With the use of these common standards to establish the test conditions and limits that must be met, the primary differences between various global EMC regulations are in the conformity assessment details. A sampling of these details is summarized in Table 2. Note that some regulations include multiple conformity assessment procedures, usually based on the type of product or product classification.

Table 2: Sampling of compliance details for EMC regulations

Conclusion

Many countries around the world have a variety of hardware regulations that must be met before ITE is marketed, sold or imported into those countries. These regulations exist for valid reasons and generally are intended to protect something: people, other equipment or the environment. For the most part, the technical details of hardware regulations can be met without placing excessive burden on the manufacturer, provided the requirements are understood at the start of a product’s design cycle. The most challenging aspect of complying with the regulations is often the conformity assessment process – the administrative details that need to be completed after the technical analysis or testing is finished. 

John Maas is Corporate Program Manager for EMC for IBM Corporation and has responsibility for IBM’s worldwide EMC regulatory compliance program. He has over 25 Years of EMC experience including hardware design and test. He has been involved in international standardization for much of his career and currently is active in IEC SC77B/WG10 and the US advisory groups for IEC TC77, SC77A and SC77B and CISPR/I. Mr. Maas can be reached at johnmaas@us.ibm.com.