My Product Line Went to Hazard Based 62368‐1 and All I Got Was This Lousy CB Report

The objective of this article is to offer an alternative to the CB route of compliance to meet the new European safety standard EN 62368-1, Audio/video, information and communication technology equipment – Safety requirements, for equipment having an existing IEC 60950-1 CB certification.

The European Union (EU) has extended the mandatory implementation date of the new hazard-based standard, EN 62368-1, to December 20, 2020. This means that information technology equipment (ITE) shipped into the EU after this date will require compliance to the new standard whether, it is currently certified or not (i.e., no grandfathering). For companies with many products required to go through transition, this can be an expensive and time-consuming process.

In this article we will compare two methods of upgrading products to the new hazard-based requirements of the Low Voltage Directive (LVD). The aim is to analyze whether the potential benefits of an alternative compliance route can outweigh those of the more conventional method. The two methods in question are:

• Conventional update of existing CB Scheme certifications (CB update approach); or
• Alternate path of producing new LVD reports (LVD report approach)

The LVD is part of the EU’s CE marking platform. No matter which method you chose to demonstrate compliance with the LVD, the CE mark rules mandate, for all practical purposes, that the manufacturer self-declare compliance with the requirements. This means that, even if a CB-certified body triple stamps the certification documents, the responsibility of conformity with the LVD still rests on the manufacturer, i.e. self-certification.

Many ITE manufacturers routinely obtain CB Scheme certifications for their products. The main advantages of CB certification are:

1. Can, generally speaking, be relied upon to declare compliance to the EU’s LVD;
2. Can serve as a “passport” for other international certifications;
3. Relative ease of a tried-and-true certification process (for most types of computer-related equipment); and
4. When bundled with NRTL (e.g., UL, CSA, MET) certifications for the U.S. and Canada, does not add significant cost to a project.

The passport concept implies that CB certificates can be “easily” leveraged to obtain other international certifications. (More on this idea to follow.)

An EU-compliant LVD report is similar to a CB report, except that it is exclusively used to declare compliance with the EU’s LVD. Another advantage of the LVD report is that it can be produced by anyone from a CB certification body to the manufacturer of the product in question.

Bundling Issues

In instances where a product must be upgraded to meet the EU’s new requirements, some of the advantages mentioned above for CB scheme certification are negated. Take bundling for example. The U.S. and Canada have also adopted the December 20, 2020 implementation date of the new hazard based standard. But, unlike the EU where compliance becomes mandatory, NRTLs will only require that new products and products that have undergone significant changes comply with the new standard.

This means that if a current product remains the same, in basic layout and function, the existing NRTL certification to UL/CSA 60950-1 should not need to be updated. Without the NRTL bundling, the cost of CB certification alone becomes significantly higher.

Not as Easy as it Used to Be

Another area where the CB update approach is marginalized is in the ease of the certification process.  One must keep in mind that not only is this process new for manufacturers, it is also new for certification engineers. These engineers do their best to apply the requirements of the standard, but they are human and mistakes can occur. By the time most manufacturers fully commit to updating their existing products, the deadline-fueled influx of work will require that testing laboratories take an “all hands on deck” approach. Consequently, manufacturers run a considerable risk of being assigned a project handler who may misinterpret the new requirements.

Further, any non-compliances found during a CB evaluation must be corrected to the CB body’s satisfaction, regardless of actual validity. The back and forth communication to resolve these perceived non-compliances will waste valuable time. In general, since the LVD report approach is strictly used for self-certification purposes, it allows the manufacturer greater involvement and accountability for the certification process and enables projects to be completed in shorter time frames.

Because the LVD report does not require the exclusivity and overhead of a CB certification body, the cost and time to obtain one can be significantly less.

Is Your New Passport Accepted?

To complicate matters, the EU upgrade upheaval pulls the rug out on the CB passport concept. The main advantage of a CB Scheme is the ability to leverage the certification to gain approval in certain international markets. Currently, many international markets do not accept the 62368-1 base standard and most are uncertain as to when they will accept it. This means that a CB Scheme certification issued against the new standard may not be accepted as a “passport” for some time after the transition date, while existing CB certifications would still work. For example, if China does not convert IEC 62368-1 into an official Chinese GB standard, a CB report to that standard will be useless in obtaining Chinese CCC certification, while the existing CB scheme to IEC 60950-1 would still provide value.

When and Where is Your CB Certification Really of Value

You may be thinking, “What if I upgrade my existing product line using the LVD self- certification route instead of CB certification, and subsequently international markets to which I sell adopt the 62368‑1 base standard? Will I have to upgrade to a new CB certification at that time?” This question requires some explanation regarding the value of the CB report as a passport. In general, no certification body requires CB certification as a pre-requisite to obtaining their national certification, and the value of submitting a CB certification varies greatly from Certification Body to Certification Body. Some country Certification Bodies will accept CB reports carte blanche, and some will only use them as a reference. Using a server as an example, Table 1 indicates the relative benefit of a CB certification in obtaining some common international certifications.

*Notes:

1. International compliance rules are ever changing. The chart above is a snap‐shot in time given current conditions (9/2018).
2. CB Benefit rating takes into consideration cost and time savings of certification along with the requirement to ship samples to the destination country.
3. The information in the chart above is based on the authors experience and may not be indicative of all experiences in the same region.
4. Different product types, such as audio/video or other office equipment, may yield different results; for this reason, it is recommended that similar analysis be conducted for other product types and countries

Table 1: CB benefit analysis chart for ITE server

Conclusion

As shown in the table, a CB scheme certification offers varying degrees of benefit. If one is shipping to countries that have a CB benefit rating of three or four stars, it may make sense to upgrade existing CB certifications in the anticipation that it is currently or will soon be accepted in those target markets. If, on the other hand, one is shipping to countries with no stated safety requirements or those identified with a one or two-star benefit rating, it may make more sense to proceed with the LVD report option and address other international certifications on a case-by-case basis.

Should you upgrade existing CB certifications or go with a new LVD report?  Hopefully this article has shed some light on which method will best serve your needs, and how you might potentially save some time and money using the road less traveled.

References

1. Official Journal of the European Union, http://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/low-voltage
2. UL Webinar – “The Global Transition to IEC 62368-1,” June 22, 2018
3. Quick Access to Global Markets, http://www.tuv-sud.com/home-com/resource-centre/publications/white-papers-e-books/globalmarketaccess

Paul Milton has been managing product certification programs for over 25 years.  He works for G&M Compliance, Inc., who specializes in Homologation management services, offering certification solutions and providing unique outsourcing services.  Paul can be reached at paul@gmcompliance.com.