A Guide to the Ever-Changing World of Mexico’s Electrical Safety Regulatory Compliance Requirements

In our previous article, “Navigating Mexico Certification Requirements for Radio-Telecom Devices” (see In Compliance Magazine, July 2024), we outlined Mexican approval procedures for radio and telecom products from a radio-telecom compliance perspective. Separate from radio-telecom requirements, many electronic devices are subject to electrical safety compliance requirements. Fortunately, many of the organizations and processes involved in radio compliance are the same as the ones involved in safety compliance.

In this article, we will review the requirements for three safety standards in Mexico and the processes and actors involved in demonstrating compliance with those requirements. We will also explain how to obtain import documents for devices that fall outside the scope of the three standards. Finally, we will cover an important standard that is applicable to most electronic products regarding labeling, packaging, user guides, and warranties.

Key Players in the Compliance Process

Like the radio-telecom compliance process, Mexico has chosen a compliance regime for safety that is enforced at the border and, therefore, includes roles for importers and Mexican customs. The key players involved in the safety certification process include some of the same players as those involved in radio-telecom compliance:

• Manufacturers: These provide product documentation and samples (if required);
• Importers: They are the official holders of certificates and are responsible for importation;
• Customs brokers: Customs brokers assist in identifying the proper Mexican HS code and, when ready, get shipments through customs;
• Accredited test laboratories: Test labs must be accredited according to Mexican regulations. They perform tests to prove compliance with official Mexican safety standards (Normas Oficiales Mexicanas, NOMs); and
• Certification bodies (CBs): These are accredited entities that review and determine if a product’s test reports and other required documents associated with regulated products comply with the applicable NOM(s). They issue Certificates of Conformity (CoCs) and conduct any subsequent surveillance.

Product Analysis

Like the radio-telecom compliance process, enforcement of NOMs begins at the border as Customs requires CoCs or equivalent documents prior to allowing entry to the country. To give guidance to its inspectors, the Customs Service has a website that lists possible NOMs to be applied to products based on their HS Codes. Although the Customs Service has matched HS codes to NOMs, the database sometimes lists more than one NOM as applicable when only one applies.

An additional problem occurs when the database lists a NOM, but because the product qualifies for an exemption based on use or other criteria, the NOM is not legally applicable. To begin the analysis of applicable NOMs, Customs brokers normally confirm that the HS code used for a product is appropriate and then review the listed NOMs and provide their opinion regarding which listed NOM(s) apply. This analysis is then reviewed by a CB, which makes the final decision on which NOM(s) are applicable.

The Most Common Safety NOMS

The main objective of safety NOMs is to prevent risks to the health, life, and assets of the user, and compliance with them is mandatory. These technical regulations present the information, requirements, specifications, procedures, rules, attributes, test methods, guidelines, characteristics, or prescriptions applicable to a product and methodology that allow government agencies to establish measurable parameters. These standards are published and updated in the Official Gazette of the Federation (DOF), the official newspaper of the Constitutional Government of Mexico.¹

The following are the most common NOMs applied to electrical products.

• NOM-001-SCFI-2018, Electronic devices-Safety requirements and test methods²
• NOM-019-SCFI-1998, Security of data processing equipment³
• NOM-003-SCFI-2014, Electrical products-Safety specifications⁴

NOM-001-SCFI-2018, Electronic Devices-Safety Requirements and Test Methods

This official Mexican Standard specifies the requirements to reduce the risks of fire, electric shock, or injury for the operator and non-professional personnel who may encounter the equipment and, when specifically established, for maintenance personnel.

Scope of the NOM

• Electronic equipment and its accessories that use public service electrical energy (mains) for their supply, with single-phase supply voltages up to 277 V ac at 60 Hz and/or three-phase voltages up to 480 V ac between lines at 60 Hz, as well as other energy sources, such as batteries, accumulators, self-generation and alternative power sources up to 500 V dc.
• Common products, such as TVs, remote controls, electronic toys, speakers, video cameras, charging bases, and other miscellaneous items.
• New, discontinued, rebuilt, reconditioned, used, or second-hand electronic equipment.

NOM-001 Conformity Assessment Procedures

Every approval holder must be registered at a CB before starting the conformity assessment process. The actions of each actor follow:

1. Importer: After confirming the HS Code with a Customs broker and obtaining their opinion on applicable NOMs, an importer, or an authorized third party acting on its behalf, submits samples to test lab and application forms and other required documents to a CB.
2. Certification body: The CB can analyze the product and confirm which NOMs and certifications apply if the manufacturer needs confirmation. If more than one Model of a product line is included in an approval as a family, the CB will confirm that all models qualify.
3. Laboratory: An accredited laboratory tests the product and issues a test report for submission to the CB. (20-40 days, depending on the standard to test)
4. Certification body: The CB then issues a CoC for the applicable NOMs.
5. Extensions: Extensions of the main CoC to other importers are available without testing or additional samples under the following conditions:
   • The holder of the CoC must allow the extension to another company; and
   • The new approval holder accepts responsibility for the Certificate requirements.
6. Family approvals: Family formation of products is allowed, and multiple models can appear on the same certificate if they meet the following conditions (listed in Appendix B, B.1 of the Regulation):
   • Same brand and or manufacturer: 
   • Same type of electronic equipment and/or system;
   • The same supply voltage, frequency, and the same elements that make up the power supply, when applicable;
   • The equipment or systems must present the same electrical consumption or have a tolerance of 20% between the models with the highest and lowest consumption;
   • The insulating, thermal, and electrical materials must be of the same type and operating capacity; and
   • Mechanical fastening systems must be of the same type and strength.

Final approval: Unlike the radio-telecom approval process, which results in a certificate of homologation, the CoC is the final document and has a validity period of just one year and must be audited and renewed with additional samples and testing at the ninth month of the validity period.

NOM-019-SCFI-1998, Security of Data Processing Equipment

This official Mexican Standard establishes the security requirements for all peripheral data processing equipment or related equipment that is marketed in Mexico. It is under review as it is partly based on UL 478-1980 4a and other older safety standards. A project to update this NOM was published under PROYECTO de Norma Oficial Mexicana PROY-NOM-019-SE-2020, “Equipos de tecnologías de la información y sus equipos asociados, así como equipo de uso en oficina-Requisitos de seguridad (cancelará a la NOM-019-SCFI-1998 y cancela al PROY-NOM-019-SCFI-2016)” in the DOF. However, as of September 2024, no official NOM update has been published.

Scope of the NOM

• Portable electronic data processing machines, (laptop, notebook), microcomputers, personal systems, personal computers, network terminals (PC-net), servers, etc.
• Printers, plotters, external disk drives, external tape drives, digitizing tablets, image digitizers, optical readers, monitors, and terminals.
• Equipment used for electronic communication between data processing equipment and peripheral equipment, local area networks (LAN), such as concentrators, protocol converters or routers, etc.

NOM-019, Conformity Assessment Procedure, Extensions, and Family Approvals

The conformity assessment procedure of NOM-019 is the same as for NOM-001, except that just one sample is required instead of two, and the testing period of about 5-10 days rather than 20-40 days. Extension procedures and family approvals rules under NOM‑019 are identical to those of NOM-001.

NOM-003-SCFI-2014, Electrical Products-Safety Specifications

This official Mexican Standard establishes the characteristics and safety specifications that electrical products, which are imported or marketed, must meet, with the purpose of:

• Protection against dangers from the electrical product itself;
• Protection against dangers caused by the effect of external influences on the electrical product;
• Safe operation; and
• Information on the use and conservation of electrical products, marking and labeling.

Scope of the NOM

This standard applies to electrical products that use public service electricity for their power supply, as well as other energy sources, such as batteries, accumulators, and self-generation, in alternating current and/or direct current, with a nominal voltage of up to 1000 V in alternating current and up to 1500 V in direct current. Common products include tools and lawn care equipment.

NOM-003, Conformity Assessment Procedure, Extensions, and Family Approvals

The conformity assessment procedure of NOM-003 is the same as that applicable to NOM-001, except that the testing period is approximately 20-40 days. Extension procedures and family approvals rules under NOM-003 are identical to those of NOM-001.

NOM vs. NMX

Unlike NOM-019, which is self-contained, NOM-003 refers to various Mexican standards established by CBs (not the Secretary of the Economy), called Mexican Standards or Normas Mexicanas (NMXs). These include NMX-J-521/1- ANCE; NMX-J-524/1-ANCE, NMX-J-038/1-ANCE, and NMX-J-307-ANCE, which in turn have been based on the international standards IEC 60335-1, IEC 60745-1, IEC 60974-1, and IEC 60598-1, respectively. 

Super-Specialized Equipment

As mentioned above, it is possible that the Customs database may associate a NOM with a product that does not necessarily apply. One especially important example of a misapplication of NOM-019 to data equipment occurs with equipment that is only operated by professionals and meets the specialized criteria described on the NOM. Section 1.2 of NOM‑019 specifically excludes workstations, servers, fault-tolerant systems, enterprise systems, and other products from its scope.

Although these products are outside the scope, it is possible that Customs agents may mistakenly require a CoC. To avoid this problem, it is possible for an importer to request an expert opinion (“dictamen”) from a CB. Presentation of this document at Customs will allow a product to be imported successfully without a CoC.

Labeling-User Guide-Warranty Requirements

NOM Mark

Upon entering the Mexican marketplace, products certified to any of the three safety NOMs must display the NOM mark. Rules concerning the design, size, and placement of the mark are contained in NOM-106-SCFI-2017⁵. Section 2.4 of this standard states that there are options for the kind of label and its placement on the product as follows: 

“Any label, inscription, image or other descriptive or graphic material, written, printed, stenciled, marked, engraved in high or low relief, adhered to, superimposed or fixed to the product, its packaging or, where this is not possible due to the characteristics of the product or its packaging, to its packaging, or in digital format within the product software.”

Figure 1 of NOM-106 states that the minimum height of the logo, if printed, must be 2.5 mm (about 0.1 in) high. Further details regarding the physical characteristics of the logo, as well as conditions of use, are found within the standard. An example of a NOM mark is found in Figure 1.

Additional Labeling, User Guide, and Warranty Requirements

Most electrical and electronic devices are also subject to NOM-024-SCFI-2013⁶. This standard covers product information that must appear on the product or its packaging as well as describing the required user guide and warranty requirements. Like other NOMs, the Mexican Customs database may list compliance to this NOM alongside radio, telecom, and safety NOMs as a requirement for importation to the country. To demonstrate compliance, one must use an accredited CB to obtain a document called a “Constancia.”  The following documents must be provided to the CB as part of the approval process:

• Warranty in Spanish from the Mexican company that will cover it before the customer;
• User Guide in Spanish;
• Label; and
• Package artwork that shows brand and Model (since the rest of the information will be in the NOM-024 label that will be affixed on the package, it is not necessary to repeat this information).

Each of these items needs to show some minimum information to be accepted.

User Guide

A user manual must be in Spanish for it to be accepted by the certifying body in Mexico that will analyze the NOM-024 requirements. The manual can have other languages for global compliance purposes, but it must have a Spanish version at least detailing the following information to be compliant:

• Clear use instructions;
• Warnings (if applicable);
• Importer information (full company name, Registro Federal de Contribuyentes (RFC), equivalent to their Mexican federal tax identification), address and contact information);
• Brand;
• Model;
• Nominal voltage (in Spanish notation); and
• Invitation to read the manual.

Label

For the label, most of the information from the previous point will be repeated, including:

• Model;
• Product description in Spanish;
• Nominal voltage;
• Importer information such as full legal name, RFC number and address;
• Country of origin;
• Warnings (if applicable);
• Invitation to read the manual in case this information is not present in the manual; and
• Brand name.

Warranty

The warranty document needs to clearly show the following information:

• Brand;
• Model;
• Information with regards to where the customer can activate the warranty in Mexico;
• Validity of the warranty;
• Scope of the warranty;
• Procedure of fulfilling the warranty; and
• Importer information such as full legal name, RFC number, contact information and address.

Exemptions to NOM-024

It is possible to demonstrate that a given product is exempt from the need for a NOM-024 certificate, specifically if that product is not intended to be commercialized to the public, such as industrial machines that are only intended to be used in factories. To prove that a product qualifies for an exemption, one would need the following items to present to Customs:

• Copy of the contract that includes commercial, warranty, and installation information (mandatory); or
• Opinion letter issued by a CB stating that under their analysis the product does not fall into the scope of the NOM-024 (voluntary but highly suggested to avoid problems at customs)

Endnotes

1. https://www.dof.gob.mx
2. https://dof.gob.mx/nota_detalle.php?codigo=5572453&fecha=17/09/2019#gsc.tab=0
3. https://dof.gob.mx/nota_detalle.php?codigo=4902685&fecha=11/12/1998#gsc.tab=0
4. https://www.dof.gob.mx/nota_detalle.php?codigo=5394047&fecha=28/05/2015#gsc.tab=0
5. https://dof.gob.mx/nota_detalle.php?codigo=5496689&fecha=08/09/2017#gsc.tab=0
6. https://www.dof.gob.mx/nota_detalle.php?codigo=5309980&fecha=12/08/2013#gsc.tab=0