I started this thread with a question regarding Certifications in Russia.
Thank you to all those who have replied. Let me just summarize what I have learned. For instance, it appears that the NVLAP certification of the test lab that performed our EMC and Safety testing probably won't help us. It would cost us approximately the same to go through a CB or NRTL to "re-certify". We are going through with the direct "re-certification" through Gosstandart for the eight products in question. I have had many people recommend to me that I get my products certified by a CB in the future in order to preclude this cost. Back when I first compliance tested the products, I sent out for competitive quotes. The ones that I received back from CB's were $3,000 to $7,000 higher and included longer delays. At the time, our major concern was CE for Europe and C-Tick for Australia. Australia has MOU's signed that accept NVLAP and A2LA accreditation. CE marking for Europe allows the manufacturer to CE mark with a Declaration of Conformity. Along with this freedom goes the responsibility of facing stiff penalties if we make non-compliant product. (I am by no means telling people not to use a CB, I am just saying that there are monetary, time and quality trade-offs in any purchasing decision.) So, I went with a lab that was NVLAP accredited. I didn't pick them soley for cost. I had quotes from some labs that were even lower. The main partners in the lab have been involved extensively with contributing to and writing US and IEC EMC procedures. I thought that I got the best quality of data per dollar spent with this lab. We then documented our test results and made our Declarations of Conformity. For some time, we were able to sell into Russia with the Declaration of Conformity. Now, we are facing the re-certification effort. Even with the re-certification cost included, we will probably break even (cost-wise) by not going to a CB in the first place. However, there may be increased hassle. I believe that we have been caught in a true "pay now" or "pay later" scenario. We're just paying later. Now, however, I just have to hope that another country doesn't decide to flex its regulatory muscle by enforcing requirements without accepting NVLAP certification. Would they accept the data collected by the Gosstandart certification? I just have to hope so. I have also learned that, even if I had used a CB in the first place, it may cost me on the order of a couple thousand dollars to have my CB interact with this new regulatory regime in order to get my CB's data accepted. After this experience, I really appreciate the efforts of the Australian Communications Authority and CENELEC. Using Australia as an example, when they instituted the Framework for EMC, they did their homework by having MOU's in place BEFORE the implementation date of regulations. They also based their standards on existing IEC standards to minimize re-testing for CE marked products. They then put a "Handbook for Suppliers" on the world-wide web. I was able to download this handbook, follow it and meet their requirements. I felt welcome to bring a quality, well-tested product to Australia. We are already doing business in Australia. Australian citizens that we employ there as our reps and distributors are making a living off of selling our product. The Australian communications system is getting the benefit of being tested by our high quality test equipment. It's good for us, It's good for Australia. I think its an example of how the IEC standards can be used to improve product quality and safety while allowing the free flow of goods. I hope that other countries follow suit and only implement their own wrinkles on the regulatory requirements if they can justify it on the technical grounds of increasing product quality and/or safety. > -----Original Message----- > From: Grant, Tania (Tania) [SMTP:[email protected]] > Sent: Wednesday, March 22, 2000 5:26 PM > To: [email protected]; '[email protected]' > Subject: RE: Certification of Products and other emerging countries > > > Careful, George! > > I agree with your term "Emerging standards". However, you must not have > been familiar with IEC standards until very recently. > > IEC standards, during the "iron curtain" time, used to be published in > three > languages on the title page: French, English, and Russian. Then, you > had > a choice whether you purchased the French/English version, or the > English/Russian version, etc. > > In fact, I noted that when the Soviet block began to disintegrate, did the > Russian titles disappear. Could have been a coincidence, or not. I > just > don't know. What I am saying here is that, as far as the IEC > organization > is concerned, Russian (in whatever political format) participation was the > rule, not the exception. > > I also don't agree with your historical assessment that "....under > Communism these countries had little dealings with the Western world, ..." > In fact, the Soviet block countries had a lot of dealings with the > Western > world, some of which we did not appreciate or want. But these are > political issues. And, by the way, I am not and have never been a > Soviet > "apologist"; however, it does bother me when history is not portrayed > correctly. > > Tania Grant, [email protected] <mailto:[email protected]> > Lucent Technologies, Communications Applications Group > > > ---------- > From: [email protected] [SMTP:[email protected]] > Sent: Wednesday, March 22, 2000 6:21 AM > To: [email protected] > Subject: Certification of Products and other emerging countries > > > Dear ??? > > Perhaps "emerging countries" is not the best terminology. > "Emerging standards" may be more appropriate. First of all, > there is the Commonwealth of Independent States, formerly > the USSR. For some 50 years under Communism these countries > had little dealings with the Western world, but are all now > at some point in developing standards to participate in the > global market. Russia, Belarus, etc. > > Then there are the former Soviet Bloc countries, sometimes > called Eastern Europe, such as Poland, Czech Republic, Hungary, > etc. Many already have well developed approval processes, > but some, such as Poland, can be very difficult to completely > satisfy at times. The good news here is that several of these > very much want to join the European Union, and may even accept > the CE marking in the near future prior to membership. > > Japan has long been a well developed nation, but has no product > safety certification requirements for typical ITE product, and > only voluntary (VCCI) requirements for EMC. Meanwhile, China > and Taiwan have relatively recent certification requirements for > ITE. > > Argentina only recently began to require IRAM certification for > ITE. > > The bad news is that there are still many countries that do not > now have certification requirements, but will probably adopt some > within the next decade. > > If you don't like change, Product Safety and EMC are the wrong > fields to be in at this time. > > George Alspaugh > > ---------------------- Forwarded by George Alspaugh/Lex/Lexmark on > 03/22/2000 > 09:04 AM --------------------------- > > rc%[email protected] on 03/21/2000 08:21:01 PM > > Please respond to rc%[email protected] > > To: grassc%[email protected] > cc: emc-pstc%[email protected] (bcc: George > Alspaugh/Lex/Lexmark) > Subject: Certification of Products and other emerging countries > > > > > Dear Charles, > > REGARDING: > ......the emerging countries have been very erratic in the implementation > and enforcement of EMC legislation....... > > The emerging countries are quite numerous, can you come up with some > actual > examples? > > "Grasso, Charles (Chaz)" <[email protected]> on 03/22/2000 > 02:43:36 > AM > > To: Rene Charton/TUV-Twn@TUV-Twn, Kevin Newland > <[email protected]> > cc: [email protected] > Subject: RE: Russian Certification of Products and other countries > > It has been my experience that - with the > exception of the EU and Aus/Nz - the emerging > countries have been very erratic in the implementation > and enforcement of EMC legislation. > > Rene, I must disagree with your comment regarding > scheduled implmentations. Putting incomplete > EMC enforcement/legislation in to force on schedule > is NOT good planning. Kudos to the EMC Framework - that > EMC legislation was advertised and compliance methods > available well before the required date. > > If only it were true universally... > > -----Original Message----- > From: [email protected] [mailto:[email protected]] > Sent: Wednesday, March 15, 2000 5:34 PM > To: Kevin Newland > Cc: [email protected] > Subject: Re: Russian Certification of Products and other countries > > What about > > Japan, Australia&NewZealand, South Africa, Argentina, Mexico....... > > In many Asian Countries (Taiwan, China, Korea, Hongkong.........) rules > are > just being set up. This implies that there are frequent changes, but not > on > daily basis. > > And changes are implemented according to a schedule. Can you show me a > similar schedule for the "stock exchange"? If you can, I will change my > Job > immediately. > > Rene Charton > > > Kevin Newland <[email protected]> on 03/16/2000 06:59:11 AM > > Please respond to Kevin Newland <[email protected]> > > To: "Maxwell, Chris" <[email protected]>, "'EMC-PSTC Internet Forum'" > <[email protected]> > cc: (bcc: Rene Charton/TUV-Twn) > Subject: Re: Russian Certification of Products > > Chris, > > Just remember that with the exception of Western > European countries,USA and Canada, the rest of the > world (without being rude) have not really have a > solid rule for anything. These countries rules and > regulation changes daily (just like stock exchange) > without any notice or explanation). This is sadly the > real life and we live in it. > > Thanks > Kevin > > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > To cancel your subscription, send mail to: > [email protected] > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Jim Bacher: [email protected] > Michael Garretson: [email protected] > > For policy questions, send mail to: > Richard Nute: [email protected] > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > To cancel your subscription, send mail to: > [email protected] > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Jim Bacher: [email protected] > Michael Garretson: [email protected] > > For policy questions, send mail to: > Richard Nute: [email protected] > ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: [email protected] Michael Garretson: [email protected] For policy questions, send mail to: Richard Nute: [email protected]
