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CE Marking Fans

1. STAGE DESCRIPTION CE marking represents a passport for selling fans into Europe and to other countries where it is recognised but it does not guarantee that anyone will buy the product Before making any attempt to obtain it therefore manufacturers must identify potential markets and verify that their products will meet market needs Section 3 2 All manufacturers must operate a production control system to guarantee the conformity of their products Although not compulsory an ISO 9001 2008 system certified by a reputable third party is recommended Section 3 3 1 Identification of markets 2 Operation of factory production control Possibly the most important and time consuming of the tasks Manufacturers must prepare technical documentation which includes a description of the product s the production system the production control system the marking labelling and user information and how the product meets regulatory requirements Section 3 4 3 Preparation of documentation All products to be CE marked require testing This may involve testing by a notified test laboratory based in Europe and or testing by an accredited test laboratory in Pakistan If a Notified Body is involved screening tests in Pakistan may help remove some non conformities in advance Section 3 5 2 and 3 5 3 4 Submission of products for testing Screening tests and tests by a Notified Body may well show up defects and other 5 Correc
2. It is important that manufacturers check the website above to ensure that they are applying the most recent version of the standard s which is a legal obligation In addition if either of the two standards for fans is changed technically and therefore the new version would be listed on the website manufacturers have to apply the new versions and this may well require new testing As already stated in Chapter 1 the LVD does not require the intervention of a Notified Body for the testing of electrical and mechanical safety But as also stated there is a market requirement on manufacturers to use a Notified Body and so for the rest of this Guide it is assumed that manufacturers will do so How a Notified Body can be selected is described below 2 3 TheElectromagnetic Compatibility EMC Directive The EMC Directive ensures that electrical equipment neither emits high levels of electromagnetic radiation nor is it affected by external electromagnetic radiation This is expressed by the following requirements Protection requirements Equipment shall be so designed and manufactured having regard to the state of the art as to ensure that 05 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS a the electromagnetic disturbance generated does not exceed the level above which radio and telecommunications equipment or other equipment cannot operate as intended b it has a level of immunity to th
3. is currently made up of 28 Member States with a combined population of approximately 500 million people The EU is a well developed market but one which has high levels of safety consumer protection and quality as its basis All Member States operate as part of a Single Market which means that any product which has been shown to be safe in one place and at one time can be placed on the market of all Member States without restriction and without any retesting or re evaluation This provision applies just as much to products entering the EU from third countries as it does to products made in Europe as long as these products meet all EU requirements The fact that a product is safe is usually demonstrated by it bearing the CE marking which is why the CE marking represents the passport which allows products to be sold in Europe Safety is a wide term which covers a number of different aspects These include absence of risk of personal injury for fans this includes avoidance of contact with moving and or live parts performance in use for fans this includes tests such as overload performance in high temperatures and the operation of thermal cut outs It also includes the degree of protection offered by the product and avoidance of electro magnetic hazards durability environmental performance this includes rated power and noise levels absence of dangerous substances certain substances such as lead are banned or
4. the regulatory requirements on fans appear to be stable and unlikely to change immediately But to give examples of how requirements can change the ROHS requirements for fans only entered into force in July 2011 while the Eco design Directive did not start to apply to fans until January 2013 Manufacturers need therefore to remain aware of all applicable regulatory provisions and also of any changes to the harmonized European Standards This section of the TF needs to contain all of the directives which apply to the product and to show how the manufacturer complies with them When as is assumed in this Guide to be the case conformity is based on the application of harmonized European Standards these standards need to be listed here and in the case of the LVD the clauses of the standard which are applied also need to be listed When listing the clauses of an LVD standard as is done in the example Technical File in Annex 1 itis better to list all requirement clauses in the standard and then indicate any which do not apply By listing all clauses it is clear that no requirement has accidentally been overlooked If a fan is intended for tropical conditions 40 C or above this should be mentioned here The name and address of the body ies used to perform the type approval ROHS and Eco design tests appear in this section When the first draft of the Technical File is being prepared and the names of the bodies are not known this informatio
5. 1604 12 D 1605 12 E 1606 12 F 1607 12 G d material colour and thickness and e material delivery report certificate Accepted materials components are delivered to storage rejected materials components are returned to the supplier giving the reasons for rejection iii Motor and blade assembly Electrical steel sheet Thermal protector Body Insulating bushing Plastic material Single core wire Paint Rotor Copper wire Insulation paper Silicate sleeve Plate Bush Tie lock Axle Screw RH Switch Power cable After moulding blades are weighed and sized and are then segregated to provide optimum balance The rotor unit is pressed as one from electrical grade steel and is visually examined before being machine wound Connections are made by manual soldering and all units are tested prior to assembly After assembly including bearings the unit is tested for functionality and correct performance Defective units are returned for reworking or scrap 1 In an actual Technical File a supplier should be shown against every component in this list In this example only a few are shown IFL 2001 14 IFL 2002 14 IFL 2003 14 IFL 2004 14 IFL 2005 14 IFL 2006 14 IFL 2007 14 IFL 2008 14 IFL 2009 14 IFL 2010 14 IFL 2011 14 IFL 2012 14 IFL 2013 14 IFL 2018 14 IFL 2019 14 IFL 2020 14 IFL 2021 14 IFL 2022 14 IFL 2022 14 cO O lt S N ve N LL O 2 LO O eb Cc Cc Q O
6. Notified Body allowing the scope of testing to be identified 6 it permits the Notified Body to verify that the samples received for testing are really those which the manufacturer intends to produce by checking that the samples delivered are the same as those described inthe TF and 7 itmay be used in full or in part by the manufacturer as a sales brochure for purchasers importers etc Or these reasons the TF is a crucial document and its preparation needs to be as complete and accurate as possible If the product samples sent to the Notified Body for testing do not fully correspond to what is described in the TF the body will most likely reject them and not start testing causing delay The same is true if the list of components given in respect of ROHS testing is incomplete or inaccurate or if any supporting ROHS certificates are not supplied For these reasons manufacturers might consider getting external expert advice in the preparation of their file If nothing else it is worth checking the English grammar and spelling because poor English gives a poor initial impression as far as the Notified Body is concerned in the same way that poor language in the User Instructions gives a bad impression to purchasers Before reading the sections which follow manufacturers should read earlier chapters of this Guide so that they fully understand the reasons for the TF and its contents When and if following the model TF given in Annex
7. applies Clause 11 Heating always applies Clause 13 Leakage current and electric strength at operating temperature always applies Clause 14 Transient over voltage always applies Clause 15 Moisture resistance applies except to IPXO products if permitted Clause 16 Leakage current and electric strength always applies Clause 17 Overload protection does not apply unless fan contains a transformer Clause 18 Endurance this requirement does not apply Clause 19 Abnormal operation always applies Clause 20 Stability and mechanical hazards applies to pedestal but not to bracket fans Clause 21 Mechanical strength always applies Clause 22 Construction always applies Clause 23 Internal wiring always applies Clause 24 Components always applies Clause 25 Supply connection external flex always applies Clause 26 Terminals for external conductors this requirement does not apply Clause 27 Provisions for earthing always applies Clause 28 Screws and connections always applies Clause 29 Clearances creepage and solid insulation always applies Clause 30 Resistance to heat and fire applies to non metallic parts Clause 31 Resistance to rusting may require visual inspection Clause 32 Radiation toxicity and similar hazards See certificates in Section 11 The tests of Clauses 10 11 and 13 are carried out at 40 C and the appliance is marked T only Conformity with the provisions of the EMC Direc
8. automatically mean that results will be received within 6 weeks of the laboratory receiving the samples this time is often the total time taken to perform the tests and manufacturers should seek from bodies agreement on starting and finishing times although difficult to judge the cost of any retesting in the event of failure should be discussed and the length of validity of the type approval certificate and the cost of renewing it is a factor As long as nothing changes with the product its design materials etc the production method the production control method or the harmonized standard s no retesting or repeat testing is necessary for CE marking purposes The body may require that the type approval certificate is renewed from time to time every 3 to 5 years is typical but this renewal is intended mainly to ensure that nothing has changed This renewal is therefore an administrative rather than a technical exercise and should not be expensive 300 500 Manufacturers should be cautious of bodies requesting renewal of the certificate more frequently than this and or charging substantially more Beyond these considerations it is suggested that manufacturers identify a number of possible Notified Bodies send the draft Technical File to each of them and then make a selection based on the offers received Lowest cost should not necessarily be used as the only criterion on which the decision is made Two questions
9. be given As with the user information discussed above the example data plate s and information to be given on the packaging and or User Manual and which appears in the Technical File must be the same as what appears on and with the product There is no need to provide any specific information in relation to electromagnetic compatibility or ROHS The CE marking symbol itself shows that the product has met these requirements One parameter coming from IEC 60879 if the manufacturer has chosen to declare this parameter is the fan speed in rpm which is not needed for CE marking purposes As such when it is declared for example on the packaging it needs to be kept separate from the CE marking because the CE marking does not guarantee the value as it does for the other parameters 3 4 8 Test reports and certificates These two final sections of the Technical File have to contain copies of all test reports the type approval certificate received from the Notified Body and any ROHS certificates received from component part manufacturers Once the Technical File is complete with test reports and certificates included and the Declaration of Conformity signed and dated the complete File should be sent once again to the Notified Body for final verification 3 4 9 The Declaration of Conformity All directives require that the manufacturer prepares and then signs a Declaration of Conformity DOC and that a copy of this appears in the
10. directive Unless the manufacturer has the necessary test equipment however he will need to have the parameters tested by a third party test laboratory and for practical reasons it may be best to use the same body as for LVD and EMC testing 2 6 The Waste Electrical and Electronic Equipment Directive WEEE This directive is very easy to apply in that it only requires that the product usually on its data plate is marked with the Do not include in normal waste symbol 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS 2 7 The Reach Directive In principle the REACH Directive applies to every product placed on the EU market and it has an extensive list about 600 pages of all the restricted or banned substances which cannot be used in products In practice however as long as electrical products comply with the ROHS Directive no additional assessment is usually needed to satisfy REACH but for example for something like an oil filled radiator the oil may need to be REACH compliant 2 8 Identification and selection of a Notified Body This Guide is unable to recommend any specific Notified Body or Bodies but it does show how manufacturers can identify them and then gives some considerations for how to select them All Notified Bodies working under the LVD and EMC are listed on the EU s NANDO website http ec europa eu enterprise newapproach nando index cfm fuseaction searc
11. does not apply directly to products it only sets out the basic regulatory framework Whether the requirements apply to a specific product depends on there being an implementing regulation such as is the case of fans Regulation EU 206 2012 For products other than fans whether implementing regulations exist can be found by looking at the list at http ec europa eu eneragy efficiency ecodesiqn doc overview legislation eco design pdf For fans the characteristics which need to be tested and declared are Description Symbol vawe um rFan powerinput SSS There is however no specification of which test methods have to be used to determine these characteristics IEC 60879 is the most appropriate standard for most parameters apart from sound power level where any suitable test method may be used The attestation of conformity procedure referred to in the regulation is Internal design control This means in practice that the manufacturer must fully describe in his Technical File the design of his products and then operate an FPC system to ensure that all products comply with this design As long as the Technical File is prepared as shown in Annex 1 of this Guide and the manufacturer is operating an FPC system suitable for controlling LVD and EMC parameters he will also meet the requirements of the Eco design Directive There is no obligation to involve a Notified Body and in fact there are no Notified Bodies under this
12. i G N N vr vr O eb c c Q O io N vr N IFL 2001 14 Electric motor 2001 14 AA Induction motor Page 5 Page 6 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS iv Final100 inspection After final assembly all 100 of the fans are inspected by Quality Control staff to ensure that they have been properly manufactured and that they operate correctly The criteria used are a finish visual inspection b operating switch function including remote control unit when included C sweep function where specified and d information label logo v Packing Following finished product inspection products are sent for packing in pre printed packaging The product label is checked against information on packaging and packed products are then stored by order and type ready for distribution shipping 6 User information The following user instructions are to be included in the packaging of each fan Operating instructions to be included in this Technical File are also provided with each fan as are mounting and wiring connection details for bracketfans CAREFULLY READ THESE INSTRUCTIONS BEFORE USING THIS PRODUCT This fan is intended for indoor use only Do not use in humid conditions such as bathrooms Unplug or disconnect the unit before undertaking any cleaning and especially before removing the safety grill Cleaning sh
13. of the distributor without the distributor taking any responsibility for CE marking then strictly speaking a distinction should be made between the manufacturer with responsibility for CE marking and the distributor on the product its packaging or the commercial documents This could be done by the mention of Manufa3ctured by and Distributed by 3 4 3 Identification of the product s There are no strict rules on how many or how few products can be included in the same Technical File hence common sense and one important principle can be applied If products from the same manufacturer are significantly different their materials are different their production system is different etc so that there would basically be at least two separate sets of information in most sections of the TF then it is probably better to prepare two or more separate documents The important principle however for type approval testing is that it is possible to group similar products or models together in what are called variants or families in order to reduce the number of tests that need to be done Grouping is actually done on the basis of a performance requirement which can be expressed as follows C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS Products may be grouped together into families whenever it is clear that the results of testing any one product within the family are applica
14. or where that is not possible on the packaging c The electrical equipment together with its component parts should be made in such a way as to ensure thatit can be safely and properly assembled and connected d The electrical equipment should be so designed and manufactured as to ensure that protection against the hazards set out in points 2 and 3 is assured providing that the equipment is used in applications for which it was made and is adequately maintained 2 Protection against hazards arising from the electrical equipment Measures of a technical nature should be prescribed in accordance with point 1 in order to ensure a that persons and domestic animals are adequately protected against the danger of physical injury or other harm which might be caused by direct or indirect contact b that temperatures arcs or radiation which would cause danger are not produced C that persons domestic animals and property are adequately protected against non electrical dangers caused by the electrical equipment which are revealed by experience d thatthe insulation must be suitable for foreseeable conditions 3 Protection against hazards which may be caused by external influences on the electrical equipment Technical measures are to be laid down in accordance with point 1 in order to ensure 04 C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS a that the electrical equipment meets the expected me
15. predominantly electrical only the LVD applies It applies to any equipment designed for use with a voltage rating of between 50 and 1000 V for alternating current and between 75 and1 500 V for direct current This clearly means that it covers electric fans and all other electrical domestic appliances The voltages above mean the input or output voltage different voltages e g for control may exist within the equipment but the directive still applies Some electrical equipment is excluded from the directive and this includes for example plugs and sockets equipment used in lifts and equipment used in explosive atmospheres The LVD and indeed other directives apply to things which are sold together and are intended to be connected and or used together So if a manufacturer sells a fan and a separate control switch or a fan with a remote control unit then both the fan and the control switch remote control unit would need to be shown to be safe and to function correctly together The LVD sets out the general and safety requirements which have to be met as follows 1 General conditions a The essential characteristics the recognition and observance of which will ensure that electrical equipment will be used safely and in applications for which it was made shall be marked on the equipment or if this is not possible on an accompanying notice b The brand name or the trade mark should be clearly printed on the electrical equipment
16. tested in order to demonstrate conformity and as explained below this will usually be done by a Notified Body based in the EU but after this initial testing there is no further repeat or routine testing as a condition of CE marking The primary purpose of FPC therefore is to ensure that all future products manufactured remain the same as those submitted for type approval this means that the results of the type approval tests remain valid for all future C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS products As examples of this the Low Voltage Directive states that Internal production control is the procedure whereby the manufacturer ensures and declares that the electrical equipment satisfies the requirements of this Directive that apply to it LVD Annex IV 1 The manufacturer must take all measures necessary in order that the manufacturing process shall ensure compliance of the manufactured products with the technical documentation and with the requirements of this Directive that apply to them LVD Annex IV 5 The Restriction of Hazardous Substances ROHS Directive requires that manufacturers shall ensure that procedures are in place for series production to remain in conformity Changes in product design or characteristics and changes in the harmonized standards or in technical specifications by reference to which conformity of EEE electrical and electronic equi
17. the Notified Body for retesting Experience with the TRTAII programme has shown that fans made in Pakistan struggle to achieve positive results in all tests when they are first sent to the Notified Body and this even after screening tests at PCSIR has eliminated many other deficiencies hence screening tests are highly recommended PCSIR are competent to perform LVD testing and they can also perform Eco design testing so that because no Notified Body is involved in Eco design these tests do not need to be repeated by the Notified Body unless the manufacturer wishes them to be Unlike most LVD tests Eco design parameters are not pass fail the value of each parameter is determined in the tests and it is these values which are then declared with the CE marking PCSIR are not able to perform EMC tests and while they offer some testing of ROHS any results in this area should be considered as indicative only As stated above however even though tests done in Pakistan can help remove many defects in the products they cannot with the one exception of Eco design be used as the basis for 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS CE marking in a way which will satisfy the demands of customers and importers Strictly speaking because all directives for fans rely on manufacturer s declaration of conformity a manufacturer could if he so wished use a non Notified Body to carry out the type
18. the material any reference number or identifier the technical specification in brief and the name and address of the supplier The supplier information is important because if the supplier is changed even if the specification of the component part appears to be the same one or more of the performance or ROHS test results could be invalidated Finally although not essential drawings of the main components of the fan may be included this is not done in the Annex 1 example But care should be taken that this does not make the whole TF too large to be sent easily by E mail typically no more than 3 5 MB 3 4 4 Description of the production method and factory production control system It is necessary to describe both the production method and the FPC system in enough detail that they can be understood and that the adequacy of the FPC system can be judged They do not however need to be described in full detail and an outline flowchart is often sufficient The level of detail given in the example TF in Annex 1 is appropriate but if in any doubt it is better to give too much detail rather than too little All key stages related to production and production control should be shown including for example ordering and reception of materials and component parts and packing labelling and dispatch because both of these have a bearing on the conformity of products Stages unrelated to production and production control such as handling of custom
19. which are often asked are 1 can manufacturers use test laboratories in Pakistan in support of CE marking and 2 does the manufacturer need an Authorised Representative based in the EU The need to use a Notified Body in support of the LVD and EMC has been discussed above and currently Notified Bodies cannot exist in Pakistan Afan manufacturer is entitled though to use a laboratory in Pakistan to test Eco design Directive parameters where no Notified Body is required and may also use a national laboratory to undertake both screening tests prior to CE marking see Chapter 4 below and to perform testing in support of FPC if any such tests are required The only other way in which a Pakistani test lab could undertake CE marking tests is by entering into an agreement with an EU based Notified Body Then by sub contract the Notified Body would authorize the Pakistani test lab to perform tests on its behalf For this to happen however the Pakistani test laboratory would need to be performing at avery high level of competence no such arrangements exist at present The Authorised Representative AR a term which appears in many directives is an organization based some where in the EU which is contracted by the manufacturer to perform certain tasks on the manufacturer s behalf The AR may for example hold the Declaration of Conformity and Technical File on the manufacturer s behalf and act as the contact point for market surveillance autho
20. will ensure suitability for a wide range of countries The same is true of ambient conditions a few if any EU Member States will require suitability for tropical conditions 40 C or above but this is very likely to be required in Middle Eastern countries for example In summary CE marking is not something which should be taken lightly It should only be considered by manufacturers who believe that their products are capable of meeting the requirements for CE marking who have identified that a market exists for their products in countries where CE marking is either mandatory or required by the market and who are serious about supplying these markets Finally it is only something to be considered by those manufacturers willing to putin the resources and effort required to achieve it 3 3 Operation of factory production control All directives require in greater or lesser detail that manufacturers must operate some sort of factory production control FPC system However this is not the same as a Quality Management system see below CE marking should not be confused with normal third party product certification where the certification body will test products in order to issue a certificate in the first place but will then from time to time test further samples to ensure continued compliance and where the product certificate may be suspended or withdrawn if the product no longer complies For CE marking the product needs to be initially
21. 1 manufacturers must ensure that all sections of the file are made specific to their products and their production systems 3 4 2 Identification of the manufacturer s In EU legislation the manufacturer is defined as the person responsible for affixing the CE marking and whose name appears on or with the product In most cases the manufacturer will be the company which makes the product and consequently it is the details of this company which appear at the beginning of the TF In some cases however the product may be sold entirely in someone else s name in which case from a legal point of view it is that someone else who becomes the manufacturer of the product and acquires as a consequence all the responsibilities imposed on the manufacturer which includes the need to hold a Technical File in his own name The second manufacturer may be the company which makes the product but sell sit under a different name It is beyond the scope of this Guide to go into details of the different responsibilities if the same product made by one company is sold by two or more different legal entities and advice should be sought if this situation arises If the same product is sold under two different names both of which are trade names of the manufacturer who takes responsibility for the CE marking then the TF needs to make clear that both names will be used to sell it If the product is to be distributed in someone else s name i e the name
22. ANUFACTURERS European market checking the presence of the CE marking symbol and that technical information and user instructions are present and credible A lack of CE marking on a product which should bear it or a lack of technical information or user instructions is itself an offence whether the productis safe or not documentary checks where the authorities ask to see proof of conformity via the Technical File If a manufacturer does not hold a TF if the file is incomplete does not contain test results for example or the manufacturer refuses to send the TF to the authorities this is also an offence and visual assessment and or product tests Authorities will easily spot obvious faults and in such cases they may conduct testing Itis unlikely that the detailed ROHS testing would be repeated but action will be taken if ROHS requirements are clearly not met use of chrome plated screws for example or very shiny paint which indicates the presence of lead The simplest ways in which manufacturers can avoid market surveillance actions are by firstly keeping their Technical File fully up to date and correct which includes ensuring that certificates are up to date and that any new test reports are included Secondly they should verify every product or batch of products they supply including its marking and accompanying information and they should be very careful of making any changes to the product its design or its compone
23. C MARKING FOR ELECTRIC FANS APPLIANCES AND EQUIPMENT This guide is prepared under EU funded TRTA II Programme which is implemented by UNIDO in association with ITC and WIPO DEY G A International Trade gt INTELLECTUAL PROPERTY Centre Wl O eles ken Pakistan Council of Scientific United Nations Industrial amp Industrial Research Development Organization Government of Pakistan European Union European Union This guide is prepared under EU funded TRTA II Programme which is implemented by UNIDO in association with ITC and WIPO Z A N f NI sy International 3 4 Trade world NEW A gt Cant gt retuscrua PROPERTY SSE entre WIPO Government of Pakistan Pakistan Council of Scientific United Nations Industrial amp Industrial Research Development Organization C MARKING FOR ELECTRIC FANS APPLIANCES AND EQUIPMENT Guide for Manufacturers PREFACE The European Union s CE regulatory conformity marking is crucial to all Pakistani manufacturers of electrical appliances without it the very future of this major industry is called into question Although it may seem burdensome and unnecessary whether we like it or not CE marking is compulsory for almost all electrical appliances sold in Europe because Europe with its population of about 500 million people has to be one of if not the most important market for Pakistani ma
24. EEE 2012 19 EC which requires that fans be marked as unsuitable for normal waste streams 6 the Registration Evaluation Authorization and Restriction of Chemicals Directive REACH EC 1907 2006 which restricts the use of dangerous substances but see below and T the Energy Labelling Directive 92 75 EEC thatapplies to some electrical appliances but not fans Manufacturers must comply with all of these directives although the Eco design Directive is applied for fans through an implementing Regulation EU 206 2012 Compliance with the first four of the directives leads to the product bearing the CE marking while the WEEE Directive requires manufacturers to put a symbol on the product indicating that it should not be disposed off with general waste The text of all of these directives and the implementing regulation can be found at the European Commission s website on the internet and it is strongly suggested that all manufacturers seeking the CE marking read it 02 C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS Safety is generally expressed in performance rather than prescriptive terms and manufacturers have the choice of how to satisfy the requirements An example of a performance requirement from the LVD is that persons and domestic animals are adequately protected against the danger of physical injury or other harm which might be caused by direct or indirect contact The directive doe
25. MC as well as ROHS and Eco design although the body will not be acting as a Notified Body in respect of ROHS or Eco design ensure that the body is willing to provide only type approval certification as required for CE marking and is not suggesting full product certification or wants to assess the manufacturer s FPC system which would be beyond the requirements of CE marking this does not prevent manufacturers from seeking voluntary product certification if they so wish typical costs of testing per model see below are likely to be between 3 000 and 4 000 The cost per model especially for ROHS testing will be proportionally higher per model if the manufacturer submits only one or two models but will be cheaper if he submits more models at the same time see below bodies which offer a price much below or much above the price range given above should be treated with some suspicion a body which has a representative in Pakistan may make contact between the manufacturer and the body easier but this is not essential the body needs to be willing to work in English 08 C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS there could be some economies if the manufacturer uses the same body for type approval testing as for third party ISO 9001 system certification if the manufacturer opts for this the turn around time will typically be quoted as 4 6 weeks but this does not
26. Technical File The DOC is the statement given by the manufacturer acknowledging that he has ensured on his own responsibility that the products he sells conform to all applicable regulatory requirements There is no definitive model for the DOC to follow but that given in Annex 1 is adequate Atthe time that the TF is first prepared the DOC cannot be signed because this can only happen when test results and a type approval certificate have been received As soon as these are received however the DOC needs to be signed and a copy included in the TF The DOC also needs to be kept up to date So for example if the harmonized standard changes and the product is retested anew DOC will need to be prepared and signed 3 5 ECtype approval stages 3 5 1 Introduction Having prepared the Technical File as described in 3 4 ensured that a Factory Production Control system is in place according to 3 3 and selected a Notified Body according to 2 8 type approval testing can begin Prior to this however manufacturers may decide to have screening tests performed by a laboratory in Pakistan Such as PCSIR in Lahore since this can help in eliminating major non conformities prior to sending the samples to the Notified Body in Europe 3 5 2 Screening tests Although screening tests add time and some cost to the procedure local testing will be cheaper than Notified Body testing and will save the time and expense of having to resend the sample to
27. alified persons in order to avoid a hazard 11 There are no user repairable or user replaceable parts in the fan unit Any repairs must be made by an authorised agent CAUTION PLEASE DO NOT IMMERSE MOTOR HEAD IN WATER Page 7 C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS The documentation also includes the CE marking symbol and the parameters of the Eco design Directive namely Description Symbol vawe um O o a SV Psp Lwa C D ao rsericevae SVP i i W Standby power consumption x x Fan sound power level B A Page 8 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS 7 Quality management system International Fans Limited Pakistan operates a Quality Manager System according to ISO 9001 certified by QEC UK see certificate below In summary the Quality Plan comprises the following Activity process Procedure Inspection Person responsible No point No eteiavconponentpuctese GWP 06 __ Pucesing Deparment HE eet tee ara e onana Rotor andstatorstamping awP o7 __ Production Department s componentmoucing WP 09 __ Producton Department e eats se hein nd pang amemo Producton Deparment 7 component snisning amen Production Deparment Te Motor assembiy and varnishing aMP 12 _ Production Deparment o moorei amers Production Deparment 10 unt eanna paining and ourna amera _ Produ
28. andards applied EN 60335 2 80 2008 International Fans Limited IEC 60879 1986 Pakistan Issue date 19 04 2014 CE MARKING TECHNICAL DOCUMENTATION Class I electric bracket and pedestal fans Council Directives 2006 95 EC 2004 108 EEC ROHS Directive 2011 65 EU WEEE Directive 2012 19 EU and the Eco design Directive 2009 125 EC International Fans Limited 123 Main Road Gujrat Pakistan Tel fax 92 53 1234 5678 Web site www IFLfans com TABLE OF CONTENTS 1 Document introduction and scope 2 2 Product description 2 3 Technical drawings and images 2 4 Description of materials and components in the product 4 5 Manufacturing method 6 6 User information T T Quality management system 9 8 Compliance with the LVD 2006 95 EC EMC Directive 2004 108 EEC 10 and other directives 9 Product marking 11 10 Test reports 12 11 Material and product certificates 12 12 Declaration of Conformity 12 Preparation This Technical File is prepared initially without test reports in respect of CE marking related characteristics Declaration of Conformity or identification of the Notified Body These are added on receipt of the EC type approval certificate from the Notified Body For re validation of the type approval certificate the full Technical File is submitted to the Notified Body Page 1 C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS 1 Document introduction and scope This Technical File des
29. approval testing However as already discussed there is no commercial test laboratory in Pakistan capable of performing the required EMC tests and relying on national testing alone is unlikely to give the degree of confidence required for CE marking nor satisfy the needs of customers Finally PCSIR may also be able to assist with the checking of the Technical File and aspects such as product marking before products are sent to the Notified Body 3 5 3 Type approval testing and certification by the Notified Body lt has already been assumed that manufacturers will use the same Notified Body to carry out all required tests for LVD EMC ROHS and Eco design unless these are done locally This is certainly advisable although strictly speaking there is no obligation on the manufacturer to choose just one body and if for example he can get a better total price by having a Notified Body perform LVD and EMC tests and a different body non notified to perform ROHS testing and assessment he is entitled to do so The chosen Notified Body will provide the manufacturer with a quote which will include an amount for testing and usually a separate amount for certification Some Notified Bodies may offer a service for Preparation of the Technical File but as long as the manufacturer has followed the example given in this Guide this service is not necessary The quotation should indicate the number of samples which need to be submitted and the Noti
30. ble to all other products within the same family Products may be grouped differently depending on the characteristics being considered This can perhaps be better explained by giving some examples Firstly if a manufacturer makes a bracket fan a table fan and a pedestal fan and all of these models use exactly the same motor and enclosure then the electrical and mechanical safety and ROHS tests of the motor would need to be done only once on one model and the results would apply to the other two the stability test of the pedestal fan would of course still need to be done on that model Secondly ifa manufacturer makes several models of ceiling fans which differ only in the colour of the casing and the blades but are all in the same family with respect to motor characteristics still separate ROHS tests might need to be performed on the different materials of the casing and blades In both of these two cases it would be sensible for all models in each family to be included in the same TF Finally ifa manufacturer made fans using the same materials for the casing and blades but different motor designs then these fans would be in one family for ROHS tests on the casing and blade materials but motor and other tests would need to be done on each different model in the latter case it might be best to prepare two separate TFs but with instructions to the laboratory to not to repeat the ROHS tests Where a manufacturer proposes the use of variant
31. ccessful test will mean that the type approval certificate will not be issued and consequently CE marking cannot be applied there is no acceptable degree of non conformity permitted by EU directives 100 of the requirements must be met On receipt of a failed test report from the Notified Body therefore the manufacturer must take action to correct the problems Manufacturers have to accept that the Notified Body has absolute authority in deciding whether a product meets the requirements or not With this in mind there is very little point in the manufacturer trying to persuade the Notified Body to change its mind and there is even less point in trying to argue that the standard is unfair It is not advisable for the manufacturer to try to change from one Notified Body to another in the hope of finding a less demanding one even if for other reasons a manufacturer may change from one body to another if he so chooses All Notified Bodies are accredited to perform the tests in exactly the same way within the normal limits of uncertainty of each test as any other body and therefore while one body might give a different level of customer satisfaction from another the notion of demanding versus easy bodies does not exist in Europe If failures are identified by the Notified Body then the manufacturer must simply address them and then resubmit samples to the Notified Body for repeat testing If the failures are minor the sample
32. ce document for CE marking and these sites can also be considered to be accurate At a third level websites of manufacturers associations and other organizations may provide useful information but the accuracy of the information they provide may need to be verified C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS Chapter 3 STAGES TO BE FOLLOWED FOR CE MARKING 3 1 Presentation of stages The stages towards CE marking as shown in the Introduction are given in the following flowchart Each stage is then described in detail in the following sections of this chapter although some of the stages shown in this figure are combined in the explanation sections Identification of market s Is CE marking required 1 Yes x n Either or 2 Complete Declaration of Conformity Apply CE marking Continue same production and renew CE marking as necessary 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS 3 2 Identification of markets There is very little point in making any preparations for CE marking apart perhaps from seeking a third party certified Quality Management System according to ISO 9001 which has benefits independent of CE marking unless the manufacturer first identifies that there is a market for his products in Europe or in other countries Having identified such markets the manufacturer then needs to decide whether CE mar
33. cess ROHS No SHAEC1204205525 SHAEC1000606505 A001R130116035001 2 RLSHD000823580017R2 SH591521 CHEM CE 2005 A0861C D CANML1202337704 CE 2012 64942 HKGEC1300244901 th Oual J 1a ity Ca Lath W re Imported Insulating Paper Supplier Certified eS C s nst a Automatic IC ligt ee i nee _ Insulating Plant gt ie towing ee KIHIS QA Pil fig Q amp Inspection lt a The manufacturing process of these fans comprises the following main stages i Purchase of raw materials All purchase orders for materials and components are placed according to our own technical specifications Material composition ii Material component reception inspection LIST OF COMPONENTS All 100 deliveries are inspected and tested according to the following characteristics Electrical steel sheet Si 0 06 Round head screw 3 8 x 3 16 IFL 2015 14 Capacitor 1612 12 O 2 5 MFD 450 V AC 20 AWG copper 99 99 3 x 1 00 mm 300 volt UK BS 1363 9518 Wire washer 6N 4 Rotor Electrical steel Copper wire 99 99 Laminated paper Insulating sleeve Thermal cut out 160 C Aluminium body Aluminium plate Bush universal 9 0 mm Nylon tie lock Round standard Stoving paint 1 2 3 G 0 a material component quantity b material component quality visual inspection c material hardness softness where applicable 1602 12 B 1603 12 C
34. chanical requirements in such a way that persons domestic animals and property are not endangered b that the electrical equipment shall be resistant to non mechanical influences in expected environmental conditions in such a way that persons domestic animals and property are not endangered c that the electrical equipment shall not endanger persons domestic animals and property in foreseeable conditions of overload All of these requirements apply to all electrical equipment including fans In order to meet the requirements of the directive the manufacturer has two main options 1 he applies a harmonized European Standard which has been written in support of the LVD and therefore which has expanded the requirements of the directive and given them in terms of requirements and test methods which apply specifically to certain products or 2 he complies directly with the requirements given in the directive in which case he has to perform a risk assessment identify for himself the requirements on his product and propose suitable test or assessment methods to satisfy them In reality demonstrating conformity by applying a harmonized European Standard where the word harmonized means accepted by Member States as giving a presumption of conformity with the provisions of the directive is so much simpler than direct compliance that only the standards approach will be discussed in the rest of this Guide Although many harm
35. cribes the International Fans Limited Class bracket and pedestal fans and demonstrates how these fans meet the requirements of the EU Low Voltage Directive 2006 95 EEC originally Directive 73 23 EEC modified by Directive 93 68 EEC This document has been produced according to the requirements of Annex IV of the directive International Fans Ltd is a major manufacturer of electric fans founded in 1985 selling its products nationally in the Middle and Far East and in the EU This Technical File identifies the products and their materials the manufacturing process and production control method the Principle Elements of the Safety Objectives Essential Requirements of Annex of the directive and the harmonized European Standard applied to demonstrate conformity with these Requirements The European Standard applied demonstrates that the fans submitted for EC type approval meet the provisions of the directive while the production control method ensures that all production continues to meet these provisions This Technical File also identifies that the products meet the provisions of the EU ROHS2 Directive 2011 65 EU the EU REACH Directive EC 1907 2006 demonstrated in part by certificates from material component Suppliers see Section 11 and in part by testing and the Electromagnetic Compatibility Directive 2004 108 EC Finally it identifies that the products meet the EU Eco design Directive 2009 125 EU and the EU Waste Electrical and Ele
36. ction Deparment Cn untassenoy omens __ Producton Deparment s reco wa O S Packing Department Tia sose omre Storage Surove 15 Disribwionshipning amero Epon Depanmen CEC WHO CERTIFICATION Fi Quality Management System Certificate of Approval This Is to certify that the QMS of U I Industries 182 C S LE G T ROAD Gujrat Punjab 50200 Pakistan Has been assessed and found to meet the requirements of ISO 9001 2008 This certificate is valid for the following scope of operations QEC CERTIFICA Manufacture and Sales of Electrical Fans and Related Products Clauses 7 3 7 5 2 and 7 5 4 are excluded with justifkation as detailed in Company s Quality Manusi QEC Certification Registration House 22b Church Street Rushden Northamptonshire NN10 9YT Tet 01933 383261 emal info qec co uk Web Company number 02812220 Page 9 C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS 8 Compliance with LVD 2006 95 EC EMC Directive 2004 108 EEC and other directives The products covered by this Technical File meet the following clauses of harmonized European Standard EN 60335 2 80 2008 and on this basis are considered to satisfy all applicable provisions of Directive 2006 95 EC see the test reports in Section 9 Clause 8 Access to live parts always applies Clause 9 Motor starting this requirement does not apply Clause 10 Power input and current always
37. ctronic Equipment Directive 2012 19 EU This Technical File also demonstrates that the fans have been tested according to International Standard IEC 60879 2 Product description Product IFL bracket and pedestal fans Brand name International Fans Limited Class Insulation Class to EN ISO 60335 1 Models Acme wall bracket IFA WB and Acme pedestal IFA PL Type of appliance Mains 220 240 V 50 60 Hz powered manual and electronically operated for the pedestal fan with incorporation of supply cord with plug for the pedestal fan without plug for the bracket fan The fan unit is the same for the pedestal and bracket models Colour White see Section 3 Usage Suitable for tropical climates 3 Images and technical drawings RAUNT N A f a y f x i ATII iu Be Ww y 4 i h m yZ f AA 3 Bracket fan Pedestal fan Page 2 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS ZN MERN m bated a u E Overall fan unit design Details of motor construction FAN MOTOR gt Auxillary Winding Capacitor Terminal Block at Terminal Block in motor body gt i fixed wiring to be Provided by the user Earth Terminal at Motor Body wil 4a e SY Thermal Protector gt l Main Winding pee ee ventas ii Ot Leen Supply form Switch Board L Stands for line phase alo s on co N Stands for Nutral Alamo Slee Stands for Ear
38. cy the rated power and the letter T indicating suitability for operation in tropical conditions v The donotdispose symbol of the WEEE directive X The data plates for International Fans Ltd fans tested at 40 C are as follows IFA WB 1 400 mm A 1400 mm Voltage 220 240V i 77 International Fans Gujrat Made in Pakistan Voltage 220 240V 50 60 I sow T International Fans Gujrat Made in Pakistan IFL IFLBRACKETFAN FAN a IFL PEDESTAL FAN CE The packaging shall be marked with the above information together with the other performance information from IEC 60879 Air delivery and service value is shown with the CE marking whereas maximum speed as non harmonised information is presented separately as follows IFL IFLBRACKETFAN FAN IFL PEDESTAL FAN C 4 AB 2 55 m minyW 2 55 m miny W Max speed Max speed Page 11 C MAR K N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS When the ILF fans are sold in the name of Second supplier in packaging with this name itis ILF s name which is shown with the CE marking 10 Testreports This section will contain all test reports as received from the Notified Body together with the Eco design test reports 11 Material and product certificates This section will contain certificates from material and component suppliers and the EC type approval certificate and ROHS certificate issued by the Notified Bod
39. e Notified Body might require in the test report to be informed of any major changes and might not therefore need to know about the minor changes In practice however from a technical point of view it is irrelevant whether a Change is major or minor what is important is whether the change has an effect on continued conformity Changing nuts and bolts may be a minor technical change but the new ones could affect continued ROHS compliance If the manufacturer has any doubts about a change he should consult the Notified Body anyway Changes to standards should be checked at least once every five years after the date of the standards all standards are reviewed every five years whether they are changed or not Standards may of course be amended more frequently than this If the manufacturer becomes aware of a new version of a standard he should consult the Notified Body to identify whether any repeat testing is required Apart from these measures however as long as nothing changes the manufacturer may continue to apply CE marking to his products 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS Annex 1 EXAMPLE TECHNICAL FILE Note that this example is used only to show the principles and layout of a Technical File It does not correspond to any particular real fans and it might not be fully complete or internally consistent Technical File Number IFL 1 Revision 0 Principal st
40. e electromagnetic disturbance to be expected in its intended use which allows it to operate without unacceptable degradation of its intended use In principle not all equipment needs to be tested for EMC emission and immunity although equipment containing electronic components will need testing The so called benign equipment which because of its design can be known not to emit or be affected by radiation is excluded from the scope of the directive Having said that different test laboratories interpret this differently and if the laboratory chosen by the manufacturer recommends or insists on tests being done it may be better for the manufacturer to accept this With positive test results there can be no doubt that the equipment meets both requirements There are three harmonized standards applied to assess EMC conformity of fans EN 55014 1 2006 A1 2009 EMC requirements for household appliances electric tools and similar apparatus Part 1 Emission EN 61000 3 2 2006 A1 2009 A2 2009 Electromagnetic compatibility Part 3 2 Limits for harmonic current emissions EN 55014 2 1997 A1 2001 A2 2008 EMC requirements for household appliances electric tools and similar apparatus Part 2 Product family standard A1 and A2 refer to the two Amendments which have been made to these standards As for the LVD Directive manufacturers should ensure that the current versions of these standards are used for testing although a test laboratory sho
41. er orders or complaints do not need to be given it is best not to identify by name the people responsible for different stages because if one person leaves the TF would need to be changed the function however e g Production control supervisor may be identified Even if third party ISO 9001 certification is used as partial proof of the adequacy of FPC in which case a copy ofa valid certificate has to be included in the TF the key stages of the FPC system still need to be listed and or described This helps to ensure should there be any doubt that the third party certification is both genuine and adequate 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS 3 4 5 User information The LVD in particular requires that adequate user information be given to allow the product to be correctly installed and operated and also to place any limitations on the use of the product Because of liability laws especially in the EU any restrictions on the use of the product such as indoor use only that the product must not be used if damaged and that no parts are repairable or replaceable by the user need to be given in the user information since the manufacturer is then not responsible if the product is used in conditions outside of his specifications and an accident occurs lf the manufacturer already has user instructions perhaps in the form of a User Manual these may be copied directly in
42. er States as being competent to assess products under one or more directives These bodies have to be based in Europe although they may have representatives in other countries such as Pakistan this means therefore that in order to obtain a CE type approval certificate test samples will have to be sent to Europe for testing In addition to responsibilities on manufacturers EU provisions also impose obligations on importers and distributors These must ensure that any products entering the EU market or sold in that market which are required to be CE marked are CE marked and are accompanied by any necessary documentation In short they are committing an offence if they sell products without the CE marking when the products should indeed be marked Manufacturers of fans therefore need to be aware of this provision and refuse to supply products to any importer in the EU that does not impose CE marking Because market surveillance authorities in Europe concentrate a lot of their efforts on checking electrical products products without CE marking are very likely to be subject to control actions very rapidly and in the case of any problems both the manufacturer and the importer could be found guilty of an offence Prior to sending products for testing in Europe manufacturers must draw up technical documentation to identify the product and its production process and how the manufacturer intends to demonstrate that his product complies with all rele
43. fied Body should having assessed the Technical File prior to giving a quote have considered any grouping of products into families proposed in the File Even where families are grouped the Notified Body may well ask for one sample of all models in each family so as to verify that they really are the same and may in addition ask for one of more samples of all models in order to cover those tests which are not covered by the notion of families The Notified Body will provide a contract to be signed by the manufacturer and will usually request that the entire testing fee be paid in advance with the certification fee being paid only once testing has been successfully completed If testing is successful a draft report will be issued to the manufacturer and once the manufacturer agrees and the final version of the Technical File is accepted by the Notified Body the EC type approval certificate will be issued If some tests are not successfully passed the manufacturer will be informed and the advice in the following section should then be followed Finally although this Guide uses the term Notified Body and assumes that manufacturers will select such a body the body may decline to be referred to as such and will instead ask to be considered only as a third party The manufacturer should follow the wishes of the body although it makes no difference to the general guidance given in this document 3 5 4 Correction of defects Any one unsu
44. h main On entry to this web page there is a Free search screen as follows Free Search Keyword On Bodies Keyword On Legislations Keyword On Articles Annexes Keyword On Procedures Keyword On Products Keyword On Horizontal Technical Competence Typing Low Voltage or Electromagnetic Compatibility into Keyword on Legislation will produce the list of Notified Bodies competent to work under the LVD or EMC Directives respectively By clicking on the name of the body its details can be found below which can be found the list of which legislation it is competent to perform type approval testing for The scope of competence of each body can then be found by clicking on the HTML or PDF tabs against the legislation which will call up the accreditation scope of the body A manufacturer in Pakistan is entitled to use any of the bodies given in the NANDO lists and in principle all bodies are equally technically competent and their results equally acceptable However a number of considerations may help in guiding manufacturers on how to choose a suitable body because the demand for the Notified Body is coming from the market and not from regulation manufacturers should check that the body they use will be accepted by their customers this may mean choosing a well known body with a good international reputation for practical reasons it may be better to choose a body able to perform all tests those of LVD and E
45. ified system which has been assessed by a duly accredited certification body then they will be considered to have met the regulatory requirements for FPC Manufacturers should therefore consider attaining ISO 9001 certification not only for CE marking purposes but also as a benefit in its own right If a manufacturer uses ISO 9001 certification as the basis on which he claims satisfactory FPC a copy of his certificate which must be current has to be given in the Technical File Even in this case he must still describe the main stages of his control system Strictly speaking a manufacturer does not need to have a functioning FPC system before he submits his products for type approval testing However because it can take time typically 6 months to a year to implement such a system it is recommended that this system is operational before type approval testing starts 3 4 Preparation of documentation 3 4 1 Introduction Although this section covers mainly the preparation of the Technical File TF required to fully identify the product there are in fact a number of decisions and actions that need to be taken in order to prepare this file When EU directives talk about a product the product in question is actually defined not only by the physical item to be tested but also by the materials and components from which it is made its manufacturing process its factory production control system its marking and labelling the harmo
46. king is mandatory from a regulatory point of view the case for European Union and EF TA countries whether it is required by or advisable for the market Middle East some north African countries whether it brings a marketing advantage even if not required for example ex Yugoslavian and ex Soviet countries or whether it is not necessary at all This section is not a guide on how to identify potential markets but it does give some guidelines which might prove helpful While the CE marking allows products to demonstrate that they are legally entitled to be placed on the market and is therefore a marking primarily intended for customs and market surveillance authorities it does not indicate that customer requirements will be satisfied Customer requirements often go beyond the requirements of CE marking and cover aspects such as price functionality appearance durability although some CE marking tests also cover durability the manufacturer s reputation and after sales service all of these aspects should be considered by manufacturers before starting the CE marking process There is an initial cost associated with obtaining the CE marking mainly covering type approval testing and certification and the cost of purchasing standards Typically this cost will be in the broad range of 5 000 to 15 000 depending on how many models are considered at the same time This should add very little to the unit cost for any fans sold in large or nor
47. latory background to the CE marking Chapter 2 THE APPLICATION OF DIRECTIVES Introduction The Restriction of Hazardous Substances Directive ROHS II The Eco design Directive 2009 125 EC The Waste Electrical and Electronic Equipment Directive WEEE The Reach Directive Identification and selection of a Notified Body Market surveillance Further information Presentation of stages Identification of markets Operation of factory production control Preparation of documentation 3 4 1 NTOdUCHON tao EN 3 4 2 Identification of the manufacturer s e 3 4 3 Identification of the PFOCUCT S oo mmm 3 4 4 Description of the production method and factory production control system 3 4 5 User iNfOrmMation ce 3 4 6 Compliance with regulatory requirements i e with all applicable directives 3 4 7 Produc MaK NO aT 3 4 8 Test reports and CertifiCates niin 3 4 9 The Declaration of Confom iiy snes eet te at nse ee EC type appro VA SUAS a 3 5 1 INIrodUC ION a ececcnsisdesen essence tance tainted 3 5 2 SD CPS SING LSS US icc cecarneseans cinta cncnctateanmsatnmts ct taseane cue ntaen ms nti ehnden emaetedeti 3 9 3 Type approval testing and certification by the Notified Body e 3 5 4 Correction of defecisS oo cmmmmuniiniinniiinntininnniiitntnitinnnnnnitnnitnnnnnn 3 5 5 Drawing up of the Declaration of Conformity DOC eeen 3 5 6 Continuation oi produco eesse EXAMPLE TECHNICAL FILE The Low Voltage Directive LVD The Electromagnetic C
48. mal quantities but manufacturers should also be aware that the demand for fans in some EU countries may well depend on the weather there might be few sales in a cold winter or cool summer many more in a hot summer Cost should not though really be a factor in deciding whether to obtain CE marking or not Manufacturers should also take into account the time required to obtain the CE marking This is likely to be 6 months minimum even while assuming that everything proceeds smoothly and no re design or re testing of the product is necessary and could easily extend to 18 months Manufacturers should not therefore undertake to supply CE marked products until they are certain that they will be able to Manufacturers should also be aware that CE marking requirements can be technically demanding especially with regard to user safety and avoidance of hazardous substances content Products which can be sold in Pakistan for example may require a re design to be suitable for use in the EU and the difficulties associated with this re design together with the time necessary to implement it should be considered before opting for CE marking There are a few technical considerations which may also be important For example EU countries use a voltage of 230 V and a frequency of 50 Hz Non EU countries tend to have a range of both voltage and frequency so ensuring that the fan is qualified for a voltage range of 220 240 V and a frequency range of 50 60 Hz
49. n should be left blank but once the body ies are known the relevant information can be included 3 4 7 Product marking There are three locations where information regarding performance and CE marking may appear on the product itself usually a data plate on the packaging and on accompanying documentation which is usually the User Manual This section of the Technical File indicates by way of descriptions and examples what information appears in which location To know what needs to be marked on the data plate the manufacturer has to read the EN 60335 2 80 2008 standard together with EN 60335 1 and follow the prescriptions given there The example data plate shown in Annex 1 of this Guide comes from the standards and includes the CE marking symbol and the Do not dispose symbol of the WEEE Directive Eco design parameters do not need to appear on the data plate unless the manufacturer wants them to All information related to CE marking needs to appear together LVD information the WEEE symbol and Eco design parameters in one location even if this means repeating what is given on the data plate This location may C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS be the packaging as is the case of Annex 1 or it may be the User Manual or it could be both It is convenient and easiest to simply copy the data plate format adding the Eco design parameters and use this as the information to
50. nized standard applied and even in some cases by who manufacturers it Because the TF is required to uniquely identify the product which is CE marked all of the information which goes to define it needs to be included in the TF The various sub sections in this section cover how the TF should be prepared and Annex 1 gives an example which can be used as the basis for a manufacturer to prepare his own While each directive requires that the manufacturer prepares a TF all the information can be put into one single document covering all directives The Technical File serves quite a number of purposes beyond just the needs of CE marking 1 itis the complete definition of the product as discussed above serving as a reference for the manufacturer as part of any Quality Management system E MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS 2 itis the main document which satisfies the regulatory obligations on the manufacturer by describing how he has met the provisions of all applicable directives 3 it can prove to market surveillance authorities that the product conforms because when they question the conformity they will usually ask to see the Technical File first 4 itallows the manufacturer to obtain an outline quotation from candidate Notified Bodies before test samples are sent 5 it allows the manufacturer to indicate his preferences in terms of performance parameters to the
51. nmental protection and energy consumption and re cyclability are set out in a series of directives which apply equally in all EU Member States The requirements and the way to meet them are however no different for manufacturers in Pakistan than for manufacturers in any other country of the world including the EU itself While the market for comfort fans in Europe may not be the biggest in the world the market for domestic electrical equipment in general is huge and growing total annual sales of domestic appliances approach 50 000 000 and are growing at approximately 3 per year If Pakistani manufacturers are able to break into this market the economic benefits could be substantial The discipline imposed by CE marking may help raise the overall safety and quality levels of Pakistani products It was to help Pakistani manufacturers meet the CE marking requirements that the EU funded Trade Related Technical Assistance TRTA Il programme implemented by the United Nations Industrial Development Organization UNIDO in partnership with the International Trade Centre ITC and the World Intellectual Property Organization WIPO started a CE marking programme in 2012 This programme aimed to develop a sustainable CE marking procedure applicable by any Pakistani manufacturer to test and validate this procedure by assisting some fan manufacturers to achieve CE marking and to train and qualify a group of Master Trainers to assist other man
52. nt parts without informing the Notified Body ofthis In the unlikely event that market surveillance action is taken the importer and or the manufacturer will receive a notice explaining the reasons for the action what needs to be done to correct it and the time allowed for this In such cases the required actions must be taken and the authorities must be informed or there is a risk that the product will be suspended or removed from the market 2 10 Further information There is a great deal of information related to EU regulations directives and CE marking on the internet and it is recommended that manufacturers consult this from time to time so as to better understand the process and requirements Perhaps the best source is what is known as the Blue Guide 2014 which gives a good and thorough presentation of the subject and can be found at http ec europa eu enterprise policies single market goods documents internal market for products new legislative framework index_en htm Other guidance can be found simply by typing the name of a directive into a search engine but different levels of information need to be treated differently The European Commission s website anything starting with ec europa eu can be considered to be definitive and correct but will often lack the technical details required by manufacturers At a second level many Notified Bodies provide information through their websites often in the form of a flowchart or guidan
53. nufacturer in the first instance If the manufacturer employs a third party e g a product certification body or a test laboratory see below these parties do not authorize the affixing of the CE marking they only provide information which assists the manufacturer in declaring that his products conform which he does by using the CE marking All directives fix a system of attestation of conformity AoC which means who is involved in demonstrating that the product meets the requirements of the directives For all of the directives listed above the system is manufacturer s declaration of conformity which means that the manufacturer may if he has the necessary test equipment test the product himself without the intervention of a third party There is also no regulatory obligation for third party assessment of the manufacturer s factory production control system In practice however two factors make the intervention of a third party Notified Body necessary Firstly it is highly unlikely that manufacturers will have all the test equipment required for the full range of tests and will have the equipment for testing electromagnetic compatibility or the content of hazardous substances Secondly many importers and purchasers require indicating that this is a market need not a regulatory one that the products they buy are tested by a Notified Body Notified Bodies are product certification bodies or test laboratories which are recognized by EU Memb
54. nufacturers Therefore we either accept and adopt the CE marking or allow this crucial market to be closed to us Without access to the European market however it is difficult to imagine a successful future for Pakistani appliance manufacturers Even for appliances not directly intended for the European market the requirements of Europe in terms of product performance and production system requirements such as control of raw materials in production checks and assessment of finished products can bring benefits to Pakistani manufacturers These benefits in particular can be improvements in product quality increased productivity and reduction of waste While CE marking is only mandatory for products sold in Europe it is recognised in many other countries where it can be used to provide a substantial marketing advantage This timely Guidance Document funded by the European Union through the TRTAII project in Pakistan managed by UNIDO in association with ITC and WIPO at Islamabad provides an excellent presentation of the whole subject of CE marking Its easy to read and clear style combined with a presentation of all the stages which any manufacturer needs to go through in order to achieve CE marking makes it an essential reading for any Pakistani manufacturer It also provides an example Technical File an essential component of the CE marking process which can be copied by and adapted to the specific situation of any manufacturer The develo
55. ompatibility EMC Directive Chapter 3 STAGES TOBE FOLLOWED FORCE MARKING Wo CO CO NN OO fF A A Na ee ee a ee a ee ee a O O CO GON NN NN DODD OT FP FW WN YN a OC CO 20 C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS Chapter 1 INTRODUCTION 1 1 CEmarking procedure The CE conformity marking and other regulatory compliance is required by law for all electric fans sold into the European Union which means that products without the marking cannot be sold there The CE marking is also required or recognised in other countries such as the Middle East North Africa and some ex Soviet republics However obtaining the CE marking is not an easy option The technical standards required are high the procedural aspects can be time consuming and the costs associated with testing and certification can also be relatively high Attempts to obtain the CE marking should therefore be undertaken only by manufacturers who are serious about wanting it who produce products of good quality who possibly already operate a Quality Management system according to ISO 9001 2008 and who are willing to put in the necessary time and effort For those manufacturers therefore this document explains the stages and gives examples of documents necessary to complete the process The stages towards CE marking are summarised below Each stage is then discussed in more detail in the following chapters
56. onized standards for electrical products are technically the same as IEC standards it is only the European EN version of the standard which allows the provisions of the directive to be met All harmonized standards ENs contain an Annex ZA which indicates which clauses of the standard are required for CE marking For some products there may be requirements in the standard which do not need to be satisfied for CE marking while some other standards may not cover all the essential requirements of the LVD in which case the manufacturer must find an alternative route to comply with those missing requirements this can only be known from the European version of any standard Manufacturers must hold a copy of the main standard s those which give product requirements they rely on to demonstrate compliance with the directive even if all the testing is done by a Notified Body For fans the main harmonized European Standard to apply is EN 60335 2 80 2003 Household and similar electrical appliances Safety Part 2 80 Particular requirements for fans which refers to EN 60335 1 2002 Household and similar electrical appliances Safety Part 1 General requirements All harmonized standards which support the LVD can be found on the internet at http ec europa eu enterprise sectors electrical documents lvd standardisation index_en htm So while applying for CE marking for equipment other than fans the appropriate standard to use can be found on this website
57. ould be done using a soft cloth and warm water only This product comes with a lifetime guarantee and is not designed to be repaired In case of problem return the product to the retailer Position the pedestal fan on a flat surface Do not allow children to play with the remote control unit 1 Improper installation may result in risk of fire electrical shock or injury to persons PA Be sure thatthe fan is connected with a grounded outlet box 3 It is ESSENTIAL that adequate clearance exists between the blades of the fan and adjacent walls furnishings etc Ifthe fan is operating abnormally cut the power off immediately for inspection T indicates suitable for tropical climates Children should be supervised to ensure that they do not play with the appliance ie D e For cleaning first of all disconnect the electrical supply for safety purposes Use a cloth with a neutral cleaning agentto clean the fan Then wipe it with a dry cloth 8 To vary the speeds select the position marked 1 for slow speed Position 3 for high speed of fan The position 0 is only for the off position 9 This appliance is not intended for use by persons including children with reduced physical sensory or mental capabilities or lack of experience and knowledge unless they have been given supervision or instruction 10 Type Y attachment if the supply card is damaged it must be replaced by the manufacturer his service agent or similarly qu
58. pment is declared shall be adequately taken into account As long as the primary objective that of ensuring the production of conforming products for which the type approval test results remain valid is met there are no other more specific requirements or definitions of FPC In practice an FPC system will be made up of incoming material and component checks in process tests and controls finished product testing and packaging shipment controls but the types and frequencies of these tests and controls are left to each individual manufacturer s discretion There is no direct third party control of FPC as a requirement for CE marking The FPC system has to be described in appropriate detail in the Technical File see the example in Annex 1 and the Notified Body should check that what is described is credible and adequate The directives also require manufacturers to hold FPC records for 10 years What this means therefore is that the obligation to control production appropriately falls entirely on the manufacturer Importantly if any non conformities with the product are detected or an accident is caused as a result of the product and the manufacturer could not produce results to demonstrate that FPC had been applied correctly he may well have committed an offence The EU directives themselves do not make the use of a certified ISO 9001 Quality Management system mandatory It is accepted though that if manufacturers have such a cert
59. pment of the Technical File is one of the key stages in the whole process and the example makes this stage a great deal easier Following the Guidance Document does not of course on its own guarantee that CE marking will be achieved the products themselves need to be good enough to meet the performance required of them This performance may initially be considered demanding and difficult to achieve but by achieving it our manufacturers can only stand to benefit The Guidance Document indirectly points to other areas where improvements can be made throughout the Pakistani appliance industry some of which have already been mentioned Wider adoption of ISO 9001 quality management systems brings a discipline from which all manufacturers can benefit improved productivity allows us to compete more effectively and efficiently while higher product performance levels allow us to compete on quality rather than simply price We need to take these improvements to heart if we are to have a healthy future for our industry This document too surely presents us as an industry with as many challenges as it does opportunities Can we for example enhance local testing capability so that we do not have to rely on laboratories in Europe Can we design products so that they meet the performance requirements the first time every time Can we improve component supplies so that hazardous substances are no longer an issue The choice seems clear either we rise
60. production process The manufacturer must therefore continue to produce the same products as were subject to type approval as described in the following final section Because the manufacturer claims conformity on the basis of applying standards it is difficult for him to accept his responsibility if he does not hold a copy of all the standards which have been applied even if these have actually been applied by the Notified Body or another third party He should therefore purchase and hold a copy of all standards related to product requirements but he does not need to hold test method standards 3 5 6 Continuation of production In order to maintain conformity the manufacturer must do the following keep the product and its component parts fundamentally unchanged inform the Notified Body of any changes to the product or its component parts which might have an effect on the product s conformity in respect of LVD EMC and Eco design for ROHS conformity if any component part is replaced either ensure that it has a ROHS certificate or have ittested have the type approval certificate renewed at whatever interval the Notified Body specifies monitor the European Commission s website to check for changes or updates to the relevant standards and maintain the Technical File fully up to date replacing test reports ROHS reports and or certificates the type approval certificate and the ISO 9001 certificate if applicable Th
61. rities The AR may also coordinate the work of one or more Notified Bodies but is not permitted to take on any of the responsibilities placed on the manufacturer Pakistani manufacturers have no obligation to appoint an AR The one instance where having one could be beneficial would be to coordinate the sending out of test samples if more than one test laboratory in the EU is involved in type approval testing The AR may also act as the importer in which case he takes on the responsibilities of an importer as described above 2 9 Market surveillance The CE marking of a product shows that in the European Union at least it is given a presumption of conformity with all applicable regulatory requirements which means that the letters indicate that the product has already been tested and shown to be safe As a matter of principle therefore a manufacturer who has followed all the steps in this Guide and has applied the CE marking correctly should not be subject to any market surveillance which includes customs actions Nonetheless because of the inherent risks involved with electrical goods this is asector where market surveillance authorities are particularly active This section describes briefly the possible actions and how manufacturers should respond Market surveillance authorities have three main ways of checking whether a product is legally placed in the 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR M
62. s may be resubmitted directly to the Notified Body while if they are more serious or there are too many of them it may be worth considering further screening tests first The Notified Body should only repeat those tests and or assessments which led to the failure and therefore the cost of this should be small however manufacturers need to be careful while changing the product to address one failure that they do not change it in a way that leads to a problem which did not exist before C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS 3 5 5 Drawing up of the Declaration of Conformity DOC Adraft DOC will have been drawn up in the preparation of the Technical File Once all the documentation required for CE marking test reports for LVD EMC and Eco design EC type approval certificate test reports certificates for ROHS components parts where these have been tested on behalf of the manufacturer and ROHS certificates from component part suppliers is available the manufacturer signs and dates the Declaration and includes this in the complete Technical File accepted by the Notified Body This is a crucial point in the process because it is the signature which indicates that the manufacturer accepts full responsibility for the safety and conformity of his products The manufacturer has to take this responsibility himself because after the initial tyoe approval testing there is no third party involvement in the
63. s not prescribe how protection against injury must be achieved only stating that protection must be offered In many cases the general safety requirements are made more specific in harmonised European Standards written in support of one or more directives For fans the European Standards based on IEC standards EN 60335 2 80and EN 60335 1 include various requirements and test methods which must be satisfied for the protection against physical injury requirement to be met Directives do not cover functionality which means for example that they do not set requirements on whether fans have a certain number of speeds whether they are designed for use in high temperatures or whether they have a particular power rating These aspects are left to each manufacturer to decide but once he has decided the product must be tested accordingly For example if a manufacturer wants his fan to be suitable for use in temperatures of 40 C or above then some of the tests have to be performed at this temperature One crucial aspect of all European Union EU directives is that conformity to their requirements is always done under the direct responsibility of the manufacturer This means in particular that the manufacturer is responsible for ensuring that every product he places on the market complies with the requirements of the directives and is properly CE marked if a product is found to not comply i e is unsafe action will be taken against the ma
64. s or families this needs to be stated in the Technical File together with the details of each family The test laboratory will verify that the requirement for different models being grouped is met but will refuse the manufacturer s proposal if it is not met Once families are accepted the test reports and type approval certificates need to state not only which model s were tested but also for which other models the results remain valid In this way it is clear that all models proposed by the manufacturer have been approved It is helpful and often required for photographs of the fan models together with any other products such as control units or remote controls to be included along with a circuit diagram Each model should be given a name and a type designation for identification purposes but there are no rules on how the type designation is created As already stated above the TF must contain a complete and accurate list of all the component parts used to make up the product This list should give the components as they would be broken down for ROHS testing to be performed hence describing one component as the Motor unit would be inadequate because the whole motor unit will never be ROHS tested as a whole instead it will be broken down into rotor armature copper wire etc The specification of each component part needs to be given in sufficient detail for it to be properly and uniquely identified and this may include for example
65. strictly limited in electric equipment and re cyclability electrical equipment should be recycled rather than thrown away as part of general household waste and products must be marked accordingly to ensure this The above requirements are set out in general terms in a series of EU directives which apply equally in all Member States This means that all Member States have agreed on what is meant by a safe product so a product judged safe in one Member State is also judged safe in all other Member States It also means that no Member State is allowed to impose additional requirements such as additional safety levels or mandatory product certification beyond those laid down in the directives The directives which apply to electric fans are 1 the Low Voltage Directive LVD 2006 95 EC which covers risks mainly of electrical and mechanical nature note that industrial fans are covered by the Machinery Directive MD 2006 42 EC instead which also applies to industrial versions of other products 2 the Electro magnetic Compatibility Directive EMC 2004 108 EC which covers the emission of and immunity to electro magnetic radiation 3 the Restriction of Hazardous Substances Directive ROHS II 2011 65 EC which limits the content of certain dangerous substances 4 the Eco design Directive 2009 125 EC which covers issues such as rated power and noise 5 the Waste Electrical and Electronic Equipment Directive W
66. thing Abo YI Circuit diagram Page 3 C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS 4 Description of materials and components in the product The motor unit is produced in house from electrical grade steel certified copper wire Type 1 ball bearings high temperature solder and varnish Suppliers are Electrical grade steel The Electrical Grade Steel Company Tokyo Japan Copper wire The Copper Wire Supply Company Tokyo Japan Ball bearings The Ball Bearing Supply Company Lahore Pakistan Solder The Solder Supply Company Lahore Pakistan Varnish The Varnish Supply Company Lahore Pakistan Casings guard and fan blades are injection moulded in house using Acrylonitrile Butadiene Styrene ABS supplied as pellets and designated Polylac and Polypropylene supplied as pellets The pedestal fan base and column are boughtin Suppliers are Polylac The Polylac Supply Company Taiwan Polypropylene Either The Polypropylene Supply Company 1 or The Polypropylene Supply Company 2 Fan base and column General Fan Supply Company Gujrat Pakistan The hand held remote control unit and Control module are supplied by Controls R us Tokyo Japan Paint The Paint Company Sialkot Pakistan Page 4 FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT CE MARKIN CE MARKIN GUIDE FOR MANUFACTURERS GUIDE FOR MANUFACTURERS 5 Manufacturing pro
67. tion of non conformities Manufacturers must deal with these and re submit products to defects the test laboratories until all of these are resolved Section 3 5 4 6 Drawing up of On receipt of satisfactory reports from the test laboratories the manufacturer Declaration of must draw up a DoC as proof that his product meets all regulatory requirements Conformity DoC The DoC allows the manufacturer to affix the CE marking Section 3 5 5 The CE marking applies to a product defined by its design its components its production system and its production control system Any changes to one or more of these which may have an effect on the conformity of the product may require re testing or re assessment Section 3 5 6 All manufacturers wishing to obtain the CE marking are strongly advised to inform themselves of the procedure and the requirements This can be done by studying this document by reading guidance on the internet by consulting with PCSIR Lahore and by discussion with CE marking Expert Trainers The Pakistan Electric Fan Manufacturers and Exporters Association in Gujrat may also be able to provide assistance This document is written specifically for fan manufacturers However many of the principles and procedures apply equally to other electrical equipment 01 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS 1 2 Regulatory background to the CE marking The European Union EU
68. tive 2004 108 EEC was demonstrated by applying the following two standards EN 55014 1 2006 A2 2011 EN 55014 2 1997 A2 2008 Compliance with these provisions is demonstrated by applying the harmonized European Standard with EC type examination performed by Notified Body ABC Satisfaction of the provisions of the ROHS Directive 2011 65 EU and the EU REACH Directive is demonstrated by the fact that all materials and components are certified to contain no regulated dangerous substances above the limits prescribed see certificates in Section 11 below Satisfaction of the Eco design Directive 2009 125 EU is demonstrated by assessment of maximum fan flow rate fan power input service value standby power consumption fan sound power level and maximum air velocity Page 10 4 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS These tests are performed by PCSIR Lahore Finally satisfaction of the Waste Electrical and Electronic Equipment WEEE Directive 2009 1 9 EU is ensured by marking the product with the symbol 9 Product marking IFL bracket and pedestal fans 500 mm mains powered are marked on the data plate with i the CE marking symbol indicating conformity with the Directives 2006 95 EC 2004 108 EEC 2011 65 EU and 2009 125 EC ii identification of the manufacturer and country of origin iii the model IFA WB or IFA PL Class 1 and diameter iv the rated voltage supply frequen
69. to and meet these challenges in which case our industry will prosper or we decline into relative obscurity losing out to our better prepared commercial rivals This Guidance Document is therefore highly recommended M Azhar Aslam Chairman Pakistan Electric Fan Manufacturers Association PEFMA FOREWORD There are as many as 200 manufacturers of electrical appliances and other electrical equipment in Pakistan based mainly in Gujrat and Gujranwala providing high levels of employment in these areas Among these manufacturers are those producing good quality products some of which are already exported others of which have the potential for export For those manufacturers able to export however markets in the Middle East Africa Asia and perhaps most importantly in the European Union EU a market of some 500 million people seem attractive A major reason preventing more manufacturers from exporting their products to the European Union is the regulatory requirements of Europe which finds its evidence in the need for electrical products to bear the CE conformity assessment marking Individual EU Member States have had safety requirements going back many years but with the introduction of the EU s Single Market especially since 1992 there is now just one set of regulatory requirements and one way of satisfying these requirements throughout the Union These regulatory requirements which relate mainly to safety enviro
70. to the TF provided that they are in a language usually English which can be understood by the Notified Body If at the time the TF is being prepared a User Manual does not yet exist and the text is therefore written for the first time in the file when the User Manual or user instructions are printed the text needs to be the same as that given in the TF because the Notified Body will have assessed its adequacy There are no minimum or maximum specifications on the length or content of the user information but the example given in Annex 1 is both typical and sufficient Although unrelated to conformity as stated above spelling and grammatical errors should be eliminated from the user instructions because otherwise this gives a bad impression to anyone reading those instructions 3 4 6 Compliance with regulatory requirements i e with all applicable directives It is the manufacturer s responsibility to identify all of the regulatory requirements i e directives with which he must comply in order for his product to be legally placed on the market In a very few cases there may be other national requirements not covered by EU directives and not included in the CE marking which also need to be complied with but it is beyond the scope of this Guide to attempt to identify these Ignorance of the existence of a regulatory requirement would not be accepted in the EU as justification for the manufacturer not applying it At the moment 2014
71. ts Option 1 should be possible for most major materials such as steel wires and cables capacitors and switches especially when these come from large international suppliers although Pakistani manufacturers should check 06 C MAR KI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS whether certificates they receive from suppliers are credible but it is not possible for many minor components such as screws nuts and bolts nor is it currently possible for many components and materials manufactured in Pakistan Option 3 if a third party test laboratory is involved depends on the approach taken by that laboratory Some laboratories are willing to exempt from testing those components and materials which clearly do not contain any of the restricted substances such as paper other laboratories insist on testing everything which is not covered by an ROHS certificate In order to allow testing to take place manufacturers must as part of the preparation of their Technical Files see Chapter 4 include a detailed list of all materials and components used in their fans together with the specification the name and address of the supplier and a copy of any ROHS certificate if this is used instead of testing This list needs to be thorough and accurate and should avoid using names for components which would not be understood by a test laboratory 2 5 TheEco design Directive 2009 125 EC The directive itself
72. ufacturers At the end of this programme in 2014 all of these aims have been met The procedure for CE marking is what is presented in this Guidance three Pakistani fan manufacturers have achieved the marking for 17 different models in total and a pool of Master Trainers whose details canbe found from TRTAII Islamabad exists The efforts of the TRTA II CE marking programme team should be appreciated here in particular Dr Adam Pinney who as an international CE marking expert provided invaluable strategic and technical advice and who wrote this Guidance Mr Badar ul Islam who managed the programme on behalf of TRTAII and Mr Qasar Wasique TRTAII Sector Expert who worked closely with the supported manufacturers The Electrical Laboratory at PCSIR Lahore should also be thanked in particular Engr Irfan Ahmad Rabbani and Mr Muhammad Azhar who provided invaluable testing and technical support throughout the project Messrs Wasique and Azhar in addition both qualified as Master Trainers We greatly acknowledge and appreciate the support of the European Union Delegation to Pakistan and the assistance of PITAD in developing this Guidance Bruno Valanzuolo Chief Technical Advisor CTA Trade Related Technical Assistance TRTA Il Programme United Nations Industrial Development Organisation UNIDO 1 1 1 2 2 1 2 10 3 1 3 2 3 3 3 4 3 5 Annex 1 CONTENTS Chapter 1 INTRODUCTION CE marking procedure Regu
73. uld know this The same situation applies in respect of EMC testing as for the LVD The EMC Directive does not require the intervention of a Notified Body but importers and customers do In addition there are no commercial EMC testing facilities in Pakistan so manufacturers are obliged to have their products tested by a foreign test laboratory 2 4 The Restriction of Hazardous Substances Directive ROHS Il This directive is relatively recent but it is important because it is the one which can cause problems for Pakistani fan manufacturers Its basic aim is to limit the content of six potentially hazardous substancesbelow the percentages by mass shown below Lead Pb 0 1 Mercury Hg 0 1 Cadmium Cd 0 01 Hexavalent Chromium Cr vi 0 1 Polybrominated biphenyls PBB 0 1 Polybrominated diphenyl ethers PBDE 0 1 These substances are most usually found in impure wires and cables chrome plated nuts bolts and screws and flame retardant plastic products manufacturers should aim to avoid using any of these lead in solder is excluded from the ROHS Directive There are three main ways in which manufacturers can satisfy the requirements of this directive 1 by using materials and components which have already been shown to be ROHS compliant by their suppliers and which are delivered with a ROHS compliant certificate 2 by testing of materials and components 3 by risk assessment of deemed to satisfy materials and componen
74. vant regulatory requirements In some cases the content of this documentation is described in the directive but there is no defined format which has to be used The various steps which manufacturers need to go through to obtain the CE marking are described in Chapter 3 Before that Chapter 2 discusses the application of directives and also presents sources of information which are important in the CE marking procedure so that manufacturers can understand what is expected of them and why allowing them to understand the steps given in Chapter 3 MARKI N FOR ELECTRIC FAN APPLIANCES AND EQUIPMENT GUIDE FOR MANUFACTURERS Chapter 2 THE APPLICATION OF DIRECTIVES 2 1 Introduction This chapter explains in more detail what the different directives require the manufacturer to do and how the manufacturer meets the directives requirements It also briefly covers the market surveillance activities and what manufacturers may expect from this While it is not crucial for manufacturers to understand all of the details of all directives the more they understand the better their position will be when discussing with importers Notified Bodies and customers 2 2 TheLow Voltage Directive LVD The LVD is the directive which covers all the electrical and mechanical safety aspects of electric fans and most other electrical equipment Although the EU s Machinery Directive also covers equipment with moving parts where the equipment is
75. y Declaration of Conformity 1 Products Acme bracket and pedestal fans mains powered Models IFA WB and IFA PL 2 Description Class 1 mains 220 240 V 50 60 Hz powered electrical equipment for internal use 3 Directives 2006 95 EC LVD electrical safety of low voltage devices 2004 108 EC EMC electromagnetic compatibility 2011 65 EU ROHS restriction of hazardous substances 2009 125 EC Eco design 4 Harmonized standards and other regulations EN 60335 2 80 2008 EN 55014 1 2006 A2 2011 EN 55014 2 1997 A2 2008 EN 50581 2012 Directive 2012 19 EU WEEE waste electrical and electronic equipment Regulation EU No 206 2012 implementing Directive 2009 125 EC Eco design requirements for air conditioners and comfort fans 5 Manufacturer International Fans Limited 123 Main Road Gujrat 50200 Pakistan As the manufacturer of the above products we declare on our own responsibility that the products referred to in 1 above are in conformity with all relevant requirements of the European Union specified in 3 and 4 This conformity is demonstrated by the following marking Stamp and signature POSITION sicdicehestaceimevedeeencnovexcweda DE E AA A AE A SINGO sesia e Rea Signed IN csr stescetpereeeecdcnsosencsespeienten Page 12

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