The Ministry of Home affairs, with the collaboration of CABs (Conformity Assessment Bodies) and related test laboratories is currently establishing new requirements for the certification of IP phone terminals.

 Until now, these devices were mostly handled as leased line equipment for connection to public ethernet services, with test requirements limited to the measurement of pulses and impedance. The format of their certification number was DXX-XXXX or LXX-XXXX for digital devices.

 Electrical testing (physical layer) and voice-related measurements such as audio output power are now required. The new format for the certification number will be EXX-XXXX.

 A draft version of the test requirements is currently under review by the Ministry and it will be submitted for public comments on the Ministry home page by the end of the Year.

 The publication of the final regulations is expected for February 2011, and their application for April 2011.

 IP phones already certified as leased device won’t have to be re-certified again.  The new regulations will apply to all new devices used on the Japanese market after their enforcement.

Contact Ms Chun Kim for details on our experienced and efficient Japanese approvals.

New requirements on Machinery in Europe

On December 29^th 2009 a new Machinery Directive, 2006/42/EC, came into force in the EEA (EU + Iceland, Liechtenstein and Norway) and Switzerland. Exporters of machinery to the states in this area should analyse the provisions as there are important changes in the new directive. Some of these are explained in this article.

Person authorised to compile the technical file

One of the changes is directed towards manufacturers outside the EEA. A person, that is authorised to compile a technical file, has to be appointed. The name and address must be presented in the Declaration of Conformity or in the Declaration for Incorporation. The agreement between this person and the manufacturer must be in a written form.

Relation to LVD (low voltage directive), 2006/95/EC

The old Machinery Directive gave the manufacturer of machinery the authority to choose to comply with the machinery directive or with the low voltage directive, if the risk assessment indicated that the electrical risks were the predominant. The new directive does not provide  this entitlement. Instead, the new directive contains a list of machinery that are excluded as they are covered by LVD.

The essential health and safety requirements of the LVD are included in the new machinery directive.

Manuals

Each state in Europe requires the manuals to be written in its official language(s). The requirements of the old directive were often understood that it was only the safety instructions that had to be written in the member state’s official language(s).  The new directive is clear; Product manuals have to be written in the member state’s official language(s), otherwise the product must not be sold or taken into service.

Harmonised standards

Machinery that is manufactured in conformity with a harmonised standard is presumed to comply with the essential health and safety requirements covered by such a harmonised standard. It must be observed that all standards that were harmonised with the old directive are not automatically harmonised with the new directive.

Partly completed machinery

The scope of the new directive has been expanded. It comprises not only completed machinery but also partly completed, defined as “an assembly which is almost machinery but which cannot in itself perform a specific application”. The only requirement in the old Machinery Directive on partly completed machinery was that the manufacturer had to draw up a Manufacturer’s Declaration (annex IIb). In the new directive, article 13 explains what has to be done before partly completed machinery is placed on the market in the EEA:

1. 1.       The manufacturer of partly completed machinery or his authorised representative shall, before placing it on the market, ensure that:

(a)  the relevant technical documentation described in Annex VII, part B is prepared;

(b)  assembly instructions described in Annex VI are prepared;

(c)   a declaration of incorporation described in Annex II, part 1, section B has been drawn up.

1. 2.       The assembly instructions and the declaration of incorporation shall accompany the partly completed machinery until it is incorporated into the final machinery and shall then form part of the technical file for that machinery.

Summary

The new Machinery is explaining the responsibilities of the manufacturers and of the representatives in more plain terms. Furthermore, it requires additional liability and accountability for partially completed machinery so that even though it might form part of the complete machinery the manufacturer is still held accountable for their product ensuring liability in case if non-compliance with the essential occupational health and safety requirements.

As the new directive requires a representative having the authority to compile a technical file, a manufacturer in Australia should consider expanding this mandate. The authorities in the EEA will never address a manufacturer outside the EEA with questions if they doubt that a product doesn’t comply with the provisions of the machinery directive. Instead the importer will be considered manufacturer and eventually held responsible for non-compliance. This could potentially result in importers in the EEA all requiring copies of the technical file. Instead of sending copies to several importers, an authorised representative established in the can receive a written authorisation from the manufacturer to perform on behalf all or part of the obligations and formalities relating to the machinery directive.

Contact Approval Specialists for assistance in placing your product on the European Market.

Until this month, there has been a lack of uniform approach to certification in Japan of products that combine wireline technologies such as dial up, ISDN or Broadband, and RF/Wireless devices with 802.11a/b/g, UWB or cordless phone technologies.

This has now been clarified with JATE producing an english version here.. Interpretation_Art9. 

Please direct certification questions regarding JATE to Ms Chun Kim

In a clear wake up call to other energy efficiency regulators, the United States Department of Energy have from April 14, changed their requirements for MEPS registration of products under the Energy Star program.  “The EPA has strengthened its approval systems and is no longer relying on an automated approval process.   Companies are now required to submit complete lab reports and results for review and approval by EPA prior to labeling.  All new qualification applications will be reviewed and approved individually by EPA. ”

The certification process will be further strenghtened at the end of the year when only test results from approved, accredited labs will be accepted as evidence of compliance. 

For A2LA (The American Association for Laboratory Accreditation) accredited MEPS testing, contact our Australian lab www.austest.com.au

VCCI Council will commence enforcement of radiated disturbance limits above 1GHz for products subject to conformity verification report filing on and after October 1, 2010.

Curiously, for one year until September 2011 it is up to each member to decide whether or not they will opt in conformity assessment tests above 1GHz.

Confused ?  The VCCI are asking very nicely for companies to comply with the new limits prior to Sept 2011  ” let us ask you to positively go ahead and ship products conforming to the 1GHz+ requirement by filing conformity verification reports on and after October 1, 2010 as if there were no 1-year grace period. This is because VCCI runs its operation based on CISPR standards transposed to Japanese standard by the Information and Communication Committee, and July 2007 Japanese standard says implementation of 1GHz+ should start in 2010.”

Background for 1-year grace period

• EU Official Journal issued on August 21, 2009 states the valid period of EN55022:1998, European equivalence of CISPR22 Edition 3, is extended ubtil September 30, 2011. With this extension manufactures can select either CISPR22 Edition 3 or Edition 5 for product conformity until September 30, 2011.
• Similarly US FCC has announced that conformity assessment test can be based either on ANSI C63.4-2009 or ANSI C63.4-2003.
• Under such circumstances it is necessary for VCCI Council to establish the 1-year grace period for avoidance of creating potential technical barrier to trade against overseas product to be distributed in Japan and, at the same time, for affording Japanese manufacturers flexibility in choice of marketable products in the grace period.

(Courtesy VCCI Council).

Effective 1 Jan 2010, the Korea Customs Service has amended customs importation procedures for all products falling under the scope of KCC approval. 

The Ministry of Justice, Republic of Korea, has revised the designated notice of goods, per ”"Notice of Korea Customs Service, No. 2009-115 and Article 226 of Customs Act”,  with the revised notice effective as of January 01, 2010.

In summary, all products imported into Sth Korea must have an existing KCC approval in order to complete customs clearance.   This new examination of all products clearing customs is to ensure products designated for the Korean market have appropriate KCC certificates.

The procedure for importation of test samples prior to obtaining approval has not yet been released…..we will provide further updates as they come available.  For more information, contact http://www.approvalspecialists.com/contact_us/contact_us

Here’s a summary of NCC  approval requirements for Wireless Lan devices

Firstly, it’s important to note that Notebook PCs equipped with WLAN, BT or WWAN modules can’t be certified as a system approval.   Certification can only be achieved as a limited module within a specific host. The model and brand name of the laptop/host will then be listed on the certificate.

The applicant can be the module manufacturer or the Notebook PC manufacturer.

For WWAN modules applying for NCC approval, the main tests will be CNS 13438 and PLMN01/PLMN08.  Safety testing will be required when the EUT is a headset or some platforms such as laptop PCs with WWAN modules inside.  Per NCC 20090211 Technical Meeting Minutes, “platform” is defined as a device with multi-functions, for example, Notebook PC, fax machine; PDA, cell phone, USB modem dongle, game player are excluded.

CNS 14958-1 & CNS 14959 SAR testing is required only when the devices are designed to be used on a persons head, for example, cell phones.

For Class II permissive changes due to alternate/additional antennas used with a certified WWAN module, the ID will remain the same as the original. The technical justification policy of alternating antennas is same as LP0002 as follows:

• Same type antenna with higher gain, only radiated spurious emission test is required; same type antenna with lower gain, no test is required however registration is still needed.
• Different type antenna from original, only radiated spurious emission test is required.

Per NCC 20090602 Technical Meeting Minutes, all antennas’ specifications and photos shall be documented and submitted for review; and per NCC 20090406 Technical Meeting Minutes, all antennas submitted will be listed into NCC certificate as LP0002 applications.

For Class II permissive changes for adding a portable host as a laptop PC, additional tests of CNS 13438 EMI and CNS 14336 or  IEC 60950-1 Safety tests are required.  The ID will be the same as the original per NCC 20090427 Technical Meeting Minutes.

For WWAN devices applying for NCC applications, additional tests are required as follows, despite the tests being specified in the related standards of PLMN01 and PLMN08:

• Frequency error, including multi-path and vibration tests as specified in item 6 of section 3 of PLMN01/PLMN08.
• Radiated spurious emission tests as specified in item 5 of section 3 of PLMN01; and item 8 of section 3.1 and section 3.2 of PLMN08.
•  GCF test (or an attestation letter, declaring that the device has met the related requirements per Annex C of PLMN01).

Requests for Taiwan approvals can be made thru our approval specialists website contact page, http://www.approvalspecialists.com/contact_us/contact_us

As of 20 July 2009, EMC Directive 2004/108/EC will be in force, replacing EMC Directive 89/336/EEC.   

For products marketed in the European Union (EU) after 20 July 2009, all the applicable technical documentation and Declaration of Conformity (DoC) should be updated to include this new directive.

We will provide further analysis of the new directive in a separate post.