Mind the Gap when exporting Electrical Products to the USA

The differences between EU standards for product safety and North American standards often seem minor, and sometimes trivial, but every year we learn of products that have been ‘red tagged’ or ‘held-up’ from being released onto the market simply because European manufacturers are unfamiliar with the equipment rules which are engaged by the Occupational Safety and Health Administration (OSHA), an organisation created by the United States Congress to assure safety and enforce standards. Although electrical product safety standards may seem similar, there are significant differences that need to be understood:- 1) Some equipment may be defined as ‘machinery’ in N. America, but not so in Europe and therefore needs to be assessed accordingly. 2) Operating voltage can change the scope of assessment. 3) Remarks made in N. American standards may imply from a European perspective that something is ‘informative’ whereas the language when translated actually means it is mandatory. 4) More detailed technical documentation is required for N. America. 5) Cables, their colour and rating, along with safety critical parts must be recognised for use in N. America and their regulatory paths fully documented. This may require subtle design changes to the product which would not meet European regulations and therefore might not have been considered. 6) Local laws in some states may impose material changes to the product which may result in expensive delays and potential design changes. Specific standards are the basis for enforcing compliance in N. America whereas in the EU, the requirement is simply to comply with all relevant Directives with the proviso that you may be required to prove conformity to a particular standard. Cranage-EMT has product testing laboratories in Ireland and the United Kingdom to certify your products for the North American market. The partnership between EMT in Ireland and Cranage in the United Kingdom provides a much needed resource for local manufacturers seeking regulatory assistance or technical interpretations on standards, and can analyse your existing certifications or approvals to identify what else you need to do.

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