This product has CE. A statement I often get, or this product is tested. What does that mean? It can be a lot but it can also be an empty shell. When you go deeper into the matter is when you find out what has actually been said. The problem is however that a lot of people do not go deeper and do not ask the questions that they need to ask to assure themselves of what they are buying.
So if somebody says I have CE, what does he mean by that. CE means basically that somebody from that company has declared that the product complies with the CE requirements. Or in some cases it is somebody who decides the put a sticker with CE on the product. That does not mean that the product is actually tested and found to be in compliance.
What to ask? You could start with asking according to which directives the product was declared to comply. In case of lighting that should generally be the LVD, EMC, RoHS and ErP directive. If somebody says “oh yeah we also have RoHS” than please be suspicious since RoHS is a CE directive and is not an add-on or a big plus!
So if this answer is already been given it comes nearer to what you need. Check if he has a certificate that shows the directives. If he does, check if the product is properly identified on the certificate. If it is not, the certificate is not connected to this product and therefore the product could be different.
What does a certificate actually say? Basically not so very much. A certificate is a statement that a product was tested according to the standards and/or directives mentioned and was found to be in compliance. This document generally has a important statement and that is that the conformity of the production is the responsibility of the manufacturer.
If the manufacturer is serious and the certificate details check out you can be fairly sure. The directives do require one other issue and that is that the manufacturer must implement a kind of quality control system to control the actual production output. Does he have that in place? Do you as an importer want to take that risk? Good question that you have to answer for yourself.
In the certification check I did not mention the test reports yet. For some people these are difficult to read but normally the last section of the report shows pictures of the tested product. This is not always the case but if it does it gives you another handle to identify the product when they are there. Also the ratings, component lists etc are mentioned in the report and these can be checked as well. This all gives you more and more hints in finding out if the product is actually the same as the tested product.
Making one last step. There is another option and that is called the approval mark. There are many approval marks available in the world but in general an approval mark does have also a production control mechanism build in. For example in ENEC a manufacturer is also checked on his quality system implementation and the test houses actually take products from the market and check them. There are also some tricky issue’s to consider here.
ENEC for example covers the low voltage directive but not the other directives. So an ENEC approved product should be in compliance with the LVD but could be non-compliant with the EMC directive. This is not a good situation but this situation is existing already for a long time. The market has not been asking for a change in that situation.
Maybe there is a case to be made for an approval mark that fully covers all the EU directives and in that covering the full CE scope for a product. The biggest challenge would be to provide a service that would be not to expensive. Maybe something for test houses to work on.
Jacob