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Today, US ecommerce companies and Amazon sellers, import electronics directly from Chinese manufacturers – without even having a basic understanding of product safety requirements and liability.
Electronics are high risk products. Reports of unsafe lithium batteries and chargers are frequent.
A major reason for this is the lack of information on what US electronics importers must do to ensure compliance. Believe it or not, but for many electronic products, there are not even mandatory safety standards.
Hence, many believe that they don’t need to care about compliance when importing power banks, or any widget that comes with an AC adapter.
That is not the case.
If, or when, something goes wrong – you will be liable. If someone is injured, or if property is damaged, you might be looking at millions of dollars in losses. It’s game over.
Instead, Importers and Amazon sellers must rely on ‘voluntary standards’ from UL and ETL, that are ‘de facto’ mandatory. At least for anyone who want to sleep at night.
These things are complex, but absolutely essential.
Luckily, we have worked with Joey Kwok Deputy Manager of CMA Testing in Hong Kong, and a leading expert on US electronic product regulations.
Notice: Be sure to read this one at least two or three times, and feel free to ask questions in the comment section below.
Free Consultation (30 Min): Ask Questions About the Importing Process
Joey, please tell us a bit about what you do at CMA Testing in Hong Kong
CMA Testing, is a well-known third party assurance body with rapid global expansion, specializes in testing, inspection and certification services.
Our worldwide networks have been spreading out rapidly to Asia, Middle East, Europe and North America.
Our compliance services cover toys, consumer electronics and electrical products, textiles & garments, materials, chemicals, food & food contact articles, furniture, cosmetics, pharmaceutical products, environmental and more.
Most US Importers are aware of FCC regulations. What does it mean to ensure compliance with FCC regulations?
The Federal Communications Commission (FCC) governs the law of communications by radio, television, wire, satellite, and cable within the United States.
These regulations are covered in Federal law CFR 47. Any electrical and electronic product and RF [Radio Frequency] product shall comply with FCC rules to meet CFR47.
According to the FCC rules, the product shall comply with technical requirements, labelling requirements, user instructions and licensing.
a. For Technical standard, it is mainly based on ANSI standards.
b. For compliance, the product shall go through the authorization procedure of certification and Supplier Declaration of Conformity (sDoC).
c. For Certification (i.e., test reports), the testing shall be performed by an FCC accredited Laboratory.
d. For sDoC, the testing can be tested by any lab having the test capability [and accreditation] for FCC rules.
For Certification and sDOC, the manufacturer shall be ready the technical document such as a circuit diagram , block diagram, operation description, tune up procedure, software control, test report for the certification process and market surveillance.
Editor’s Note: The Importer is defined as a ‘Manufacturer’ in almost all cases. Hence, you should not expect foreign (non-US) OEM manufacturers to provide the required compliance documents or even provide general guidance concerning FCC compliance.
Right, so FCC regulations don’t cover any safety aspects?
FCC regulations only concern the interference on telecommunication network and frequency spectrum.
In other words, FCC governs the RF exposure to the human body by the transmission power from the transmitter for which the harmful radiation affect the human body.
Other than the radiation hazard emitted by the appliances, systems or components, FCC regulations do not cover any safety issues of any electrical device.
Are there any CPSC or other federal electrical safety regulations in the US?
For electrical safety, it is governed by OSHA on electrical safety in the workplace and by local code, NFPA 70 National Electrical Code (NEC), for example, applies to all telecommunication products.
Other than that, there is no mandatory federal law.
Okay, so it’s up to the Importer to comply with UL, ETL and other ‘voluntary standards’?
If the product is not used in the workplace and governed by NEC. Compliance with the NRTL certification, for example, UL and ETL, are voluntary.
It is up to the importer to comply with voluntary standards [i.e., UL or ETL]. More importantly, there are some retailers and buying offices in the United States that are imposing their in-house requirements based on UL or ETL standards, and other in-house standards
Editor’s Note: While there are no mandatory electrical safety standards for many products, you are still liable for any unsafe products you import and sell in the United States. As such, we strongly recommend that all US electronics importers ensure compliance with all relevant voluntary safety standards – for example those developed by UL or ETL.
What can happen If an Importer only ensures compliance with the legal minimum and don’t bother with UL or ETL standards?
Manufacturers [Importers] shall comply the legal requirement because they shall not violate the law. Other than the legal requirements, any other testing and certification is voluntary to show their product safe.
In US, most Americans are [more] likely to buy appliances with UL mark or other NRTL mark to ensure the safety of the product.
If the appliance does not bear any NRTL mark, it can be sold on the market, but it may not be chosen by consumers.
If manufacturers or importer only ensure the bare minimum, but not going for the (voluntary) UL or ETL certifications, they may face legal lawsuit by the state government if there is an accident.
When there is an accident involved by household electrical appliance, the California Lawyers will initiate a lawsuit based on this state law.
Editor’s Note: Ensuring compliance with ETL and UL helps you drastically reduce the risk of fire or electrical hazards. Hence, compliance with voluntary standards is always strongly recommended when selling electronics in the United States.
From an Importer perspective, how do I make sure that my product is UL or ETL compliant?
Check the label of the product to see whether any certification mark is bared and ask the manufacturer to provide the NRTL certificate to prove the product is NRTL certified.
On the other hand, you can use the NRTL certification number to double check whether the NRTL certificate is valid.
If the product does not bear any NRTL mark and does not tested for UL or ETL compliant, you can consult laboratory, for example, CMA, for the UL and ETL certification.
Editor’s Note: Some suppliers may have a limited selection of UL listed / tested products. However, the majority of products are not UL or ETL compliant. As an Importer, you will likely need to start the ‘compliance process’ from the very beginning – regardless of whether you import OEM or ODM electronics.
How do I find out which UL or ETL standards apply to a certain product?
UL and ETL certification is mainly based on UL and ANSI standard. You can go to UL website to check what standard is used for your product.
But, I recommend you may consult with lab cooperated with UL or ETL certification to help you to ensure the standard used for your product. It is because the certification body may have different interpretation on the use of standard.
Let’s say that I’ve sourced an ODM power bank from a supplier in Shenzhen, that I want to sell on Amazon.com. How do I know if this product can pass UL or ETL safety testing?
Check whether the powerbank is bare the NRTL mark associated with the up-to-date certificate and test reports: if there is any NRTL certificate provided.
Also, the customer can double check with the certification body (e.g. UL or ETL to validate the certificate and re-confirm the genuinity of the reports and certificates).
Otherwise, perform the UL or ETL certification.
Assume that I have created a custom designed electronic product. How do I make sure that the PCB and other components are compliant with UL or ETL?
First, make sure all the components used in the design are having UL certification.
If your supplier failed to provide the certificate, you can still test the component and design against the UL standard.
Moreover, please make sure your manufacturing plant are ready for the UL audit when your products required UL or ETL certification, because during the UL certification process, the certification body only accepts UL granted component certificates.
I reckon that CMA testing can also advise Importers on which electrical safety standards apply to their products?
That is depending on the product category, the usage (e.g. Indoor, outdoor, portable, build-in transformer, adapters or rechargeable batteries), and the countries of destination.
There is more than a single solution to ensure the product compliance, therefore CMA testing shall provide the consultancy what testing and certification shall be done, what testing and certification should be done, and what is applicable standard used.
Even the product is in development stage, we can provide prototype testing to check against the latest regulations
Thank you Joey. What kind of other services can you offer companies that want to sell electronics in the United States?
CMA is UL WDTP laboratory to perform the witness test for UL certification to provide the electrical safety test.
CMA is also FCC accredited Laboratory to perform FCC certification for RF product.
CMA is also CEC approved lab to perform the energy efficiency test for CEC and DoE. CMA is also providing chemical tests, such as California Proposition 65 and California RoHS.
Therefore, CMA can cover all related testing and certification for mandatory and voluntary basis.
How can they best get in touch with you?
Joey can be reached by phone or email:
Email: email@example.com or by calling directly on (+852)26908255
Free Consultation (30 Min): Ask Questions About the Importing Process
Co-founder of Asiaimportal (HK) Limited and based in Hong Kong. He has been quoted in and contributed to Bloomberg, SCMP, Alibaba Insights, Globalsources.com, China Chief Executive, Quartz Magazine and more.
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