Most countries and markets, including the United States, the European Union, Canada and Australia, sets strict requirements for the performance and safety of electronics products. This should not come as a surprise, but the complexities of ensuring compliance with overseas electronics regulations and standards, in China, is not as obvious. In this article, we explain how you can avoid compliance issues and forced recalls in three, well, not so simple steps.
Step 1: Confirm Applicable Electronics Standards and Regulations in Your Market
While some standards or directives may apply to all types of electronics, others may apply specifically to certain devices and functions, for example WiFi and Bluetooth enabled products. The table below contains a brief summary of standards and regulations in the United States, the European Union and Australia:
| Standard / Regulation | Market | Description |
|---|---|---|
| FCC Part 15 (Intentional Radiators) | US | An intentional radiator is a device that is intended to emit radio energy. This scope includes any WiFi and Bluetooth Enabled device. |
| FCC Part 15 (Unintentional Radiators) | US | An unintentional radiator is, in 47 CFR 15.3, defined as any electrical device “operating at over 9000 pulses per second (9 kHz) and using digital techniques”. This definition includes most consumer electronics containing a chip, such as USB enabled devices, even if not equipped with a WiFi or Bluetooth transmitter. |
| UL | US | Underwriter Laboratories develops safety standards for electronics and components. While UL compliance is not required by law, most retailers will not buy products that are not UL certified / listed. UL compliance among Chinese manufacturers is very rare in most industries. |
| Low Voltage Directive | EU | The LVD applies to electronics, and components, with an input, or output, ranging between 50 to 1000 volts AC, and 75 to 1500 volts DC. As such, the Low Voltage Directive is not appicable to most handheld devices, but does cover, for example, phone and laptop chargers. |
| EMC Directive | EU | The EMC Directive is applicable to fixed electronic appliances. The purpose is to ensure that electrical equipment don’t interfere with other electronics, and signals, in its proximity. While the EMC Directive is applicable to a wide range of products, certification may not be mandatory for certain smaller devices, which are very unlikely to interfere with other electronics. |
| R&TTE | EU | The R&TTE directive is applicable to radio and telecommunication equipment. The scope of regulations includes both final products and individual components. Therefore, products with radio, WiFi and Bluetooth transmitters and receivers are required to comply. |
| Ecodesign | EU | The Ecodesign Directives is applicable to ‘energy-using’ electronics (and other products, such as insulation materials), including LED light bulbs, water boilers and other home appliances. |
| RoHS | EU | The RoHS directive restricts the amounts of certain substances in electronics, including lead, cadmium and mercury. Similiar legislation is being implemented in other countries around the world, including Korea and India. |
| AS/NZS3820 | AU/NZ | Framework regulation that applies to all electronics products imported to, and sold in, Australia and New Zealand. However, AS/NZS3820 is not a standard by itself, but requires the importer and/or manufacturer (if domestic) to ensure compliance with all applicable AU/NZS standards for electronics. |
Note: The table above is not listing all standards and regulations in the mentioned markets, applicable to electronics.
Electronics Labeling Requirements in the United States, EU and Australia
Many consumers are familiar with the various compliance marks and labels, commonly found on electronic products. The purpose of a compliance mark, such as the well known CE mark, is to signal that the device is manufactured in compliance with all applicable regulations and safety standards. Therefore, there is no such thing as a “CE standard” or “CE certificate”. Similar labeling requirements also exist in the United States and Australia.
| Sample | Mark | Market | Description |
|---|---|---|---|
 | CE | EU | The CE mark signals compliance with all applicable EN directives, for example the EMC Directive, R&TTE and RoHS. CE marking is mandatory, whenever applicable. |
 | WEEE | EU | Unlike the CE mark, the WEEE mark is not used to indicate compliance with any technical standard. Instead, the WEEE mark signals that the device must be handeled within a producer recycling scheme. |
 | FCC | US | Similar to the CE mark, the FCC mark signals compliance with all applicable FCC regulations. |
 | UL | US | The UL mark shows that the device is UL listed and approved. |
 | RCM | AU/NZ | Electronics products sold in Australia must bear the RCM mark. Starting in 2013, the RCM mark replaced both the C-tick and A-tick marks. As only Australian companies may register for RCM, Chinese manufacturers cannot provide ‘ready made’ compliance documents, further complicating the selection process for Australian importers. |
Note: The table above is not showing all mandatory, and voluntary, marks and labels applicable to electronics products, in the mentioned markets.
2. Finding Compliant Electronics Manufacturers in China
A minority, even among exporting oriented electronics manufacturers in China, is capable of ensuring compliance with overseas electronics standards. To do so, the assembly manufacturer must possess specific technical expertise, and the right component suppliers. Price is therefore not the primary selection criteria when sourcing electronics manufacturers, as compliance is, by far, the most important factor. To make things simple, the following table explains how you can differ between ‘compliant manufacturer’, and it’s non-compliant counterpart.
| Factor | CompliantSupplier | Non-CompliantSupplier |
|---|---|---|
| Documents | Can provide various Test Reports, Technical Documents and Certificates, issued by third parties (e.g. SGS and TUV) | Cannot provide authentic test reports or compliance documents. |
| Target Markets | Large export percentage to developed markets, mainly the EU and the US. | Focused on the domestic Chinese market, or other developing markets. May have a few, small, buyers in developed markets. |
| Registered Capital | Often above RMB 5,000,000. The more, the better. | Often below RMB 500,000. |
| Operation | Almost exclusively a manufacturer, but of varying size. | An agent, trading company, wholesaler or a manufacturer. |
| QMS | ISO 9001 Certified | Rarely managing production according a quality management system. |
| Price | Higher than non-compliant devices | Lower than compliant devices |
| MOQ | At least 500 pcs per SKU. These suppliers “make to order” and don’t keep stock waiting for potential buyers. | Anything from 1 pc to 1000 pcs. Traders can offer very low volumes, while domestically focused manufacturers still need to the same order volumes to maintain profitable, as their ‘compliant’ counterparts. |
In short, avoid traders, agents, wholesalers and manufacturers that can’t provide previous compliance (e.g. provide the right documents).
Step 3: Product Selection, Testing and Certification
Note that with ‘compliant manufacturer’, we are not referring to a factory exclusively making goods for the EU, US or Australia. The term refers to manufacturers with the ability to comply, and not that all their goods are compliant by default.
A ‘compliant manufacturer’ can manufacture both compliant, and non-compliant, ODM products. Whether or not an existing device is compliant can only be determined as following:
1. Select products that are already certified: All ‘compliant’ SKUs are listed on the relevant test reports and product certificates. Begin by listing SKUs of interest, and request the supplier to provide documentation for each.
2. Order a ‘Compliant Prototype’ to submit for testing and certification: If ‘your product’ is not already certified, which most likely is the case, you need to submit it for third party testing and certification. As the suppliers’ existing factory samples may not be fully compliant, you must first order a prototype manufactured in compliance with the relevant standard/s and directive/s. This sample must then be submitted for compliance testing to a third party, for example SGS or Bureau Veritas.
When developing OEM products, the only way to ensure compliance with electronics regulations is for obvious reasons the second option. However, even with all the compliance papers in hand, importers are wise to implement a reasonable testing strategy, to ensure that the manufacturer doesn’t attempt using cheap and substandard components, which in turn may render your product non-compliant, for the sake of shaving a few dollars off the unit cost. Such things are, as many of you already know, far from unheard of over here.
Dear Fredric thank you so much for the free information, i really appreciate. Now i have a question. I want to buy massage products from China to US, is that have to be certified? Is it better to ship through air cargo or ship?
Thank you sir