EUROPEAN TESTING INSPECTION CERTIFICATION SYSTEM
ETICS
ETICS, the “European Testing, Inspection and Certification System”, is an international not-for-profit Association governed by the Belgian law.
ID: 535644220179-18
Lobbying Activity
Response to Evaluation of the Low Voltage Directive 2014/35/EU
27 Nov 2017
CEOC-ETICS-IFIA-VdTÜV: THE TESTING, INSPECTION, CERTIFICATION (TIC) FEDERATIONS CALL FOR A RE-VISION OF THE LOW VOLTAGE DIRECTIVE 2014/35/EU
CONFORMITY ASSESSMENT OF LVD PRODUCTS SHOULD BE REVIEWED TO RAISE COMPLIANCE
The level of conformity of LVD products in the internal market does not provide assurance that products comply with the requirements for protection of safety and health. In the context of market surveillance, it can be traced over a longer period of time that electrical products are often not compliant.
As the Rapid Exchange of Information System – rapid warning system for dangerous consumer products (RAPEX) has shown for many years, electrical appliances represent a significant part of all notifications on dangerous products. Behind textiles and toys they consistently have been number three in the ranking.
Independent testing of products before products enter the market represents a useful and necessary complement to market surveillance activities by national authorities. Unsafe products are identified early and before entry to the market. Based on the TIC Industry’s experience, approximately 50 percent of products presented for independent testing show non-compliances with the relevant requirements.
RESPOND TO INCREASED RISK POTENTIAL OF ELECTRICAL PRODUCTS
Through innovation, products in the course of their development, must satisfy new functional expectations. In short, products need new requirements and the European legislator has to adapt the regulatory framework for that.
Increasing risks with significant hazards can be observed in the area of mobile products such as battery operated products with increasing energy densities and dangerous electro chemicals used on or nearby the human body (for example: smart phones, tablets, power banks, Power tools, electronic cigarettes) and for laser operated products with high emitted energies (for example, Laser and LED bicycle (ultra) bright light, Lane laser, Laser distance laser pointer, LED (laser) flash light, Laser-LED head lamp).
As a consequence, in reviewing the LVD the European Commission is urged:
1. To include the aspect of information security in safety requirements for products, including smart products, in the respective annexes to swiftly close regulatory gaps.
2. To put the risk potential presented by products through a fundamental reassessment, while taking information security into account.
3. To assess and to adapt the applicable conformity assessment procedures in accordance with the newly determined risk potential of the product (based on the relevant conformity assessment modules).
4. To stipulate that an independent body (Notified Body) will be mandatorily involved where the risk potential of the product is significantly increased by the ICT components.
5. To grant this body suitable access to the product’s source codes/software when the product is to be assessed by a Notified Body.
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