Importing Electrical Prodiucts - Labelling

[Rincewindwiz]

Hi All
Hope someone can help
We've been advised that power supplies (for UK domestic electric products) must have the power rating on the power supply
Our power supplies have Input and output voltage and amperage (typically Input 120 - 240 v 50-60Hz. Output 5v 1200ma).
We have been advised that these might not be compliant with UK regulations as the wattage (6 watts) is not specified explicitly

A brief count of power supplies in my office shows only 2 that have wattage explicitly. |The other 9 (which ibclude power supplies form BT, TP-Link and Tiveco) all report volts and amps (which allows watts to be calculated) but have no explicit wattage measurement

So will I have to add watts to the label or is voilts and amps sufficient?

 

[fisicx]

Can Archchancellor Ridcully not help with this?

 

[MBE2017]

I would recommend you check the legitimacy of your suppliers BS and or other certification certificates. This should have you covered, unfortunately many suppliers print anything on the product, and as the importer it is yourself that will be liable for say any house fires caused as a result.

 

[Rincewindwiz]

I would recommend you check the legitimacy of your suppliers BS and or other certification certificates. This should have you covered, unfortunately many suppliers print anything on the product, and as the importer it is yourself that will be liable for say any house fires caused as a result.

The suppliers are fine - we've been selling them for several years (but not in the UK) with no problems. The products passe the electrical tests with no probelm. Its just the labelling that is the issue

 

[Rincewindwiz]

Can Archchancellor Ridcully not help with this?

Trading Standards are immune to spells

 

[MOIC]

We've been advised that power supplies (for UK domestic electric products) must have the power rating on the power supply

Who advised you?

It's important to check test requirements and label compliance as these are periodically updated, not least with the current UKCA certification.

 

[Rincewindwiz]

Who advised you?

It's important to check test requirements and label compliance as these are periodically updated, not least with the current UKCA certification.

But where can I find the current labelling requirements?

 

[DontAsk]

Again, who advised you? Go back to them and ask for details.

 

[WaveJumper]

But where can I find the current labelling requirements?

Using the UKCA marking

Find out if you need to use the UKCA (UK Conformity Assessed) marking on products you manufacture or handle.

www.gov.uk

Electrical Equipment (Safety) Regulations 2016: Great Britain

www.gov.uk

 

[Rincewindwiz]

UKCA not required intil 2025 and needs a new declaration of conformity so not a practical short term solution

 

[Rincewindwiz]

Again, who advised you? Go back to them and ask for details.

Trasing Standards at Thurrock who pulled the shipment for non-compliance with labelling requriements. But I cant find the relevant legislation and it does seem no one else bothers so I was looking for a second opinion. Fixing the power supply label is expensive. THe other labelling issues are trivial

 

[MOIC]

UKCA not required intil 2025 and needs a new declaration of conformity so not a practical short term solution

1 January 2023

But where can I find the current labelling requirements?

Take your product and have the label conformity tested with SGS or Intertek. They will have the latest updates and what is required.

There are also independent technology testing companies you can also get advice from.

The above 2 options will cost you, but will give you the authority you need.

You should also get new certificates for each new tech product you have, before 1 Jan 2023.

 

[WaveJumper]

God if I had a pound over the years for every trader in a shopping centre fined and goods confiscated I would be a rich man. Those importing especially electrical items into the UK need to be totally aware of what they are purchasing do they conform to UK regs bla bla bla. Don't rely on what a foreign manufactory tells you as 9 times out of 10 they don't conform.

 

[Red Wood]

We are loosely in the Electrical business. You can only UKCA mark your products once you have a Declaration of performance and certification against the relevant standard, BS, VDE, TUV what ever it may be.

We are a small business in this sector which is mostly made up of very large ones and we spend 6 figures a year on testing and certification with various notified bodies.

 

[DontAsk]

We are loosely in the Electrical business. You can only UKCA mark your products once you have a Declaration of performance and certification against the relevant standard, BS, VDE, TUV what ever it may be.

We are a small business in this sector which is mostly made up of very large ones and we spend 6 figures a year on testing and certification with various notified bodies.

You can save a shed load by self declaring in many product areas, if you have the technical knowledge to understand the product, trust the supplier, etc., ...

 

[DontAsk]

Trasing Standards at Thurrock who pulled the shipment for non-compliance with labelling requriements. But I cant find the relevant legislation and it does seem no one else bothers so I was looking for a second opinion. Fixing the power supply label is expensive. THe other labelling issues are trivial

Are you sure they are not confused with "energy" labels for white goods, and the like?

Have you asked TS for the relevant link?

 

[DontAsk]

These probably don't help, but

Product Markings and Labels - In Compliance Magazine

Product markings and labels provide information about the product, installation, and use. The markings and labels can also provide warnings to avoid hazardous energy transfer to a body part. The product safety aspects of markings for identification, ratings, functions, connections, and warnings...

incompliancemag.com

https://www.epsma.org/wp-content/uploads/2021/01/CE-Marking-paper-final-9-7-18-1.pdf

Unless it's in something like the LVD (I can't find it), I think TS are talking out of their proverbial.

 

[Paul Kelly ICHYB]

Trasing Standards at Thurrock who pulled the shipment for non-compliance with labelling requriements.

They have to tell you what you are not complying with, not just a simple 'you are not complying'!

If TS have confiscated the goods and they are compliant, you could have grounds for a compensation claim (probably not a lot, though).

What is more expensive - labelling (if required) or losing the goods?

BTW, what exactly do you mean by 'power supplies'? 13a plug, transformer, PSU?

 

[Kitsunae]

UKCA not required intil 2025 and needs a new declaration of conformity so not a practical short term solution

so you have an existing DoC and CE mark on these goods?

 

[Paul Kelly ICHYB]

From what I remember, PSUs also need to comply with the Low Voltage Directive (LVD).

 

[Kitsunae]

Come to think of it, you have legal obligations as the importer of electrical equipment to ensure that it complies with the regulations.

One of those requires that you keep a copy of the technical documentation for the product. The technical documentation should specify what standards have been applied in the design and manufacture of the product. You can then look at those to see whether wattage has to be on the labels.

If the standard used doesn't require it, and the standard is one that gives a presumption of conformity, then you can go back to Trading Standards and show them why they're wrong. There's no point in the rest of us trying to remember all the potentially relevant standards across the world.

(But WaveJumper is right, you can't rely on an overseas manufacturer to know and correctly apply the local regulations. Especially since you're the one who'll be left holding the bag at the end of the day.)

ETA: This is all on the premise that relabelling is expensive. If it's cheaper, then it might be easier to do that.

 

[DontAsk]

From what I remember, PSUs also need to comply with the Low Voltage Directive (LVD).

Yes, but as I posted above, there doesn't seem to be anything about labelling.

 

[Rincewindwiz]

Using the UKCA marking

Find out if you need to use the UKCA (UK Conformity Assessed) marking on products you manufacture or handle.

www.gov.uk

Electrical Equipment (Safety) Regulations 2016: Great Britain

www.gov.uk

Thanks WaveJumper.
I have read through the 2016 regulations and can find no reference to to the need for volts, amps etc on the equipment

They have to tell you what you are not complying with, not just a simple 'you are not complying'!

If TS have confiscated the goods and they are compliant, you could have grounds for a compensation claim (probably not a lot, though).

What is more expensive - labelling (if required) or losing the goods?

BTW, what exactly do you mean by 'power supplies'? 13a plug, transformer, PSU?

Power supplies - take mains voltage and outputs 5v DC

They say labelling not compliant because watts is not on the label (input volts and input and output amps are)

A survey of 11 power supplies that I have driving various bits of kit in thie office (modem, USB, Phone, Laptop etc) shows only 2 out of the 11 have watts. They all have volts and amps. This I find strange to put it mildly.|

Cost to fix - best quote to fix is around £9k - £10k (because every product has to be opened, the power supply labelled and then closed again). A label on the outside of the product box would be no problem - maybe £1500

 

[Rincewindwiz]

1 January 2023



Take your product and have the label conformity tested with SGS or Intertek. They will have the latest updates and what is required.

There are also independent technology testing companies you can also get advice from.

The above 2 options will cost you, but will give you the authority you need.

You should also get new certificates for each new tech product you have, before 1 Jan 2023.

Thanks
Have approached SGS

 

[Red Wood]

You can save a shed load by self declaring in many product areas, if you have the technical knowledge to understand the product, trust the supplier, etc., ...

We supply sectors where self declaring CPR levels for example wouldn't get specified (bottom of the market). All require 3rd party testing for anything that's not being installed in a shed.

We have maybe 5 products we create our own declaration of conformity for, but these products are basic and limited.

 

[Rincewindwiz]

We supply sectors where self declaring CPR levels for example wouldn't get specified (bottom of the market). All require 3rd party testing for anything that's not being installed in a shed.

We have maybe 5 products we create our own declaration of conformity for, but these products are basic and limited.

yes and we do most of that, We've apparently been 'cauight out' on a technicality. Nothing to do with the product (which passed with flying colours) but a failure to put watts on the power supply - something that only 2 power supplies (out of 11) that I own actualy have - so Id like confirmation that it is a failure.

 

[Red Wood]

Who has advised you on the non conformity?

*Edit, TS advised you.

As mentioned above, challenge them, forcefully. Often they don't know as much as they think they do and will never be as expert in the field as those that they challenge. Low hanging fruits first.

 

[Kitsunae]

Thanks WaveJumper.
I have read through the 2016 regulations and can find no reference to to the need for volts, amps etc on the equipment

Product safety regulations don't have the actual requirements. They refer to the technical standards. There are different options for standards, so you have to know the standard that was applied to your device. Some require current rating, others require power rating.

As I said before, this should be in the technical documentation that you're supposed to have. Then you can look up the specific standard and say whether the labels comply. (ETA: More specifically, you can buy the standard to look at it. Because these are part of the law but are crazily not available unless you pay.)

 

[Rincewindwiz]

Product safety regulations don't have the actual requirements. They refer to the technical standards. There are different options for standards, so you have to know the standard that was applied to your device. Some require current rating, others require power rating.

As I said before, this should be in the technical documentation that you're supposed to have. Then you can look up the specific standard and say whether the labels comply. (ETA: More specifically, you can buy the standard to look at it. Because these are part of the law but are crazily not available unless you pay.)

Thank you for this. I had (eventually) come to broadly the same conclusion. And it seems power supply standards are not standard!! in that some demand power, some current and some will accept either!. I will ask the manufacturer (who hopefully has the standard!!) to copy and paste the relevant sections.

 

[WaveJumper]

I would personally as I think suggested above go back to the TS who advised and ask them to point you in the direction of where there advice comes from and where it is written ...... let them give you the specific link to what they are concerned about. wouldn't be surprised if they can't find one but do lets us know.

 

[Rincewindwiz]

I would personally as I think suggested above go back to the TS who advised and ask them to point you in the direction of where there advice comes from and where it is written ...... let them give you the specific link to what they are concerned about. wouldn't be surprised if they can't find one but do lets us know.

Absolutely and I tried that.
The product was inspected by TS Thurrock. Our office is in Hertfordshire so I talk to TS Herts. I have asked the question ("please provide a link or other reference to the standards that the product failed") and it has been ignored.

I suspect TS Herts are not fully supportive of TS Thurrocks decision but are toeing the party line and TS Thurrock wont talk to me

I cant see Herts budging unless I can find some actual evidence which is why I am searching for a copy of the relevant section of the Standard to which it was manufactured.

The Designer/manufacturer is in Australia; the product is made in China so communication is a slow process!!!

 

[Rincewindwiz]

So we have a resolution on the power supply labelling issue - for this consignment - and clear instructions on what to do in the future (unless the rules change again!).

I'm not sure I'd want to embarass TS by reporting the contradictory information/advice we were given at various stages especially as a sensible (in my view) solution has been approved by the local office who were extremely helpful throughout

Thanks to all those who contributed to my understanding of the issues

 

[DontAsk]

PLease do elaborate. What is the actual requirement and solution? Where are the require,ments stated?

 

[Rincewindwiz]

We screwed up by not having Mfr and Importer name and address anywhere (we had phone num bers websites, help desks, QR codes buit no address! (a specific requriement in the 2016 regs) but we agreed that ages ago

It was claimed by the inspecting TS people that absence of "input watts" (specifically input) on the actual power supply was enough to fail the item despite it being CE certified

Local TS determined that as Volts and amps was on the device and Watts was on the packaging and on the instructions and we were in post Brexit transition this would be OK for this consignment but get it right next time.
HTH

 

[DontAsk]

OK. I still find it difficult to believe, without sight of the relevant regs, which no one seems able to quote, that a power rating is required.

 

[Rincewindwiz]

OK. I still find it difficult to believe, without sight of the relevant regs, which no one seems able to quote, that a power rating is required.

The regs are in the standards (which are available on line for a fee of around £400!!) to which a product must conform in order to get CE certification. The products in question have this certification.
Trouble is the standards keep getting amended/updated and with Brexit transition in force its . . . . . . well lets just say 'confused'!

 

[MOIC]

You need to have it retested and have UKCA certifications (affective from Jan 1 2023). You'll also need the UKCA mark for selling in the UK & CE mark for selling in Europe & a whole bunch of marks for selling 'across the pond'.

The joys (and safety) of selling electronic products and power suppliers!

 

[Kitsunae]

The regs are in the standards (which are available on line for a fee of around £400!!) to which a product must conform in order to get CE certification. The products in question have this certification.
Trouble is the standards keep getting amended/updated and with Brexit transition in force its . . . . . . well lets just say 'confused'!

Did you find out what standard it was? I can see if I have access.

 

[Rincewindwiz]

Did you find out what standard it was? I can see if I have access.

We were certified to EN 62368-1: 2012+A11:2017 but I gather there is a later version / update

 

[Rincewindwiz]

You need to have it retested and have UKCA certifications (affective from Jan 1 2023). You'll also need the UKCA mark for selling in the UK & CE mark for selling in Europe & a whole bunch of marks for selling 'across the pond'.

The joys (and safety) of selling electronic products and power suppliers!

yes. I know. I have a meeting with local TS to make sure we are compliant. No deliveries due for several months so plenty of time to make sure it is in line with the rules . . . . until they 'update' the rules