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Putting product labelling to the test

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By eeNews Europe


During assessment of a product, it often becomes clear that end users or service persons need to be warned of a hazard in the equipment. For example, where large capacitors could electrically shock a service engineer, or moving parts have enough force to injure an operator. In these cases, we need warning markings, also known as instructional safeguards. Aside from warnings, product legislation always requires traceability marking. Electrical products also need rating markings for their connection to mains, fuse characteristics, and so on.

Product labelling requirements can feel confusing, as identifying the correct information buried in the legislation relating to a particular product can be difficult. Thankfully, there are some basic rules that can be applied. In this article I look at marking requirements for manufacturers and importers, consider warning symbols, text and legibility, and highlight the need for on-product versus packaging labelling.

 

Identification and traceability

Identification labels are intended to enable market traceability – back to the manufacturer, importer, or distributor. You must mark your full company name, as well as any trade name you use. Manufacturers must also put their name on their products. The EU requires that if the manufacturer is based in the Common Market, the product need only be marked with their address, even if the actual production is taking place elsewhere. On the other hand, if the manufacturer is based outside the EU, the product must be marked with both the manufacturer’s and importer’s address – the importer being whoever brings the product into the EU. Lastly, the distributor must check the manufacturer and importer marked the product properly. There is an exception to this for retail chains’ own-branded products, as these need only be marked with the importer’s and distributor’s address, so that they can protect their sources from competition.

Your identification label must include the type, batch, serial or model number, or another element that allows identification. Whatever is used, it must link to the product’s Declaration of Conformity and technical files.

Country of Origin (COO) need not be marked on a product in the EU. However, fair trading laws require that there is no false impression of origin, and customs laws require that import declaration documents must state COO. Internationally, other laws apply – for example, in the USA and Canada, COO marking is required.


Warning symbols and text

Where your product has some hazardous parts that must be exposed to let it work properly, the test standards make an allowance and you can alert the user with a warning marking. There are many standardised warning symbols, internationally recognised, which can be found in IEC 60417. These must be used together with an explanation of the symbol in your instruction manual – you cannot rely on the symbol alone.

Aside from being required in the test standards, it is always important to explain the warnings you give, so that users can understand why they are being told about a hazard. Telling the user that they may die if they ignore your warning gives it a lot more impact!

 

Label application

While it is generally well known that it is an offence to omit the CE Marking, WEEE marking, or a safety warning on a product, there is still confusion over the legal status of many marks. For example, it is not widely known that misusing such marks is also an offence. This includes applying the CE Marking on products that are not in any CE Marking directive’s scope.

EU law requires warning markings must be clear and legible. I recommend symbols should be at least 2.75mm high, and text is at least 1.5 mm high, and in a contrasting colour. I base this recommendation on EN 61010-1, a harmonised standard, whereas the law only requires the marking to be legible.

By EU guidance, if the product is large enough to accommodate the marking, it must go on the product. Aesthetic factors are no excuse for not applying markings directly to the product. Markings can instead be placed on the packaging only if the product is too small. Your markings must be visible for reference, which can be under a cover or door that the user can open, or on the rear or underside of a product, as long as it remains accessible.


Testing requirements

Markings must be durable and last the expected lifetime of the product. The standards for household and similar goods (EN 60335-1 and family), audio-visual equipment (EN 60065), IT & business equipment (EN 60950-1), and the combined IT & AV standard (EN 62368-1) therefore include a rub test applied to markings. The label is rubbed by hand for 15 seconds, firstly with a cloth soaked in water, and secondly with a cloth soaked in petroleum spirit. The test standard for laboratory and measuring equipment (EN 61010-1 and family) specifies a similar test, but using iso-propyl alcohol (IPA, propan-2-ol), for 30 seconds.

When checking the durability of the marking, the effects of normal use must be considered. For example, markings by means of paint (other than enamel coating) on handles or parts that are likely to be cleaned frequently is not considered to be durable. In such cases, engraving or embossing is therefore recommended.

Similarly, if your equipment uses harsh solvents, be sure to additionally test your markings against those solvents. There are many labels on the market claiming to be “solvent resistant”, but you must be careful to ensure that they are resistant to the right solvents for your application. For example, labels on a machine likely to be cleaned with an oily rag must be proof against oil, whereas those on an ink jet printer must be proof against the ink’s solvents.

Labels must not peel under test, and markings must remain legible. When any deterioration of the marking happens under test, it can be a sign that the marking is not durable enough for the long term.


Brexit considerations

Brexit is a fast-moving topic but no matter what happens next, EU Directives are already transposed into member states’ national law, so the UK’s legal framework will require little change. If there is a “no deal” Brexit, the UK will adopt a “UKCA” mark in place of CE marking. The UKCA draft legislation amends existing laws to include the UKCA Mark and change some terminology. For example, the term “harmonised standards” will change to “designated standards”, but the standards themselves will remain the same, so there will be a single standards model between the EU and UK. Consequently, for product labelling, very little will change.

 

A systematic approach

There is a lot of guidance online from the EU and national governments. A good starting point for guidance on CE marking is the EU’s “Europa” website: https://ec.europa.eu/growth/single-market/ce-marking_en

While product labelling may at first appear to be confusing, a systematic approach works best. Once you identify the directives and regulations that apply to your products, the labelling requirements simply follow.

About the author:

Alastair McLaughlin is Senior Engineer at TÜV SÜD – www.tuv-sud.co.uk


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