When developing a new product and then introducing it to the market there are a number of steps that need to be completed once the development nears completion. One of these steps is determining the conformance requirements necessary for the product and market into which it will be placed and the second is determining the correct product labelling for your new product.
For most general purpose products this involves confirming that your product complies with the European and/or UK regulations applicable to your product which will allow you to mark your products as CE or UKCA compliant. For the North American market there is also FCC. We will not discuss conformance requirements and testing in this document as it is a large topic in its own right and depends heavily on the type of product you are creating.
Once you have completed conformance testing then you need to consider how the product will be documented and labelled. In this document we will consider the labelling requirements for the UK, EU and US markets.
Following compliance testing for CE, UKCA and FCC the final product needs to be labelled correctly. The label, which you should affix to your product in a permanent and indelible way, has some mandatory elements and some discretionary or optional elements.
The mandatory elements include the CE/UKCA and FCC symbols shown above along with the WEEE symbol
In addition the label you affix to your product must indicate the following:
- Name of the manufacturer
- Batch ID or serial number allowing traceability of the product
- Contact details for the manufacturer
- Model number/version
- Input/Output Voltage (if powered by an external source)
- Safety Instructions (if required)
Selling products in the EU
If your product is being manufactured outside of the EU then according to EU regulations:
“Manufacturers in non-EU countries (the UK is now a non-EU country) who wish to sell their products in the EU (including NI) must appoint an economic operator established in the EU to act on their behalf.”
This means that if you are a UK manufacturer, or a distributor of products manufactured outside of the EU, you must have an EU based authorised representative known as an ‘Economic operator’. The product labelling must also include the contact details for this organisation as they accept full responsibility for the product in the European market.
Selling products in the USA
If you are placing your products in the US market then along with the FCC conformance the label must include
- Country of origin
- FCCID for the final product
- List of FCCIDs for any components/modules used in your product
In addition, for the USA the label must contain the following text:
“This device complies with part 15 of the FCC Rules. Operation is subject to the following two conditions:
(1) This device may not cause harmful interference, and
(2) this device must accept any interference received, including interference that may cause undesired operation.”
An example/template for a label attached to a product to be placed in the UK, EU and US markets is shown below:
Most manufacturers would also include a company logo or similar along with any proprietary information they may wish to add.
For more information on conformance, labelling and product design please contact Touché Technology today