When it comes to electrical and electronic components and
systems, the major difference between the US and
European approach to product safety lies in the market
surveillance process.
US vs. EU
Market supervision is done more strictly in the USA, leading
therefore to a sense of certification duty when it comes to
E&E products. Due to geopolitical conditions, historically
evolved fears and requirements, accessing the US market
demands a more challenging product qualification process,
which includes production checks, inspections and product
certifications.
On the contrary, in Europe a lighter market supervision
process is the natural continuation of various EU guidelines
that only require the CE marking
(http://www.ee.sgs.com/ee_index/safety_ee/general_inform
ation_safety_ee/ce_mark_ee.htm) for a many products
getting into the EU market. CE marking is not accompanied
by any sort of mandatory production inspection or 3rd party
testing and certification requirements.
The different approaches to market supervision have
yielded different results. In the US there were 563 recalls of
unsafe products in 2008, whereas in Europe there were
1866 in the same period. These figures form nevertheless
only one indicator for which is the better system.
The goal is harmonization
As a result, the controversial harmonization of norms with
regards to the different product or environmental
requirements, be it supply voltage, fire hazard requirements
or product performance, is very difficult to achieve. The EU
is slowly adopting more stringent requirements, especially
with relation to hazardous substances, while the US is
developing new pieces of legislations that include the
requirements of EU norms.
Harmonization attempts are the best bet for a better future.
Conformity with a standard is the key to worldwide market
access.
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