For Product Safety Approvals, Uncertified and Improperly-Rated Components Require Surveillance

Electrical/electronic equipment manufacturers often ask if it is acceptable to use uncertified or improperly rated components in their products.  The following Frequently Asked Questions address the implications of using these components for North America product safety approvals

An uncertified power suppply?

What is an uncertified component?

Any safety critical component that is not certified by a suitably accredited agency and that does not provide surveillance comparable to that required by United States and Canadian regulatory schemes.

What is an example of an uncertified component?
Some examples include power supplies, transformers, plastics, insulation, adhesives, potting compounds and more.

Is an improperly rated component the same as an uncertified component?
No.  An improperly rated component is any safety critical component that, though it may be certified by a suitably accredited agency that does provide surveillance comparable to that required by United States and Canadian regulatory schemes, is not rated for the end-product application.

What is an example of an improperly rated component?
Some examples include power supplies connected to supply voltages greater than for which they are certified or flammable plastics rated for HB but required to be V-2 or better.

You used the term safety critical component – what does that mean?
Safety critical components are any component, material or substance that, if its performance or features change, can affect compliance with the essential safety requirements of the applicable standards.

Ok, I have equipment with uncertified/improperly rated components in it, what do I do now?
Usually the easiest route is to replace the component in question with one properly rated and certified for the end product application.  Second easiest is to have the component certified by its manufacturer, if that’s possible.  The final option is to have the component evaluated and tested by MET Labs, with a schedule for continued compliance.

I understand it may take more time and money to safety certify a product with uncertified/improperly rated components in it, but are there other implications also?
Yes.  If using uncertified components, there is no assurance of continued compliance even after evaluation and testing in product.  If certified but improperly rated, there is no assurance of continued compliance even if tested in product.  Changes may be made by the manufacturer that allow the item to remain compliant with original certification but that might cause it to become non-compliant in the end product application.

Is continued compliance a regulatory requirement?
Yes.  The United States and Canadian certification schemes require surveillance to assure continued compliance.  Surveillance applies to the end product and its components.

How is continued compliance enforced for a MET-certified component?
If a repeat of testing is not necessary and the item is not too complex to inspect at the same time as the end product inspection, the item may be described in detail in our report and our follow up inspector will verify continued compliance during the end product factory inspection.  It is necessary that the report contain sufficient product description and instructions for effective surveillance.

More complex components are returned to the laboratory on a minimum of an annual basis for reevaluation and perhaps some retesting.  Some components or circumstance might require more frequent surveillance. 

Contact us for a question about component integration into your equipment, or for a free quote for an upcoming product evaluation.

Leave a Comment

Your email address will not be published. Required fields are marked *