Global Best Practices on Product Safety Requirements for
Information Technology Products
March 2014
As the Government of Peru considers safety regulations for information technology products,
representing the global information technology industry DIGITALEUROPE, the Information
Technology Industry Council (ITI), and the Japan Electronics and Information Technology
Industries Association (JEITA) recommend the following global best practices:
Reference global standards
1.
Regulations should reference the globally accepted International Electrotechnical
Commission (IEC) standard for product safety (60950-1 second ed.)
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The international standard for information technology equipment (ITE) product safety
has had a long history. IEC 950 1st Edition was first published in 1986 (IEC 950 1st
Edition). In 1999, it was replaced by IEC 60950. The majority of the world has since
harmonized its adoption of national standards based IEC 60950-1 ed.2. We urge Peru
to adopt this standard edition and to synchronize with global adoption of future
revisions. Dedicated technical product experts from around the world have contributed
to the many revisions and supplements to ensure the safety requirements are wellgrounded in science and engineering to address real-world conditions.
As regulators are now considering adoption of the new hazard based safety standard,
IEC 62368-1, we recommend a five year transition period from IEC 60950-1 second
edition to the second edition of IEC 62368-1, which is currently being finalized for
publication.
2. Additionally, urge the Government of Peru to treat ITE as low risk and accept supplier’s
declaration of conformity and CB Scheme test reports.
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Based on the few safety recalls of IT products over the span of over 20 years, many
safety regulators view ITE product to pose a low safety risk. This is demonstrated by
the many countries which do not regulate for ITE product safety, and by those
countries that allow market access of ITE products under a Supplier's Declaration of
Conformity (SDoC) program.
The CE Marking process in the European Union is an excellent example of a successful
SDoC process. Regulators who have started out with certification schemes have often
instituted a declaration of conformity process after some time as they have found that
this model is risk proportionate, requires fewer resources on the part of the regulator,
and has been effective in achieving their objectives.
www.digitaleurope.org
www.itic.org
www.jeita.or.jp
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Member countries1 of the European Union and those countries that follow the EU
regulatory framework allow IT products to enter their markets based on supplier’s
declaration of conformity to the equivalent European standard EN 60950-1.
Other countries2 also permit market access of many IT product types based on
supplier’s declaration of conformity to the IEC 60950 standard.
The product safety risk profile posed by an IT product and its performance track record
are significantly different from product types from other industry sectors (e.g., electrical
appliances) and should not necessarily be regulated in the same method as these
other products.
SDoC offers Peru a least trade-restrictive way for its regulators to meet their objectives, as
opposed to mandating that IT products fall under Safety Certification or Self-regulatory Safety
Confirmation models. These latter two models may result in the increase in the price of
products or the limiting of their availability in Peru’s market due to the increased costs and
delays in time-to-market.
3. Lastly, the regulator should accept test reports from manufacturers’ labs and labs operating
under the IECEE CB Scheme.
As an additional option for approvals, industry recommends recognition of safety test reports
performed by a third-party certification body operating under the IECEE CB Scheme. The
IECEE CB Scheme facilitates trade by promoting harmonization of the national standards with
international Standards and cooperation among accepted certification bodies worldwide. In
addition, the CB Scheme includes acceptance of test reports from supervised and recognized
manufacturers’ test labs.
While Peru is not a direct participant in the CB Scheme, we encourage Peru’s regulators to
recognize CB reports and certificates without the need for additional testing, which might
otherwise be redundant and costly.
Product Labeling/M ark
With consumers already confused by many conformity marks on products and with the physical
size of many IT products decreasing in size, requirements for various marks present a practical
challenge. We recommend that the Government of Peru not require an additional mark for
safety on the product itself. This information can be communicated elsewhere, including
electronically via a link to web site provided by the manufacturer.
1
Countries include Austria, Belgium, Bulgaria, Czech R., Cyprus, Denmark, Estonia, Finland, France, Germany,
Greece, Hungary, Iceland, Ireland, Italy, Latvia, Lithuania, Liechtenstein, Luxembourg, Malta, Netherlands, Norway,
Portugal, Romania, Slovak R., Slovenia, Spain, Sweden, Switzerland, United Kingdom
2
Countries include but not limited to Australia and New Zealand, Japan, Egypt, Israel, Jordan, Morocco, Turkey,
United Arab Emirates. www.digitaleurope.org
www.itic.org
www.jeita.or.jp
If the Government of Peru finds it necessary to require a mark for safety, industry recommends
that it have the following attributes:
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Graphic only. No unnecessary information including variable data (alphanumeric), no
serial numbers, no supplier ID.
Minimal local language information.
Minimal size (actual size may be variable based on the product size)
No color or special printing requirements.
Permits the mark to be mass produced with minimal labor (e.g. molding) by the
manufacturer without prior communications with the regulating authority.
Allows alternative location of the marking on the product packaging or user
documentation.
Industry also recommends that the mark be required on either the package or product
and not both.
Exem pt professional highly specialized equipm ent (HSE) / com m ercial products
Highly specialized equipment, including products intended for commercial or industrial use, is
installed, operated, and maintained by professionals and it should not be regulated in the
same way as consumer products, as it does not pose a significant risk to the general public.
Avoid Retesting/Revalidation
In order to minimize trade restrictions, we support balancing limited pre-market requirements
with the establishment of reasonable post market surveillance. For example, annual market
surveillance which could require reissuing of certifications is unnecessary given fast innovation
cycle of IT products. In the end, the added costs of compliance with this requirement will be
passed on to the final consumer of the product. Revalidation of certifications should only be
required when new product lines are introduced. In addition, penalty and enforcement options
should be proportional. We would welcome the chance to discuss additional options to ensure
on-going compliance (e.g., renewal frequency, leverage follow-up services vs. factory audits,
etc.) in more detail.
Accountable Party
We recommend that the party responsible for submitting products for approval should be the
design or brand owner, rather than the factory where a product is manufactured. Unlike the
design or brand owner, factories have a limited ability to provide necessary information for
compliance.
Transition Period and Legacy Products
Industry would like to propose that new requirements for safety be applied with a transition
period of two years, as is common international practice, to allow manufacturers the time to
correctly implement the requirements. Given the complexity of global supply chains, this time
is essential to ensure compliance and a smooth transition.
www.digitaleurope.org
www.itic.org
www.jeita.or.jp
Industry also suggests that products already in the market or under a manufacture prior to the
date the regulation is enacted, and during the transition period, should be exempt from these
requirements. Industry recommends that this period of exemption be made indefinite, as
products are transitioned from store shelves.
DIGITALEUROPE, ITI, and JEITA and their members welcome this opportunity to work
together with the Government of Peru as it considers options to address product safety for ITE.
We offer our resources and global experience to help the Government of Peru meet its goals
and to ensure a smooth transition to these requirements, without disrupting Peruvian
consumers’ access to these vital products to the development of the digital economy.
www.digitaleurope.org
www.itic.org
www.jeita.or.jp