It has now become quite clear that Brussels and the information technology industry (on both sides of the Atlantic) are attacking on as many fronts as possible in their efforts to undermine the third-party-certification-based system that has been ensuring electrical safety in this country for over a hundred years. They wouldn’t phrase it this way of course. To make a long story short, the European Commission sees supplier’s of declaration of conformity (SDOC), which more or less prevails on the Continent, as all that’s necessary. The IT folks, meanwhile, are making an indirect (and in my view naïve) play for developing economy markets to the effect that if SDOC is acceptable in the States for their items (though the Commission would likely want to exploit any opening to greatly widen the product scope), then other governments (regardless of whether they have a record of voluntarily opening their markets) will adopt SDOC themselves. Plus, the high-teckers seem to forget that U.S. third-party requirements may be a major part of the reason why their equipment has become so safe in the first place, and that establishing SDOC here could open the floodgates to a wave of questionable goods from around the world.

NEMA is not categorically against SDOC. Our view is that the market should determine the appropriate means for establishing product compliance, and we recognize that there are situations where SDOC may be the preferred means. But third-party has long been the prevailing mode in the U.S. and consumers of all kinds (individuals, utilities, governments, etc.) have come to rely upon it. Imports can attain the marks. Foreign testing laboratories can qualify to do the testing. And as a matter of fact there’s a lot of public concern right now about product safety in general. In short, there’s no obvious reason to turn things on their head by making our conformity assessment requirements easier, and certainly not right now.

Nevertheless, the attack has been taken to several fronts, including:

  • The Transatlantic Economic Council (TEC), where the results of latest cabinet-level meeting were both a blessing and a curse. On the one hand, the U.S. Government rejected overtures to change by merely agreeing to re-open an OSHA public comment period on the merits of SDOC – and this served as a fig leaf that allowed TEC discussions to move on to other topics (where the Europeans did make some concessions). But we not talking closure either, with the new comment period representing an opportunity to “stuff the ballot box” and create the impression that SDOC is more widely supported than it really is. • Canada, where the full court press is also on.
  • The WTO and IEC, where the Europeans have submitted proposals to institutionalize SDOC for a wide range of products that includes large swaths of our product scope.
  • “Umbrella” trade associations such as the U.S. Chamber of Commerce, which has played a questionable “intermediary” TEC role up to now, and the National Association of Manufacturers, which the IT industry has also approached about adopting a pro-SDOC position.

NEMA and our members have begun objecting strongly on these fronts, but unfortunately there’s much more to do, be it with the Administration, Congress, press, and counterpart groups that support our position. As they say in football, we are definitely in the “red zone” now on this, so please contact me at joh_meakem@nema.org or (703) 841-3243 for more information on what you can do.


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