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Is the Path to EU Market Access Slipping away from Germany?

Germany is considered a primary market entry point into the European market for electrical products.  And for good reason, it’s the fifth largest economy in the world with 81.4 million inhabitants and a GDP of 2.9 Trillion EUR.  Recent problems with Germany’s conformity assessment requirement have dulled some of that luster.  Product entry requires a manufacturer or importer to obtain the use of Germany’s voluntary GS Mark.  GS is short for “Geprüfte Sicherheit”, which means “safety-tested”.  Application of the GS Mark on an electrical product meant that it was tested and confirmed to European safety norms by a third party. 

While Germany remains one of the largest markets in Europe, the desirability for the GS Mark has come into question because of overzealous bureaucrats.  Procuring the GS Mark hit a rough patch last year when Germany’s Central Office of the Federal States for Safety Engineering (ZLS) ruled that for GS certification, a GS certifier was prohibited from accepting another certifier’s IECEE-CB certificate and test report to substantiate the safety portion of GS certification.  For example, a German certification body issuing the GS Mark could not accept an IECEE CB test certificate and report for GS certification unless they were the ones issuing it.  The ruling had the immediate effect of slamming on the brakes for imported electrical products.

Apparently what happened was when Germany implemented the European accreditation regulation, i.e., one accreditor per country, new people were brought onboard.  They decided to enforce prior decisions instead of relying on long standing interpretations which were used to implement the prior decisions.  This particular situation caused a good deal of uproar and was recently revised.  Today, IECEE CB test certificates and reports are once again accepted by GS certifiers as the base for granting the use of the GS Mark.  While this is a positive development, it is not total acceptance of the IECEE CB test certificates and reports.  That’s because ZLS has made acceptance conditional.  Any product testing conducted by a manufacturer, i.e., testing performed under RMT, SMT or WMT, is not allowed.  To voice your concerns, please send your comments to  Hopefully by you taking action this situation will be rectified fully.

Posted 09-20-2011 5:23 PM by Solis, Joel

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