CE Marking Wire and Cable – Necessity or Luxury?

A picture showing a selection of wire and cable products

When I set out to invest­ig­ate the need for CE Marks and <HAR> marks on wire and cable products, I would not have guessed that it would turn out to be as much of an odys­sey as it did. For most products, determ­in­ing the need for a CE Mark is rel­at­ively straight­for­ward, but not for wire and cable products! As equip­ment design­ers, engin­eers and tech­no­lo­gists, we rarely think much about wire and cable. We’re mostly con­cerned with the insu­la­tion col­ours, num­ber of con­duct­ors, the gauge, and the voltage rat­ing. Sometimes we’re also con­cerned about the tem­per­at­ure rat­ing, the flex­ib­il­ity, or per­haps the shield­ing. The reg­u­lat­ory approvals car­ried by the wire are often assumed, or not con­sidered at all. This com­mon product can bring a world of head­aches if the require­ments are not fully con­sidered.

Regulatory Requirements

North America

In North America, the three main reg­u­lat­ory organ­iz­a­tions for elec­tric­al com­pon­ent safety cer­ti­fic­a­tions are UL, CSA, and NOM. All three pub­lish stand­ards applic­able to wire and cable, and the mark­ings and com­mon wire styles, like TEW, AWM, MTW, and SOW, are driv­en by these stand­ards.

Europe – HAR Marking

What about Europe? The EU has a sep­ar­ate sys­tem for identi­fy­ing wire and cable, iden­ti­fied by the HAR Mark. Learn more about this mark.

Picture of the HAR Mark.
The <HAR> Mark

The HAR mark, which stands for “Harmonised”, has been based on the applic­a­tion of Harmonised Documents (HD) pub­lished by CENELEC, includ­ing the HD 21.X and HD 22.X fam­il­ies, which was replaced by the EN 50525 series of stand­ards effect­ive 2014-​01-​17. But what is the basis for mark­ing, and is there a leg­al require­ment for man­u­fac­tur­ers to use marked wire? The HAR Mark is one of the earli­est com­mon marks in the EU, ori­gin­at­ing from an agree­ment signed in 1974. Manufacturers who wish to use the HAR Mark are required to meet strin­gent qual­ity con­trol require­ments before being gran­ted the right to use the HAR mark. Wire and cable products bear­ing the HAR mark are accep­ted by all of the sig­nat­ory states to the HAR agree­ment. (Need to know more? Have a look at the EEPCA web site.) The HAR mark is not leg­ally required, but using products bear­ing the HAR Mark may make a manufacturer’s life a bit easi­er when deal­ing with author­it­ies.

Europe – CE Marking

What about the CE Mark for wire and cable?  To answer that ques­tion, we need to look at the CE Marking require­ments in more detail. In gen­er­al, CE Marking Directives are aimed at products, not at com­pon­ents, although there are some excep­tions. Wire and cable products are one of those excep­tions that stand out. On its own, wire or cable has no defined use or applic­a­tion, in that it must be built into some­thing to be use­ful. The com­pli­ance of the final product con­tain­ing the wire products is determ­ined based on test­ing related to the fin­ished product, and the com­pli­ance of the wire used in the product is based on the spe­cif­ic applic­a­tion and the wire product’s per­form­ance in that product. So why are wire and cable products CE Marked on their own?

Determining the Right Directives

Most dir­ect­ives require that products with­in the scope have some defined func­tion, like the Machinery Directive’s defin­i­tion of a machine:

…an assembly, fit­ted with or inten­ded to be fit­ted with a drive sys­tem oth­er than dir­ectly applied human or anim­al effort, con­sist­ing of linked parts or com­pon­ents, at least one of which moves, and which are joined togeth­er for a spe­cif­ic applic­a­tion…”, [1]

or the EMC Directive defin­i­tion of “appar­at­us”:

…‘appar­at­us’ means any fin­ished appli­ance or com­bin­a­tion there­of made com­mer­cially avail­able as a single func­tion­al unit, inten­ded for the end user and liable to gen­er­ate elec­tro­mag­net­ic dis­turb­ance, or the per­form­ance of which is liable to be affected by such dis­turb­ance…” [2]

Clearly, these defin­i­tions don’t include com­pon­ents. So what dir­ect­ives do apply to wire products? The first dir­ect­ive that comes to mind is the Low Voltage Directive. If we take a look at the defin­i­tions in the Directive [3] we find:

Article 1

For the pur­poses of this Directive, ‘elec­tric­al equip­ment’ means any equip­ment designed for use with a voltage rat­ing of between 50 and 1 000 V for altern­at­ing cur­rent and between 75 and 1 500 V for dir­ect cur­rent, oth­er than the equip­ment and phe­nom­ena lis­ted in Annex II.

Once again, we have a pretty spe­cif­ic defin­i­tion for the tar­get of the Directive: “elec­tric­al equip­ment”. Or do we? What, exactly, is “elec­tric­al equip­ment”? The Directive doesn’t define this term, but it does give us a list of exclu­sions in Annex II [3]:

Annex II

  • Equipment and Phenomena out­side the Scope of this Directive
  • Electrical equip­ment for use in an explos­ive atmo­sphere
  • Electrical equip­ment for radi­ology and med­ic­al pur­poses
  • Electrical parts for goods and pas­sen­ger lifts
  • Electricity meters
  • Plugs and sock­et out­lets for domest­ic use
  • Electric fence con­trol­lers
  • Radio-​electrical inter­fer­ence
  • Specialised elec­tric­al equip­ment, for use on ships, air­craft or rail­ways, which com­plies with the safety pro­vi­sions drawn up by inter­na­tion­al bod­ies in which the Member States par­ti­cip­ate.

At this point, it doesn’t look like wire products are included in the dir­ect­ive. No fur­ther defin­i­tion of “elec­tric­al equip­ment” is giv­en, and wire and cable are not spe­cific­ally excluded in Annex II. Where do we go from here to bet­ter under­stand the defin­i­tion of “elec­tric­al equip­ment”?

The IEC pub­lishes the International Electrotechnical Vocabulary (IEV), IEC 60050 [4], defin­ing hun­dreds of terms related to electro-​technical top­ics. This is the next logic­al step in try­ing to under­stand what is covered. Definitions in the IEV are numbered as a means to cata­log the terms, and I’ve provided the defin­i­tion num­bers for ref­er­ence. Unfortunately, the IEV does not con­tain a defin­i­tion for “elec­tric­al equip­ment”, but it does define “equip­ment” [3, 151 – 11-​25]:

equip­ment – single appar­at­us or set of devices or appar­at­uses, or the set of main devices of an install­a­tion, or all devices neces­sary to per­form a spe­cif­ic task

Note – Examples of equip­ment are a power trans­former, the equip­ment of a sub­sta­tion, meas­ur­ing equip­ment.

The defin­i­tion uses the term “appar­at­us”, which con­tin­ues the lack of clar­ity. Is wire appar­at­us? Looking up the defin­i­tion for “Apparatus” 151 – 11-​22, the IEV gives us:

appar­at­us – device or assembly of devices which can be used as an inde­pend­ent unit for spe­cif­ic func­tions

Note – In English, the term “appar­at­us” some­times implies use by skilled per­sons for pro­fes­sion­al pur­poses.

Wire clearly doesn’t meet the defin­i­tion for appar­at­us, since it couldn’t be con­sidered and “inde­pend­ent unit for a spe­cif­ic func­tion”, so is wire a device? Now we have one more term to try to under­stand. The defin­i­tion for “device” is found in the IEV at 151 – 11-​20:

device – mater­i­al ele­ment or assembly of such ele­ments inten­ded to per­form a required func­tion

Note – A device may form part of a lar­ger device.

Now we’re get­ting some­where. Wire could def­in­itely be con­sidered to be a “mater­i­al ele­ment”, but we’re stuck again at the need to “per­form a required func­tion”. One more term might apply. Let’s look at “com­pon­ents”. The defin­i­tion for a “com­pon­ent” is found at 151 – 11-​21:

com­pon­ent – con­stitu­ent part of a device which can­not be phys­ic­ally divided into smal­ler parts without los­ing its par­tic­u­lar func­tion

Now we’ve got it! Wire is clearly a com­pon­ent, and this clearly makes sense when you con­sider the use we make of wire and cable products. But how does this relate back to the leg­al defin­i­tion of “elec­tric­al equip­ment”? Since the IEV is not called out by the Directive, we can’t lean on this defin­i­tion alone to decide the applic­ab­il­ity of the CE Mark to these products.

Low Voltage Directive Requirements

The EU Commission pub­lishes a Guide for most of the Directives, and the Low Voltage Directive is no dif­fer­ent. There is little dir­ect ref­er­ence to wire and cable products, how­ever, [5, para. 8] does men­tion it in broad terms, “…the Directive cov­ers con­sumer and cap­it­al goods designed to oper­ate with­in those voltage lim­its, includ­ing in par­tic­u­lar, …elec­tric­al wir­ing, appli­ance couplers and cord sets…” [5, Annex II] provides a pictori­al list of products, illus­trat­ing the cord set require­ment. Within the voltage lim­its set by the scope of the LVD, the require­ment for cord sets and oth­er “safety crit­ic­al” sub-​assemblies that include wire or cable makes sense. A com­pleted cord set with an IEC 320 con­nect­or on one end and a coun­try spe­cif­ic plug, like a a CEE plug cap, is a com­plete product with a defined end-​use, and so fits the scope. This seems to answer the ori­gin­al ques­tion: “Do wire & cable products, on their own, require a CE Mark?”, at least under the LVD. The next ques­tion must be: “Are there any oth­er CE Marking Directives that might apply?”

RoHS and WEEE Directives

We can exclude the EMC Directive, since the defin­i­tion of appar­at­us in that dir­ect­ive is quite clear. What about RoHS [6], and WEEE [7]? Let’s look at RoHS and WEEE togeth­er, since these two Directives are linked in applic­a­tion. The 2011 RoHS dir­ect­ive [8] includes some defin­i­tions of what elec­tric­al and elec­tron­ic equip­ment is, and includes two key defin­i­tions for machine build­ers:

Article 3 

Definitions

For the pur­poses of this Directive, the fol­low­ing defin­i­tions shall apply:

  1. elec­tric­al and elec­tron­ic equip­ment’ or ‘EEE’ means equip­ment which is depend­ent on elec­tric cur­rents or elec­tro­mag­net­ic fields in order to work prop­erly and equip­ment for the gen­er­a­tion, trans­fer and meas­ure­ment of such cur­rents and fields and designed for use with a voltage rat­ing not exceed­ing 1 000 volts for altern­at­ing cur­rent and 1 500 volts for dir­ect cur­rent; 
  2. for the pur­poses of point 1, ‘depend­ent ‘ means, with regard to EEE, need­ing elec­tric cur­rents or elec­tro­mag­net­ic fields to ful­fil at least one inten­ded func­tion; 
  3. large-​scale sta­tion­ary indus­tri­al tools’ means a large-​scale assembly of machines, equip­ment, and/​or com­pon­ents, func­tion­ing togeth­er for a spe­cif­ic applic­a­tion, per­man­ently installed and de-​installed by pro­fes­sion­als at a giv­en place, and used and main­tained by pro­fes­sion­als in an indus­tri­al man­u­fac­tur­ing facil­ity or research and devel­op­ment facil­ity; 
  4. large-​scale fixed install­a­tion’ means a large-​scale com­bin­a­tion of sev­er­al types of appar­at­us and, where applic­able, oth­er devices, which are assembled and installed by pro­fes­sion­als, inten­ded to be used per­man­ently in a pre-​defined and ded­ic­ated loc­a­tion, and de-​installed by pro­fes­sion­als; 
  5. cables’ means all cables with a rated voltage of less than 250 volts that serve as a con­nec­tion or an exten­sion to con­nect EEE to the elec­tric­al out­let or to con­nect two or more EEE to each oth­er; [7]

The term “large-​scale” is nev­er defined in the dir­ect­ive. So what is “Large-​scale” when it comes to machine tools? An explan­a­tion of the term is giv­en in two places, [9] and [11]. The over­all descrip­tions get a bit involved, but essen­tially it comes down to products that weigh 3 tons or more, or are at least 2.5 m x 2.5 m. Anything smal­ler than this is not con­sidered “large-​scale” and is there­fore with­in the scope of the WEEE Directive. Some examples of “large-​scale sta­tion­ary indus­tri­al tools” include [9]:

  • Machines for the indus­tri­al pro­duc­tion and pro­cessing of mater­i­als and goods, such as
    • CNC lathes;
    • Bridge-​type milling and drilling machines;
    • Metal form­ing presses;
    • Newspaper print­ing presses;
  • Machines for the test­ing of work pieces, such as
    • Electron beam, laser, bright light, and deep ultra viol­et defect detec­tion sys­tems;
    • Automated integ­rated cir­cuit board and prin­ted wir­ing board test­ers;
  • Cranes;
  • Other machinery of sim­il­ar size, com­plex­ity and weight.

What then, is a “large-​scale fixed install­a­tion”? [9] can help us out here too. Some examples are giv­en in the FAQ:

  • Production and pro­cessing lines, includ­ing robots and machine tools (indus­tri­al, food, print media etc.);
  • Passenger lifts;
  • Conveyor trans­port sys­tems;
  • Automated stor­age sys­tems;
  • Electrical dis­tri­bu­tion sys­tems such as gen­er­at­ors;
  • Railway sig­nalling infra­struc­ture;
  • Fixed installed cool­ing, air con­di­tion­ing, and refri­ger­at­ing sys­tems or heat­ing sys­tems designed exclus­ively for non-​residential use.

So, machine tools that weigh less than 3 tons, or are smal­ler than 2.5 x 2.5 m, are included in the scope of the RoHS dir­ect­ives, but machines lar­ger that this, or sys­tems that fit the descrip­tions of Large Scale Fixed Installations are out. What about WEEE? The WEEE Directive gives us some sim­il­ar defin­i­tions in Article 3:

For the pur­poses of this Directive, the fol­low­ing defin­i­tions shall apply:

  1. large-​scale sta­tion­ary indus­tri­al tools’ means a large size assembly of machines, equip­ment, and/​or com­pon­ents, func­tion­ing togeth­er for a spe­cif­ic applic­a­tion, per­man­ently installed and de-​installed by pro­fes­sion­als at a giv­en place, and used and main­tained by pro­fes­sion­als in an indus­tri­al man­u­fac­tur­ing facil­ity or research and devel­op­ment facil­ity;
  2. large-​scale fixed install­a­tion’ means a large-​size com­bin­a­tion of sev­er­al types of appar­at­us and, where applic­able, oth­er devices, which: 
  3. are assembled, installed and de-​installed by pro­fes­sion­als; 
  4. are inten­ded to be used per­man­ently as part of a build­ing or a struc­ture at a pre-​defined and ded­ic­ated loc­a­tion; and 
  5. can only be replaced by the same spe­cific­ally designed equip­ment; 

WEEE also provides anoth­er list of products to con­sider in [8, Annexes I & II]. From the point of view of machine build­ers we need only look at Annex II, 6., which lists exclu­sions:

6. ELECTRICAL AND ELECTRONIC TOOLS (WITH THE EXCEPTION OF LARGE-​SCALE STATIONARY INDUSTRIAL TOOLS)

  • Drills 
  • Saws 
  • Sewing machines 
  • Equipment for turn­ing, milling, sand­ing, grind­ing, saw­ing, cut­ting, shear­ing, drilling, mak­ing holes, punch­ing, fold­ing, bend­ing or sim­il­ar pro­cessing of wood, met­al and oth­er mater­i­als 
  • Tools for riv­et­ing, nail­ing or screw­ing or remov­ing riv­ets, nails, screws or sim­il­ar uses 
  • Tools for weld­ing, sol­der­ing or sim­il­ar use 
  • Equipment for spray­ing, spread­ing, dis­pers­ing or oth­er treat­ment of liquid or gaseous sub­stances by oth­er means 
  • Tools for mow­ing or oth­er garden­ing activ­it­ies 

If we take the inter­pret­a­tion of “large-​scale” as [11], then it becomes clear that WEEE does not include most heavy machinery. Smaller equip­ment, i.e. not “large scale”, would be included. Seems clear enough, but how does this relate back to wire and cable?

In read­ing [9, Q5.2], we find that “Internal wires are not cables. Internal wir­ing in any EEE that is with­in the scope of RoHS 2 must simply meet the mater­i­al restric­tions like all oth­er parts of the EEE; there is no indi­vidu­al CE mark­ing and DoC require­ment. If an EEE is sub­ject to a trans­ition peri­od or a scope exclu­sion, the same applies to the intern­al wir­ing. The same prin­ciple applies to per­man­ently attached cables, e.g. most lamp cables.” [9, Q5.3] con­tin­ues this line of reas­on­ing in rela­tion to extern­al cables, adding, “External cables that form part of anoth­er EEE because they are sold togeth­er or marketed/​shipped for use with an EEE, e.g. power cords, must meet the mater­i­al restric­tions but do not need an indi­vidu­al CE mark­ing and Declaration of Conformity if they are covered by the DoC for the EEE and the EEE is CE marked.” The com­ment regard­ing the applic­ab­il­ity of the CE mark applies only to the RoHS Directive require­ments.

Reading the defin­i­tions is nev­er enough. The exclu­sions to the RoHS Directive [11, Art. 2] include some import­ant points:

4. This Directive does not apply to:

c) equip­ment which is spe­cific­ally designed, and is to be installed, as part of anoth­er type of equip­ment that is excluded or does not fall with­in the scope of this Directive, which can ful­fil its func­tion only if it is part of that equip­ment, and which can be replaced only by the same spe­cific­ally designed equip­ment;
d) large-​scale sta­tion­ary indus­tri­al tools;
e) large-​scale fixed install­a­tions;
j) equip­ment spe­cific­ally designed solely for the pur­poses of research and devel­op­ment only made avail­able on a business-​to-​business basis.

So machinery that is not either a large-​scale sta­tion­ary machine tool nor a large scale fixed install­a­tion is with­in the scope of the RoHS and WEEE Directives.

Summing Up

It looks like we have the full pic­ture now, so let’s recap. Wire and cable products:

  • are included in the LVD, des­pite their usu­al clas­si­fic­a­tion as com­pon­ents, and there­fore require CE Marking under this dir­ect­ive
  • are excluded from RoHS and WEEE when in com­pon­ent form,
  • are included in RoHS and WEEE when used in small-​scale machinery (i.e., not large-​scale sta­tion­ary indus­tri­al tools or a large-​scale fixed install­a­tion), con­sumer products, and med­ic­al devices that are not in-​vitro or act­ive implant­able devices

So why are these products CE marked when in com­pon­ent form? The most obvi­ous answer seems to be that some wire and cable products have been expli­citly iden­ti­fied in the Commission Guidance on the Directive [5, Annex II]. Further, these products must always be incor­por­ated into some oth­er product, many of which are included in the scopes of LVD, RoHS and WEEE. In the case of the LVD, wire and cable products have a dir­ect impact on the safety per­form­ance of many safety-​critical assembles, like cord sets, so per­form­ance of the wire and cable product is essen­tial to the safety of the end product.  It’s worth not­ing here that “cables” are included in the examples [5, Annex II], but “wire”, e.g., an indi­vidu­al insu­lated con­duct­or, is not men­tioned. This implies that wire does not need to be CE Marked as a com­pon­ent.

Is there a man­dat­ory require­ment for the use of CE Marked or marked wire and cable products? No. No more so that there is for any oth­er com­pon­ent that may be selec­ted for use in a CE Marked product. However, it is always recom­men­ded to use CE Marked com­pon­ents whenev­er they are avail­able, as this reduces the like­li­hood of prob­lems related to these products caus­ing issues with the com­pli­ance of the final product.

Acknowledgements

I’d like to acknow­ledge the con­tri­bu­tions of the fol­low­ing people to this art­icle, and offer my thanks for their assist­ance. Some of those lis­ted are mem­bers of the IEEE Product Safety Engineering Society, as well as mem­bers of the EMC-​PSTC list:

Mr. Jon Cotman, Mr. Ted Eckert, Mr. John Gavilanes, Mr. Richard Robinson, Mr. Joshua Wiseman, Mr. John Woodgate.

References

[1] DIRECTIVE 2006/​42/​EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 17 May 2006 on machinery, and amend­ing Directive 95/​16/​EC. Brussels: European Commission. 2006.

[2] DIRECTIVE 2004/​108/​EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 15 December 2004 on the approx­im­a­tion of the laws of the Member States relat­ing to elec­tro­mag­net­ic com­pat­ib­il­ity and repeal­ing Directive 89/​336/​EEC. Brussels: European Commission. 2004.

[3] DIRECTIVE 2006/​95/​EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 12 December 2006 on the har­mon­isa­tion of the laws of Member States relat­ing to elec­tric­al equip­ment designed for use with­in cer­tain voltage lim­its. Brussels: European Commission. 2006.

[4] International Electrotechnical Commission (IEC). “Electropedia: The World’s Online Electrotechnical Vocabulary,”  elec​tro​pe​dia​.org. [Online]. Available: http://​www​.elec​tro​pe​dia​.org [Accessed: 2013-​12-​19].

[5] L. Montoya, Ed. Guidelines on the Application of Directive 2006/​95/​EC (Electrical Equipment Designed for Use Within Certain Voltage Limits). August 2007 (Last Modified: January 2012). Available: http://​ec​.europa​.eu/​D​o​c​s​R​o​o​m​/​d​o​c​u​m​e​n​t​s​/​8​7​1​6​/​a​t​t​a​c​h​m​e​n​t​s​/​1​/​t​r​a​n​s​l​a​t​i​o​n​s​/​e​n​/​r​e​n​d​i​t​i​o​n​s​/​n​a​t​ive. [Accessed: 2015-​08-​24].

[6] DIRECTIVE 2002/​95/​EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 27 January 2003 on the restric­tion of the use of cer­tain haz­ard­ous sub­stances in elec­tric­al and elec­tron­ic equip­ment. Brussels: European Commission. 2002.

[7] DIRECTIVE 2012/​19/​EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 4 July 2012 on waste elec­tric­al and elec­tron­ic equip­ment (WEEE). Brussels: European Commission. 2012.

[8] DIRECTIVE 2011/​65/​EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 8 June 2011 on the restric­tion of the use of cer­tain haz­ard­ous sub­stances in elec­tric­al and elec­tron­ic equip­ment. Brussels: European Commission. 2011.

[9] RoHS 2 FAQ. European Commission, Directorate-​General Environment. 2012. Available: http://​ec​.europa​.eu/​e​n​v​i​r​o​n​m​e​n​t​/​w​a​s​t​e​/​r​o​h​s​_​e​e​e​/​p​d​f​/​f​a​q​.​pdf. Accessed 2013-​12-​12.

[10] DIRECTIVE 2011/​65/​EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL of 8 June 2011 on the restric­tion of the use of cer­tain haz­ard­ous sub­stances in elec­tric­al and elec­tron­ic equip­ment, 2011/​65/​EU. European Commission, Brussels. 2011.

[11] DRAFT Frequently Asked Questions on Directive 2012/​19/​EU on Waste Electrical and Electronic Equipment (‘new WEEE Directive’). European Commission, Directorate-​General Environment. Unpublished.

IMAGES: Selection of wire and cable products, unknown source. HAR mark cour­tesy Ören Kablo.

Author: Doug Nix

+DougNix is Managing Director and Principal Consultant at Compliance InSight Consulting, Inc. (http://www.complianceinsight.ca) in Kitchener, Ontario, and is Lead Author and Managing Editor of the Machinery Safety 101 blog.

Doug's work includes teaching machinery risk assessment techniques privately and through Conestoga College Institute of Technology and Advanced Learning in Kitchener, Ontario, as well as providing technical services and training programs to clients related to risk assessment, industrial machinery safety, safety-related control system integration and reliability, laser safety and regulatory conformity.

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