Machinery Safety 101

CE Marking Wire and Cable – Necessity or Luxury?

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,”  electropedia.org. [Online]. Avail­able: http://www.electropedia.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/DocsRoom/documents/8716/attachments/1/translations/en/renditions/native. [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/environment/waste/rohs_eee/pdf/faq.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.

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