CE Marking Wire and Cable – Necessity or Luxury?

CE Marking of wire and cable is complex for two reasons: There are wire or cable products, like power cord assemblies or pre-made ethernet cables, and then there is the component wire or cable from which those products are made. This article discusses the current requirements to help you understand this deceptively simple topic.

TL;DR – 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

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 directly impact the safety performance of many safety-critical assemblies, like cord sets. Hence, the performance of the wire and cable product is essential to the end product’s safety.  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 to incorporate CE Marked or marked wire and cable into products? The answer is NO. No more so than any other component as part of a CE Marked product. However, it is always recommended to use CE Marked components whenever available, as this reduces the likelihood of problems related to these products causing issues with the compliance of the final product.

---

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 are mostly concerned with the insulation colours, the number of conductors, the gauge, and the voltage rating. Sometimes we are 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. This common product can bring a world of headaches if the requirements are not fully considered.

Regulatory Requirements

North America

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

Europe – HAR Marking

What about Europe? The EU has a separate system for wire and cable, identified by the <HAR> Mark. Learn more about this 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 were replaced by the EN 50525 series of standards effective 2014-01-17. But what is the basis for marking, and is it 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. All signatories to the HAR agreement accept wire and cable products bearing the HAR mark. (Need to know more? Have a look at the EEPCA website.) 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?  We need to look at the CE Marking requirements in more detail to answer that question. In general, CE Marking Directives are aimed at products, not components, although some exceptions exist. 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. The compliance of the wire used in the product is based on the specific application and the wire product’s performance. 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…”

DIRECTIVE 2006/42/EC [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…”

DIRECTIVE 2004/108/EC [2]

These definitions do not 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.

DIRECTIVE 2006/95/EC [3]

Once again, we have a specific definition for the Directive’s target: “electrical equipment. Or do we? What, exactly, is “electrical equipment”? The Directive does not 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 to catalogue 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”:

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.

[3, 151-11-25]

The definition uses the term “apparatus,” which continues the lack of clarity. Is wire apparatus? Looking up the definition for “Apparatus,” 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.

[3, 151-11-22]

Wire doesn’t meet the definition of apparatus since it couldn’t be considered an “independent unit for a specific function,” so is wire a device? Now we have one more term to try to understand. The definition of “device” is found in the IEV:

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

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

[3, 151-11-20]

Now we’re getting somewhere. Wire could be considered 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 of 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

[3, 151-11-21]

Now we’ve got it! The wire is a component, which makes sense when considering the use we make of wire and cable products. But how does this relate to the legal definition of “electrical equipment”? Since the Directive does not call out the IEV, 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 its 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 60320 connector on one end and a country-specific plug, like a CEE plug cap, is a complete product with a defined end-use and 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.

This conclusion is supported by an email exchange I had with Alexis BASIAUX of the European Commission [12]:

Wires and cables shall comply with the LVD whether they are single core or multi core if they fall within the voltage ranges of the LVD and are placed, as such (i.e as products), on the EU/EEA market.

They cannot be considered as components even when they are intended to be incorporated into machine control system (see below statement in the LVD guidelines https://ec.europa.eu/docsroom/documents/31221).

“It should be noted that the scope of the exclusion of basic components must not be misunderstood and extended to items like lamps, starters, fuses, switches for household use, elements of electrical installations, etc., which, even if they are often used in conjunction with other electrical equipment and have to be properly installed in order to deliver their useful function, are themselves to be considered electrical equipment in the sense of the LVD.“

LVD Guidelines

Below you can download the 2018 LVD Guide, which includes a visual guide to wire and cable products included and excluded under the LVD. See Annex VII.

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. 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;
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 × 2.5 m, are included in the scope of the RoHS directives, but machines larger than 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;

EU WEEE Directive

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 interpret “large-scale” as [11], it becomes clear that WEEE does not include most heavy machinery. Smaller equipment, i.e. not “large scale,” would be included. This seems clear enough, but how does this relate to wire and cable?

Reading [9, Q5.2], we find that internal wires are not cables. Internal wiring in any EEE 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. The same applies to the internal wiring if an EEE is subject to a transition period or a scope exclusion. 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.

EU RoHS Directive

So machinery that is neither a large-scale stationary machine tool nor a large-scale fixed installation is within the scope of the RoHS and WEEE Directives.

Summing Up

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 directly impact the safety performance of many safety-critical assemblies, like cord sets. Hence, the performance of the wire and cable product is essential to the end product’s safety. 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 to use CE Marked or marked wire and cable products? No. No more so than any other component that might be selected for use in a CE Marked product. However, it is always recommended to use CE Marked components whenever 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, and 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.

[12] A. BASIAUX, “Single-core cables”, 2020.

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

© 2013 – 2022, Compliance inSight Consulting Inc.
This work is licensed under a Creative Commons Attribution-NonCommercial-ShareAlike 4.0 International License.