Approving Electric Signs for International Sale
The administrative process of listing and certifying electric signs in Canada is specific to the Canadian marketplace. Other countries use different regulatory or certification processes. Some, like the United States, are very similar to the system established in Canada. Others, like in the European Union, are quite different. Many smaller nations have chosen to avoid the avoid the administrative and financial burden of establishing their own product certification process; instead they commonly accept the regulatory structures already established by a larger nation or group of nationals. (For example, the Bahamas Building Code incorporates both the Canadian Electrical Code and the (U.S.) Miami-Dade County Building Code.)
Listing in the United States
In the United States, the National Electric Code includes requirements for “listed” or “labeled” devices, similar to the CEC requirement for “evidence of approval”. Also similar to how the Standards Council of Canada works, the U.S.’ Occupational Safety and Health Administration has an accreditation process for “Nationally Recognized Testing Laboratories”. There are 10 NRTLs which list products under the “UL48 Standard for Electric Signs”. Most of these NRTLs are the same organizations that approve electric signs in Canada (Underwriters Laboratories, CSA Group, Intertek, Eurofins/MET Labs, among others). However, the certification mark that indicates approval in Canada likely will be different (but similar in appearance) to those that indicate approval in the United States. Many mass-produced signs or sign components may carry multiple certification marks indicating approval for use in the US, Canada, Europe, and other nations.
Approval in the European Union
In the countries within the European Union, the certification process is quite different than in Canada. “CE” stands for Conformité Européenne, which translates from French to English as ‘European Conformity’. CE certification is an EU safety directive that indicates that a product has passed certain tests and means that a product can legally be sold anywhere within the EU and the European Economic Area. For some products, CE marking can be carried out by the manufacturer themselves, other products must be tested by a company that offers CE marking services. A sign manufacturer needs to: (1) determine which EU Directives are applicable to their products; (2) ensure product compliance with the applicable Directives by testing and applying the relevant conformity assessment procedures; (3) compile and retain a technical file; (4) write and sign the Declaration of Conformity and keep the original with the technical file; and (5) apply CE marking to the equipment in accordance with the requirements of the Directive.
Approval in Great Britain
Prior to Brexit, the United Kingdom (England, Scotland, Wales, & Northern Ireland) observed the CE conformity certification process as part of the European Economic Area. Eventually, Great Britain (England, Scotland, & Wales, but not Northern Ireland) will have implemented fully its own conformity procedures. But the UK remains in an interim stage of withdrawal until December 31, 2024, where some products marked “CE” are legal for sale and installation in Great Britain.
“UK Conformity Assessed” marking (UKCA) is the new product marking requirement that will be needed for products being placed on the market in Great Britain (England, Scotland, & Wales). CE marking will continue to be accepted in Northern Ireland. UKCA marking will indicate that a product placed on the Great Britain market meets the UKCA Marking requirements. UKCA marking was specified in the original ‘EU Exit’ UK Statutory Instruments, and for most products this is defined in UK Statutory Instrument 2019 No. 696 and amendments. ‘EU exit’ UK Statutory Instruments and amendments require UKCA marking for products that can be self-declared or currently need a notified body assessment. Initially the UKCA marking requirements will align with CE marking requirements that they replace, but overtime divergence is possible.
Additional information on UKCA requirements for electric signs can be found at https://www.businesscompanion.info/en/quick-guides/product-safety/electrical-equipment.