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LVD Market Surveillance Campaign 2007
Electrical Safety of Cord Extension Sets
Final Report
LVD Market Surveillance Campaign 2007
Administrative Electrical Safety of Cord Extension Sets
Cooperation
LVD_MSC_2007_Final Report V4.31.doc 2/28
07.04.2008
Acknowledgements
I would like to thank the LVD MSC 2007 Task Force members for their valuable input and support:
Thomas Apel, DE, Regierungspräsidium Kassel
Guibert Crevecoeur, BE, Federal Public Service Economy, SMEs, independent Professions and Energy
Richard Harris, UK, Department for Business, Enterprise and Regulatory Reform
Georg Hilpert, DE, Bundesministerium für Arbeit und Soziales
John Brønlund Jensen, DK, Danish Safety Technology Authority
Fredrik Kagerud, European Commission, Health and Consumer Protection DG
Kleovoulos Kousoulides, CY, Ministry of Communications and Works
Romain Nies, LU, Service de l'Energie de l'Etat
Jan Roed, DK, Danish Safety Technology Authority
Antonio Valladolid, ES, Foundation for the Promotion of Industrial Innovation
Jan Willem Weijland, Enhancing Market Surveillance through Best Practice (EMARS) project
Evert Van Wilgenburg, NL, Food and Consumer Product Safety Authority
Krzysztof Zawislak, PL, Ministry of Economy
Robert Nuij from DG SANCO for co-financing and Dirk Meijer form the EMARS Project for administrative
support and providing the language versions,
Margot Ludwar for transforming the text from “conference language” into clear English.
and finally The Member States for its active participation who made this interesting project possible.
The author and project manager Gerhard Ludwar, Federal Ministry of Economics and Labour, Austria.
LVD Market Surveillance Campaign 2007
Administrative Electrical Safety of Cord Extension Sets
Cooperation
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Contents
1 Objectives..................................................................................................................2
2 Choice of Product Category ......................................................................................2
3 Participants and Financing........................................................................................2
4 Legal Provisions on Cord Extension Sets..................................................................2
5 Design of the Test Program.......................................................................................2
5.1 Handling of the Different Plug Systems..............................................................2
5.2 Organisation of the Project.................................................................................2
5.3 Market Orientation..............................................................................................2
5.4 Sampling............................................................................................................2
5.5 Evaluation ..........................................................................................................2
5.6 Reporting............................................................................................................2
6 Results ......................................................................................................................2
6.1 Main parameters ................................................................................................2
6.2 Price Range and Origin......................................................................................2
6.3 Influence of Origin..............................................................................................2
6.4 Influence of Price................................................................................................2
6.5 Inter-System Comparison...................................................................................2
6.6 Frequency of Shortcomings ...............................................................................2
6.7 Overall Result – the Verdict................................................................................2
6.8 Actions Taken Most Frequently by Competent Authorities.................................2
7 The Cord Extension Set Market in Europe................................................................2
8 Findings.....................................................................................................................2
9 Recommendations ....................................................................................................2
9.1 Review of Standards..........................................................................................2
9.2 Market Surveillance............................................................................................2
9.3 Involvement of Notified Bodies...........................................................................2
9.4 Administrative and Financial Support.................................................................2
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Figures
Fig. 1: A typical cord extension set, some shortcomings and their resulting
consequences...........................................................................................................2
Fig. 2: Participating countries (yellow: type F (“Schuko”), green: type G (“UK”), blue: type
(E (“FR”), orange: type K (“DK”))...............................................................................2
Fig. 3: Countries and their plug systems ..........................................................................2
Fig. 4: Different provisions for different plug systems.......................................................2
Fig. 5: The test parameter layer........................................................................................2
Fig. 6: Country of origin ....................................................................................................2
Fig. 7: Distribution of prices of samples............................................................................2
Fig. 8: Comparison of classes vs. origin...........................................................................2
Fig. 9: Percentage of safe products per price range. Figures in columns indicate number
of samples.................................................................................................................2
Fig. 10: Inter-systems comparison....................................................................................2
Fig. 11: Frequency of shortcomings (administrative and formal shortcomings are
indicated by white columns) ......................................................................................2
Fig. 12: Overall result .......................................................................................................2
Fig. 13: Share of actions „letter to manufacturer“ and „sales ban“ by the authorities in
relation to the classification F1 and F2+F3................................................................2
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Executive Summary
Objectives
During the course of their ordinary market surveillance activities, it has come to the
attention of the European LVD market surveillance authorities that cord extension sets
frequently do not fulfil the safety requirements of the Low Voltage Directive (LVD). The
main objectives of the LVD Market Surveillance Campaign were to promote the
transformation of cross border market surveillance into an activity that is included in the
daily tasks of national authorities. Additional objectives were to enforce compliance with
the LVD, thus achieving a concrete improvement in product safety within a product
category, to gain information on the degree of compliance of these products in the
market and also to raise the profile of LVD-related market surveillance in the opinions of
consumer organisations, trade and industry.
Key issues
Safeguard clause notifications under the LVD and statistics of the European rapid alert
system for non-food products RAPEX have shown that a considerable number of
defective cord extension sets posing risks for consumers can be found on the EU
market.
The project was initiated by the national market surveillance authorities participating in
the LVD Administrative Cooperation working group (LVD ADCO) and received financial
contributions by the Commission.
In due course, a joint European project was set up to scrutinise the problem and make it
more tangible, so that agreement on relevant measures to approaching the problem
would ultimately be possible.
Main results
An unprecedented number of 20 European countries participated in the project. 209 cord
extension sets were tested and the results show that 14.5% of the selected products
complied with the given 22 test parameters for the project and thus with the safety
objectives of the LVD.
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1 Objectives
As economic players increasingly operate on the European level, market surveillance
authorities need to adapt their operational procedures accordingly to match this
challenge.
The primary objectives of the Low Voltage Directive (LVD) Market Surveillance
Campaign were:
• to promote the transformation of cross border market surveillance from its current
state (i.e. a singular event consuming considerable attention, overhead and
resources) into an activity that is included in the daily tasks of national authorities.
• to enforce compliance with the LVD, thus achieving a concrete improvement in
product safety within a product category
• to gain information on the degree of compliance of the products available on the
market.
• to raise the profile of LVD-related market surveillance in the opinions of consumer
organisations, trade and industry.
Additionally, information on the size of market parameters and the number of
manufacturers and importers should be obtained.
2 Choice of Product Category
Safeguard clause notifications under the LVD and statistics on the European rapid alert
system for non-food products (RAPEX, operated under the General Product Safety
Directive), have demonstrated that cord extension sets with severe safety deficits are
entering the Common Market. For the following reasons, this product was selected for
the 2007 campaign:
Cord extension sets have found universal distribution and ubiquitous existence in all
households.
Safety deficits may be severe and can compromise the safety measures of connected
devices (e.g. due to the omission of earthing wires).
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Fig. 1: A typical cord extension set, some shortcomings and their resulting
consequences.
3 Participants and Financing
Due to these implications, DG SANCO decided to direct substantial financing to the
project through the provision of a total sum of EUR 356,831.87, which means that 70%
of the total costs were reimbursed to the Member States. Another important point was
the administrative support provided by the project “Enhancing Market Surveillance
Through Best Practice” (EMARS), which included three language versions of the project
documents. Both factors were crucial to the success of the project leading to an
unprecedented number of 20 participating countries, including Austria, Belgium,
Bulgaria, Cyprus, the Czech Republic, Germany, Denmark, Spain, Finland, Iceland,
Lithuania, Luxembourg, Netherlands, Norway, Malta, Poland, Sweden, Slovenia,
Slovakia and the United Kingdom.
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Fig. 2: Participating countries (yellow: type F (“Schuko”), green: type G (“UK”), blue: type
(E (“FR”), orange: type K (“DK”)).
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Four different plug systems are presently in use in the participating countries.
Type G Type F “Schuko”
BS 1363 CEE 7/4 and CEE 7/7 plug
CY, UK, MT AT, BG, DE, ES, FI, IS, LT, LU, NL, NO, SE, SI
Type E Type K
CEE 7/5 and CEE 7/7 plug SB afsnit 107-2-D1
BE, CZ, PL, SK DK
Fig. 3: Countries and their plug systems
4 Legal Provisions on Cord Extension Sets
Legal provisions on cord extension sets are based on Community as well as on national
law. First of all, there are no harmonised standards on the physical aspects of the
different domestic plug and socket systems. They were originally based on the former
CEE standard, which was out of print for an extended period of time and has since been
adapted into different national standards. The IEC Technical Report TR 60083 2006-04
“Plugs and socket-outlets for domestic and similar general use standardised in member
countries of IEC” lists these standards, which are mandatory in some Member States.
Functional requirements are covered in national standards, which may also differ for the
“same” plug system. They are generally based on the IEC 60884 standard.
On the community level, the General Product Safety Directive (GPSD) applies to plugs,
sockets and cord extension sets, as for all consumer products. Concerning the LVD,
“plugs and socket outlets for domestic use” are outside the scope according to Annex II.
Regarding the other components of a cord extension set, the cable is covered by the
LVD and harmonised standards exist.
The product “cord extension set” as a whole is covered by the LVD, as the LVD
Guideline referring to the IEC International Electrotechnical Dictionary states: “any item
used for ... distribution or utilisation of electrical energy”.
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However, the industry decided not to develop a harmonised standard for this type of
product. As a consequence, manufacturers cannot benefit from a presumption of
conformity; instead, they must verify in their technical files that the procedures applied
are suitable, in order to demonstrate that their products “have been constructed in
accordance with good engineering practice in safety matters in force in the Community
...” (Art. 2 LVD). In this respect it must be noted that “good engineering practice” may
extend beyond a national standard if a different (national) standard incorporates more up
to date knowledge.
5 Design of the Test Program
5.1 Handling of the Different Plug Systems
The central issue of this project was the question of how to compare the results from
four different plug systems, each of which employs specific national provisions
(standards and/or regulations). Thus, a direct comparison of tests results (which is
possible when evaluation is based on harmonised standards) had to be replaced by a
different approach.
BS 1363 pass/fail according to
BS 1363
ÖVE
VDE
NEN 1020 pass/fail according to
NEN / VDE /…
CZ
NBN C 61-112-1 & 2 pass/fail according to
NBN / …
SB afsnit 107-2-D1 pass/fail according to
SB afsnit 107-2-D1
Fig. 4: Different provisions for different plug systems
The solution was derived from the following assumptions:
• All plug systems, though different, share the same risks
• All various national provisions address these risks
• Risks are checked against a set of test parameters stipulated by the various
regulations
• This set of test parameters is included in all national provisions, although tests may
differ slightly.
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Consequently, a “test parameter layer” was introduced according to which the results
could be compared with respect to the different national standards.
... National provisions
... Universal test parameters
RESULT
VDE
TPT
afsnit
TPT
BS
TPT
NEN
TPT
Fig. 5: The test parameter layer
5.2 Organisation of the Project
The project was divided into the following phases:
• Market orientation: In this phase, each participant collected information on the EU-
manufacturers/importers of cord extension sets and the size of the market
• Sampling and assessing compliance with the administrative requirements
• Technical investigation
• Reporting
5.3 Market Orientation
Each participant should determine which importers and/or manufacturers bring cord
extension sets onto the EU market. Whenever possible, an estimate of the relative
importance the imports (e.g. the number, total sales in Euro, etc) should also be
available.
This phase of the project should result in a list of importers and manufacturers (for each
Member State) that are putting cord extension sets on the EU market, preferably with
additional information on their market shares.
5.4 Sampling
The aim was to obtain the broadest possible view of the selected type of products in the
European marketplace. This was a new approach compared to previous LVD market
surveillance campaigns, where the objective of sampling was to single out possible non
compliant products from the beginning. Taking this approach, it would obviously not be
possible to obtain an overview of how the industry complies with the applicable legal
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provisions, as the share of non compliant products would only give a measure of the
efficiency of market inspectors.
For the cord extension set project it was therefore decided to perform a “quasi-random”
sampling, taking products over the whole price range (up- and down-market) and from
all origins (national, EU, and imported from third countries). For practical reasons, the
basically more desirable true random sampling was out of reach within the framework of
the project. As a consequence, it is reasonable to assume that those who took the
samples might have, in one case or another, subconsciously selected products they felt
could be prone to non-compliance. As a result, the percentage of products found to be
non-conforming, might be biased to a certain extent. On the other hand, for the majority
of test parameters, not even the most experienced market inspector can tell without a
thorough lab exam whether a product is within the specifications or not, thus limiting any
possible bias.
Sampling was done according to two objective characteristics: cord extension sets were
selected which had
• a substantial market share and
• no extra features (i.e. basic cord extension sets with 3 to 6 sockets),
On average, ten samples per participant country were taken, resulting in a total number
of 209 different types of cord extension sets investigated.
5.5 Evaluation
The test parameters were basically based on national provisions, the LVD and the
GPSD. Within the LVD all essential safety aspects are covered. The test parameters
were structured accordingly. They are of a technical nature and are therefore
independent of the country-specific plug-socket-system. These are indicated as
“supplementary national requirements”.
It is assumed that there are corresponding provisions for all test parameters in existence
for all systems, which were provided by the Member States in which these systems are
in use. This approach ensured that the evaluation and presentation of the results could
be easily facilitated within the framework of this structure.
As the set of test parameters comprehensively covered relevant risks, valuable insight
could be gained on the suitability of national testing programs.
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5.5.1 Potential Risks of Cord Extension Sets
The greatest potential risks of cord extension sets include:
Electric shock due to accessibility to live parts
Electric shock due to accessibility to live parts can occur if the insulation on the cable is
inadequate or if the material of either the plug or the socket outlet is of poor quality and
will not withstand normal use or foreseeable misuse.
Electric shock due to missing earthing wires
Electric shock due to missing earthing wires can result in a very dangerous situation if
the apparatus that is connected to the cord extension set is also faulty.
Fire
Fire can occur if there is either too little distance between live parts (which triggers an
electric arc), or if there is a bad connection (higher resistance) somewhere in the cord
extension set. In practice, the latter occurs if poor material is used in construction, so
that either the pins in the plug or the contacts in the socket outlet are not held in a fixed
position, thereby creating a hot spot. In the worst possible case, this hot spot can
ultimately lead to a fire.
Why do we not see more accidents, taken into account the high number of non-
compliant cord extension sets?
The project has revealed that in 74% of the cases, the cables used are of a reasonable
quality, so the only failure that can lead to shock is caused by unsuitable material used
in the construction of either of the plug or the socket outlet, resulting in breakage during
normal use or foreseeable misuse. If this happens on the consumers’ premises, most
consumers will discover that the product has failed and will stop using it.
The electric shock that is triggered by a failure in an apparatus and a missing earth
connection in the cord extension lead is also rarely seen. The reason for this is the wide
use of Residual Current Circuit Breakers (RCCB’s) in the installation; these shut down
the current if such a failure occurs. It must also be remembered that this hazard requires
a failure in both the apparatus connected to the cord extension set and a missing earth
connection in the cord extension set itself.
With regard to the risk of fire which arises when the distance between live parts is too
short, the test results showed that this type of failure is quite rare. However, the use of
poor material is seen more often. In this case, the creation of a hot spot is possible. In
some cases, the hot spot separates the contacts from the pins and no harm is done. In
the remaining cases, the risk is real, in particular when the cord extension set is hidden
away behind a sofa or in a similar place where it cannot easily be seen.
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We can not exclude that fires are caused by the above mentioned deficiencies.
However, in many cases, the source of fires remains unresolved.
5.5.2 Classification of Shortcomings
To support the preparation of the test report, a list of common product deficiencies was
provided.
• F1 (Remark): A deviation from the product provisions which is not a direct safety
hazard for persons, domestic animals or property but could be referred to the safety
objectives of the LVD.
• F2 (Criticism): Deviations which can be a direct safety hazard for persons, domestic
animals or property but could be referred to the essential safety objectives of the
LVD.
• F3 (Serious criticism): Obvious and direct safety hazard for persons, domestic
animals or property.
• P (passed the test parameters)
Codes basically follow the Nordic Market Surveillance Codes for Common Deficiencies.
This code system corresponds to the seriousness of the shortcoming, whereby F1 is the
lowest level of non-compliance, and classifications F2 and F3 correspond to increasingly
serious shortcomings. The classification was used to sum up the assessment of the test
parameters by the competent authorities in a comprehensive “verdict”.
The additional survey and risk analysis (e.g. according to the Guide to Corrective
Actions) carried out by the authorities led to the conclusion that products which were
classified as F2 and F3 and therefore presented an unacceptable risk of damage under
foreseeable conditions of usage, would be removed from the market. This was the case
for more than 80% of the products classified as F2 and F3.
According to Art. 3 of the LVD, Member States are only entitled to impede the free
movement of goods if the safety objectives given in Annex I of the LVD are not met. As a
consequence, most samples classified as F2 and F3 cannot be considered to fulfill the
relevant safety objectives.
However, it must be clearly understood that even for these products, accidents need not
necessarily occur unless a number of conditions are met, such as utilisation for a longer
period of time, higher loads, frequent plugging and unplugging, use at elevated or low
temperatures, or general careless handling, improper use, or a concurrence of further
faults.
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5.6 Reporting
Results from the participating countries were communicated electronically via the
CIRCA1 data base.
The primary means of communicating the results were “data collection spreadsheets”
(DCSS), which were provided for each participant. Additionally,
• a scan of the declaration of conformity (DoC)
• one representative photo of the cord extension set which allows clear identification,
and
• a photo of the type plate
were also uploaded to CIRCA.
1 "CIRCA" is a part of the European Commission website with restricted access allowing for the secure
exchange of information between members of an interest group, in this case the group being LVD ADCO.
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6 Results
6.1 Main parameters
The following numbers define the main parameters of the evaluation:
209 different samples of cord extension sets were acquired
• 97 samples were partly tested
• 112 samples were completely tested (all 22 test parameters)
Since nearly all partly tested samples yielded a "FAIL" as the final result, the total
evaluation remains valid.
6.2 Price Range and Origin
Nearly three quarters of the samples originated in China, while approximately one sixth
came from the EU and about one 12th was of unknown origin. The Member State with
the highest share was Germany (5.3%), followed by Poland with 3.3% and Bulgaria with
2.4%.
Country of Origin
72,2%
5,3%3,3%2,4%1,4%1,4%1,0%1,0%0,5%0,5%0,5%0,5%0,5%0,5%0,5%
8,6%
0%
1%
10%
100%
China
Germany
Poland
Bulgaria
Czech Republic
Spain
Belgium
Croatia
Cyprus
Denmark
France
Netherlands
Sweden
Taiwan
Turkey
NA
Fig. 6: Country of origin
Prices ranged from 50 Cents to about 20 EUR, with the majority in the two to four Euro
range. The average price amounted to 5,18 EUR.
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Distribution of Prices
0%
5%
10%
15%
20%
25%
30%
35%
40%
0-2 2-4 4-6 6-8 8-10 10-12 12-14 14-16 16-18 18-20
Price range (EUR)
Fig. 7: Distribution of prices of samples
6.3 Influence of Origin
Contrary to popular belief, the region of origin indicated did not correlate as expected
with the safety deficits of the products under investigation.
Influence of Origin
31% 44%
69% 56%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
EU Non-EU
F2+F3
P+F1
Fig. 8: Comparison of classes vs. origin
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6.4 Influence of Price
Furthermore, another popular myth was proven false: the correlation between prices and
shares of safe products. Although units in a moderate price range did, indeed, yield
slightly better results, this trend was inverted in the next price range. Compared to the
lowest price ranges of up to 4 EUR, spending twice as much only raises the chance of
acquiring a safe product from about 40% to 47%. In the next price range, the rate drops
again to 40%. However, total counts of safe products are low (see the numbers in the
columns of Fig. 9), so that the statistical uncertainty is considerable and higher price
ranges are therefore omitted.
The average price of products classified P+F1 was 4.99 EUR, the average price of
products classified F2+F3 was 5.14 EUR.
Share per Price Range for Classes P+F1
0%
10%
20%
30%
40%
50%
0-2 2-4 4-6 6-8
Price range (EUR)
11 24 17 6
Fig. 9: Percentage of safe products per price range. Figures in columns indicate number
of samples.
6.5 Inter-System Comparison
The participation of four different plug systems provided the opportunity for an inter-
system comparison. It showed that the share of unsafe products for Type F (“Schuko”)
and Type K (“DK”) was lower than for Type E (“FR”). Overall, Type K, which is in use
only in Denmark, yielded the best results, although the statistic uncertainty of the low
count of samples must be taken into account. Please note that the results for the type G
system reported as "P” (pass) did not include a full assessment against all the test
criteria (see results table) so that they have been excluded from the full analysis.
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These test results are indicated as “pt*” – partially tested in the respective column in the
following table.
Classes vs. Type
7
18 4
0
0
36
15
0
042
25 7
5
14
21 6
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
Type K "DK" Type F
"Schuko" Type E "FR" Type G "UK"
F3
F2
F1
P
pt*
8*
Fig. 10: Inter-systems comparison
6.6 Frequency of Shortcomings
The following table lists the identified shortcomings for products classified F2 and F3.
Products usually showed multiple shortcomings. It was noted that compliance with
administrative requirements was lacking in 74% and 58% of the cases, respectively.
Aside from administrative requirements, the most frequent deficiencies were the wrong
shape and dimensions of plugs and sockets (43%), poor construction of the cord - i.e.
inadequate insulation material - (26%), and insufficient protection against electric shock
(21%). On the positive side, dielectric strength and material properties (resistance to
ageing, temperature, and fire) were insufficient in less than 10% of the cases.
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Shortcomings of Samples classified F2 and F3
0%
10%
20%
30%
40%
50%
60%
70%
80%
Technical File
DoC
Markings
Shape / Dimensions
Additional markings
Construction of the cord
Protection against electric shock
Cross section of conductors
Connection of cord to contact strips
Pull relief
Switching ability and Service life
Information about the manufacturer
Mechanical strength
CE-Marking
Withdrawal force
Temperature rise
Resistance to fire
Resistance to temperature
Creepage distance und clearance
Length
Resistance to ageing
Dielectric strength
Fig. 11: Frequency of shortcomings (administrative and formal shortcomings are
indicated by white columns)
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6.7 Overall Result – the Verdict
The following graph shows the overall results. Only 14.5% of the cord extension sets
were found to be compliant with the criteria analysed. In 60% of the cases, the products
were classified as F2 or F3.
Verdict
14,5%
25,5%
37,0%
23,0%
0%
10%
20%
30%
40%
PF1F2F3
Classification of Shortcomings
Fig. 12: Overall result
6.8 Actions Taken Most Frequently by Competent Authorities
The following diagram illustrates the actions taken most frequently by competent
authorities for the classes F1, F2, and F3. In the case of minor shortcomings (F1),
manufacturers/importers are usually requested to correct the situation (“letter”). Products
classified F2 and F3 were in most of the cases considered unsuitable for marketing.
Authorities imposed either a sales ban, or the manufacturers/importers decided to take
the product voluntarily from the market. Differences of up to 100% result from products
no longer on the market, or pending procedures at the closing date of the project.
Considering only products for which information on actions taken is available, about half
were removed from the market.
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Actions taken
84% 79%
0%
10%
20%
30%
40%
50%
60%
70%
80%
90%
100%
F1 F2+F3
Sales Ban
Letter
Fig. 13: Share of actions „letter to manufacturer“ and „sales ban“ by the authorities in
relation to the classification F1 and F2+F3.
7 The Cord Extension Set Market in Europe
Acquisition of market data is usually not a main objective of market surveillance. Similar
to the experience in previous projects, data could only be provided by a few participants
including BG, DK, ES, and FI. According to this data, 40 to 90 cord extension sets are
sold annually per 1,000 inhabitants. Consequently, the EU-wide market volume would
be 20 to 45 Mio. pieces sold annually, resulting in a turnover of roughly 120 to 260 Mio.
EUR. These figures are extrapolations from the data of only four Member States and
consequently are associated with a relatively high degree of uncertainty.
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8 Findings
First of all, the primary result based on the samples is that overall, only one of six cord
extension sets was found to be compliant and consequently, five sixths should not have
been placed on the market. Because this was the first market surveillance campaign
where sampling was done with an - admittedly imperfect - randomised approach, it is the
first time that an overview of the compliance of a special product on the European
market has been made available. Additionally, the high participation of 20 European
countries makes the result even more significant.
While the share of products found to be non-compliant also includes those which exhibit
only administrative non-compliances relating e.g. to faulty declaration of conformity or
missing technical documentation, another figure is even more significant: As of the
editorial deadline for this report, in 45 % of the cases for which the actions of the market
surveillance authorities were reported, the cord extension sets tested were considered to
be insufficiently in line with the safety objectives to the extent that a sales ban was
justified as a reasonable reaction to the shortcomings found.
A further finding supports the impression that the issue is not just a matter of a few
exceptional cases of unfortunate circumstances, but rather a fundamental neglect to
adhere to the procedures of the New Approach Directives: in 80% of the cases,
manufacturers/ importers were not sufficiently familiar with the administrative
requirements to draw up the documents correctly. Consequently, correct documents are
not suitable as a first means of identifying safe products: the share of incorrect
declarations of conformity (56% and 58%) and of incorrect technical documentation
(74% for both) is the same for products classified P+F1 and classified F2+F3. Thus,
more than half of the products for which correct declarations of conformity were issued,
were nevertheless found unsafe.
It is doubtful whether safety is correlated with price: the rate of compliant products of
about 40% is nearly independent of the price. Only the price range of 4-6 EUR scored
slightly better with 47%.
The bottom line for the time being is that it is not possible to identify a set of parameters
that could serve as a tool for selecting products with a higher rate of conformity to the
legal provisions.
The campaign resulted in more than 20 RAPEX notifications.
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9 Recommendations
9.1 Review of Standards
Although national versions of standards for the same plug system are all based on the
IEC 60884-1 standard, individual countries are moving in different directions. Thus at
some point, plugs and sockets from the same system can become incompatible. Even
now, standard testing requirements are often supplemented by country-specific
variations, rendering plugs and sockets which are perfectly acceptable in one Member
State to be unsuitable in another. Increasing difficulties in regard to the free movement
of goods can be foreseen.
As a consequence, a Commission mandate should initiate the elaboration of a
harmonised standard consisting of different sections for the different European systems
and up-to date testing requirements which address the latest developments and known
deficiencies of the present procedures. Additionally, the dimensions of plugs and
sockets should be included, since the CEE standards, on which these dimensions were
originally based, are out of print.
As mentioned in Chapter 5.5.2, accidents need not necessarily occur even in connection
with products considered unsafe, unless there is a concurrence of further faults.
Actually, the number of documented accidents with cord extension sets would not lead
to the same conclusion as the results of this project. There are not too many studies on
accidents caused by electrical products. According to a recent study, “Electric Fire
Fatalities in Finland”, over a period covering the years 2001-2006, 10% of the fatalities
were attributed to “other electrical appliances”, which included all appliances besides
light fittings, kitchen stoves, refrigerators, TV sets, electric heaters, coffee machines, and
sauna stoves. Consequently, cord extension sets could be potentially responsible for
only well below 10% of the fire fatalities. In absolute numbers, there was on average
about one fatality per year in this category. The mandate should therefore also consider
a scientific review of the appropriateness of the technical burdens to economic
operators.
9.2 Market Surveillance
The Commission’s initiative for a “Regulation of the European Parliament and of the
Council setting out the requirements for accreditation and market surveillance relating to
the marketing of products” to come into force on 01.01.2010 already addresses the
necessary measures to improve the level of product control, as well as to increase the
efficiency of administrative co-operation.
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On a product level, market surveillance agencies should continue focusing their attention
on cord extension sets.
LVD ADCO recommends the following steps to be taken in response to the results of
this campaign:
• LVD ADCO should take the necessary initiatives to organise cross border market
surveillance campaigns regularly, at least once a year.
• LVD ADCO should play a role in stimulating small-scale co-operation between
interested Member States. It should start collecting the annual activity plans of its
members, make them available and encourage bi- or multilateral local co-operation.
• LVD ADCO is advised to set up a working group to investigate the possibilities for
harmonising the risk classification of common shortcomings found in electrical
products under the LVD.
• It is recommended that LVD ADCO should investigate the requirements that an
information exchange system for cross border actions should fulfil as an input to the
related activities required by the commission in the above mentioned regulation.
9.3 Involvement of Notified Bodies
Thirdly, given the fact that there is a large number of notified bodies which are perfectly
up to the task of supporting manufacturers in conformity assessment, and these services
are not being accepted voluntarily, their increased involvement could improve the
situation. This does not necessarily mean that third party certification should be required.
As a first step, the situation might benefit from involvement in checking whether or not
the administrative requirements have been met, similar to the regime of the new EMC-
Directive. With the new regulation mentioned above, the quality level of the accreditation
bodies will be greatly harmonised, which in consequence will have the same effect on
the accredited and notified bodies.
9.4 Administrative and Financial Support
Partial financing of the project undoubtedly contributed to its success. Equally important
was the support of the market surveillance authorities in matters of accounting and the
provision of language versions, which is in line with Community policy to support
language diversity.
It must be noted that a few administrations decided not apply for community financing,
due to the additional administrative load necessary for its settlement. For the future,
community financing, which is generally geared towards private enterprises, needs to
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take the special conditions of fiscal accounting for governmental organisations into
account.
The new regulation on accreditation and market surveillance contains a comprehensive
set of provisions enabling the Commission to substantially support future LVD ADCO
activities. First of all, it authorises community financing for the putting at the disposal of
the Commission technical expertise for the purposes of assisting it in its implementation
of market surveillance administrative cooperation, including the financing of groups of
administrative cooperation… and the performance of preliminary or ancillary work in
connection with the implementation of market surveillance activities linked to the
implementation of Community legislation … as well as European market surveillance
campaigns…(Art. 28). Also, market surveillance initiatives designed to share resources
and expertise between the competent authorities of the Member States … shall be
coordinated by the Commission (Art. 23).
As an important step towards "coordinating" and "assisting in market surveillance
administrative cooperation", the Commission should provide office support for
administrating the financial as well as the test data of future market surveillance
campaigns. The LVD community should enter negotiations with DG ENTR on this issue
as soon as possible.
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ANNEX 1: Market Surveillance Codes for Common Deficiencies
To assist in preparing the test report, a list of common product deficiencies is provided. This is
shown in following table. Each deficiency is allocated a code from 1-3, representing its
seriousness. The codes are (1) Remark, (2) Criticism and (3) Serious Criticism.
(The codes are in use in Sweden, Finland, Denmark and Norway)
Technical deficiencies
Accessible live part in normal use 3
Accessible basic insulated parts on Class II products 2
Luminaries and domestic equipment of Class 0 1
The creepage and clearance distance is less than 10% of the
requirement in the relevant standard 3
The creepage and clearance distance is more than 10% and less than
50% of the requirement in the relevant standard 2
The creepage and clearance distance is more than 50% of the
requirement in relevant standard 1
Cord extension set with Class 0 plug and Class 1 outlet 1
Cord extension set with Class 1 plug and Class 0 outlet 3
Cord extension set with Class 2 plug and Class 0 or 1 outlet 3
Class 1 plug on 2-conductor cable to Class 0-device. 3
Phase and earth mixed up in earthed coupling 3
The equipment lacks thermal cut-out and/or current cut-out. 2 (3)
The rated current in the equipment is one step too high 1
The rated current in the equipment is more than one step too high 2
The rated current in equipment is so high that it is a fire hazard 3
The marking is incomplete or missing 2 (3)
CE-mark is missing 1 (2)
Operation instruction is misguiding, which can cause danger (2) 3
National language operation instructions with necessary safety
information is missing 2
The design diverges from standard or measuring blade. 2 (3)
Conductors not adequately attached 2 (3)
Risk for mechanical damage to conductor 2 (3)
Equipment with inadequate conductor(cross-section, insulation) 2 (3)
Cord anchorage is missing 2 (3)
Ip-classification does not comply with the requirements 2 (3)
The design diverges from standard or technical documentation (great
risk for electric shock/fire) 2 (3)
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Administrative deficiencies
Declaration of conformity is missing 2
Errors in declaration of conformity 1
Technical documentation is missing 2
Errors in technical documentation 1 (2)
Modified product sold with the same type no. etc. as product where
sales ban is issued. 1