mexico ia briefing 2013 · dictamen – things to consider • confirm applicable requirements by...
TRANSCRIPT
Mexico IA Briefing 2013
Introduction – Bill Holz Presenter – Suzanna Nagy
We can help with your Market Access
Introduction
• Mexico continues to be a country of change
• Changes impacting certification of products:
– Changes that make it better for US companies
– More competition
– More certification bodies
• Testing and compliance:
– Changes with safety certifications
– Changes with radio certifications
TUV R Mexico update
• Accredited certification body
• Wireless/telecom:
– NOM-121-SCT1-2009: Wireless products
– (902-928 MHz, 2400-2483,5 MHz y 5725-5850 MHz)
– NOM-151-SCT1-1999: Analog interface to public network
– NOM-152-SCT1-1999: Digital interface to public network
• Safety:
– NOM-001-SCFI-1993: Audio and video
– NOM-019-SCFI-1998: Information Technology equipment
– NOM-003-SCFI-2005:
• NMX-J-521/I/ANCE-2005: household electrical devices
• NMX-J-524/I/ANCE-2005: hand-held motor-driven electric tools
• NMX-J-508/I/ANCE-2010: wiring devices
Mexican Safety Certification Overview
• Requirement determined based on HS code
• Certification based on Mexican National standards (NOM)
• Limited certificate validity
• License holder must be Mexican legal importer – each importer has
to have their own certificate / extension
• No EMC requirement
• No factory inspection requirement
What are NOMs?
• NOM – what are NOMs?
• Norma Official Mexicana or the Official Mexican Standard
• NOMs pertain to many sectors as do US standards
• NOMs are designated as NOM-XXX-YYYY-ZZZZ (where XXX = the
NOM number, YYYY = the responsible authority and ZZZZ the year of
adoption)
Options for compliance - Safety
• Verify the applicable regulatory requirements against the appropriate 8-digit
HS code
– Product may be exempt
– If under mandatory requirements:
• NRLT process
• NOM approval
• Dictamen (Highly Specialized Equipment)
• Energy Labeling
US-Mexico NOM Agreement
• Scope of agreement
• Published August 17, 2010
• Ability to use US NRTL certificates in place of associated
NOM certificates
• NRTL certificate must be registered in customs database
• Effective date of agreement
• 5 days after published in the official Gazette of Mexico
(August 22, 2010)
• Recently challenged but defended
• January 29,2013 Mexican Supreme Court of Justice ruled the
Agreement legal and final
Proposed Changes Under the Agreement
• Objective of Agreement
• Based on similar requirements and close alignment between certain US
and Mexican standards, it was determined that US NRTL certificates for
specific US standards would be recognized
• Benefits
• Reduced testing
• Reduced cost
• Reduced certification time
NOMs Addressed
• The following NOMs are addressed under the new agreement:
• NOM-001 - Electronic products in general
• NOM-016 - Office equipment and devices
• NOM-019 - IT products
• Not all products under each NOM will be allowed to use the NRTL certificate
route
• Check with us to determine if your product is covered or not (based on
HS code)
• Known exception: power sourcing equipment (e.g. power supply,
charger etc.)
Process Under Agreement
• Mexican Addendum
• Document product and legal importer details in the Mexican Customs
Database
• Type of equipment
• Model designation
• Certificate number
• File number
• Standards
• Addendum issued to the legal importer
NRTL Approval Process –
Things to Remember
• Confirm that product is eligible for the process – HS code verification
• TUVR can only arrange for products that have valid cTUVus certificate
• No NOM-labeling
• Must have Mexican legal representative / importer
• Commercialization NOM (e.g. NOM-024, NOM-050) may still be required
Safety Approval Process –
Things to Consider
• Confirm applicable requirements by HS code
• Certificate is issued to Mexican legal importer – each importer has to have their own
certificate (can arrange for extensions)
• Family grouping possible: 8-14 models on a single certificate (depends on the
standard), condition: +/- 20% A or W
• Spanish manual required for consumer products, Spanish safety instruction for non-
consumer equipment
• Maintenance / renewal: typically not included in project cost, has to be performed 6-9
months after certificate issuance, 1 sample required for testing in Mexico
Dictamen –
Things to Consider
• Confirm applicable requirements by HS code
• Dictamen is issued to Mexican legal importer – each importer has to have their own
dictamen (can arrange for extensions)
• Only 1 model per dictamen
• No NOM-labeling
• English manual accepted with Spanish safety instructions
• Maintenance / renewal: typically not included in project cost, has to be performed 6-9
months after certificate issuance, no sample is required
Telecom/Radio
• COFETEL is the authority responsible for telecom/radio certification in
Mexico
• Most radio products fell under the old law
• Allowed use of Peritos
• Allowed for recognition of FCC test reports
• October 2011: Many radio products now fall under the new law applying to
NOM 121
• Mandated in-country testing
• The MRA about testing for NOM-121 in the USA is moving forward
Radio Changes
NOM-121-SCT1-2009 is the primary standard for many common radio bands and
testing in Mexico is now required for these bands
• 902-928 MHz
• 2400-2483.5 MHz
• 5725-5850 MHz
Validity of Certificate: The validity of the certificate is permanent. Random
inspections may apply when the product is on the market.
Requirements for Testing: in general, two samples are required with all software,
hardware, operating instructions, etc. 1 configured for radiated and 1 configured
for conducted testing
Family Grouping: May be possible if all products work with the same frequency,
transmission, modulation, etc. but in general, separate certificate required for
each model
Radio Changes
The NOM-121 certification is a 2-step process
• Certificate of Conformity (CoC)
• Cofetel homologation
The Ministry of Economy published in the Official Gazette on December 31, 2012 a
new regulation:
• Copy of CoC for NOM-121 and NOM-151 must be presented to customs
Radio Approval Process –
Things to Consider
• Allocate 2 samples for in-country testing: 1 configured for radiated testing, 1
configured for conducted testing
• Provide simple, easy-to-follow test instructions to go with the test software that the
Mexican engineers can follow (pictures, screenshots or even a brief video can help
prevent test/setup issues)
• User manual now MUST be in Spanish
• Have a dedicated local representative / importer. If not – TUVR can assist
• Local representative has to sign a contract with the certification body (TUVR Mexico)
prior to 1st project will delay the certificate delivery
Environmental Regulations
September 2011: Energy Consumption Labeling (ECL) Now Applies to Various Electrical
Products
• Which products need Energy Consumption Labeling?
186 product types require ELC. These are published in an official catalogue
• Who has to fulfill this requirement?
All distributors legally established in Mexico who sell and distribute the products in
Mexico. This means a legal representative is required.
• Which authority in Mexico is responsible for this requirement?
• “CONUEE” (Comisión Nacional para el uso eficiente de la energía) which is the
national commission for the efficient energy use) and
• “PROFECO” (Procurador Federal del consumidor) which is the federal Procurator of
the consumers.
Environmental Regulation Continued
• What information is needed for the Energy Consumption Labeling?
Energy consumption per unit of time
Standby power consumption per time (in case it applies)
Quantity of products or service offered by the consumed energy unit ** for certain
products only.
Note: There is no special design for the label as long as this information is shown.
Testing is not required in Mexico, as long as data is provided
• How do we proceed with products with accessories? (e.g. power supply)
– If the product is sold in one package, including the accessory, the declaration of
ECL must be done ONLY for the principal product.
– If the accessory is sold in an extra package, it needs its own ECL
About TUV Rheinland Nearly 140 Years of Innovation
1872 Entrepreneurs take the initiative and set up the DÜV to ensure the safety of their manufacturing plants
1918 Activities in the energy and mining sectors
1926 First material analysis laboratory
1900 Vehicle inspection and driving license tests
1969 International product tests and certifications
1975 Medical work
2007 Represented on all continents
2009 World‘s largest photovoltaic lab
1957 Commitment to environmental protection: dust register in Cologne
2006 Joined the
UN Global Compact
500 locations in 65 countries around the world.
Always at your service:
220 offices in Germany.
Upcoming International Approvals Events
Upcoming Roundtables (4-6 hour events)
September 10 – Orlando, FL
Register at http://education.tuv.com/IA-Roundtables/
Passport Seminars (4-6 hour events)
June 20 - IA Briefing for Brazil (Pleasanton CA)
September 17 - IA Briefing for China/Taiwan (Boxborough MA)
September 19 - IA Briefing for China/Taiwan (Pleastanton CA)
Register at http://education.tuv.com/ia-briefing/passport
Passport Webinars (45 minute events)
August 6 - IA Briefing for Russia/Customs Union (2:00pm ET)
September 12 – IA Briefing for Brazil (2:00pm ET)
November 12 – IA Briefing for Australia/New Zealand (2:00pm ET)
Register at: http://video.webcasts.com/events/pmny001/viewer/index.jsp?eventid=45366
Next Steps
Contact us for more information or to start a
project.
www.tuv.com/us
Or call us at 888-743-4652
Questions