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Grey Imports & Non-Compliance

Tue, 16 Aug 2022 16:45:36 GMT

Grey Imports and Non-Compliance

In this article we are going to discuss grey imports and who is responsible for conformity, using the TwoTrees laser engraving machine ( Alert number A11/00034/22 ) which was reported on Rapex as an example.

The fortress Europe myth.

While many believe europe to be a 'fortress' of regulations, import restrictions and checks. In reality this is far from the truth. While europe does indeed have the highest standards for product safety; and rightly so! It lacks the proper market surveillance to inspect every product that crosses the border. In reality it would be a monumental if not impossible task to inspect every import crossing the border is compliant.

If no one is checking how is conformance guaranteed?

Conformance should be guaranteed by the importer (or manufacture if already located in the EU). An importer is anyone importing any goods or products into the EU. Traditionally importers would be exclusively larger companies who would resell and distribute the product across the single market.

A company located in europe is a lot easier to hold to account than one outside. Therefore EU places the total responsibility for ensuring compliance with the importer. This legal and financial responsibility should encourage importers to carry out their own compliance checks as if the product is found to be non-conforming or causes harm later on they are solely responsible for the repercussions.

Importers responsibility.

When importing from non-EU countries, importers must check that products fulfil all EU safety, health and environmental protection requirements before placing them on the market. The importer has to verify that

the manufacturer outside the EU has taken the necessary steps to allow the product to be placed on the EU market
the necessary documentation such as the EU Declaration of Conformity (27 KB) and the technical documentation is available upon request
contact with the manufacturer is possible at any time

Source: Europa.eu

Direct to consumer, everyone is the importer.

For a long time this responsibility placed on the importer serviced. However with the rise of direct to consumer services such as Amazon, Aliexpress, Bol.com etc anyone can easily import anything through these sites.

When you order a product on these websites which is located outside the EU you (often unknowing) just became a importer and are now responsible for ensuring the product is conforming to all the relevant EU directives.

Foreign business have no issue adding a fake CE mark and claims somthing is conforming with the EU directives because when something goes wrong they cannot or are unlikely be held to account. Worst case scenario their profile is deleted however they can just relaunch / reupload under another name and ID.

Example: TwoTrees laser engraver diode was banned from sale and marketing within the EU and a recall was issued .

However the same product is back up for sale, with a new seller from china and a new EAN number making it a new product in the eyes of amazon. Link to TT-5.5S on amazon

Until these platforms are forced to take responsibility for the distribution of non compliant products they enable more and more unknowing consumers are at risk of hurting themselves and or others.

Laser Protection

Thu, 28 Jul 2022 07:43:23 GMT

Looks can be deceiving

Recently an article on Rapex came to our attention.

It concerns an industrial sheet metal laser processing machine. On the surface the machine looks modern, clean, well designed and fully encapsulated.

However the importance of detail should never be overlooked. German market surveillance investigated the machine and discovered its protective windows only offer protection level of 0.02, instead of the required level of 4!

How they came to inspect this machine and specifically decided to test the protective windows we can only speculate. However it does make you wonder if some poor worker is now left with reduced vision as a result of this machine or hopefully just a close call!

How do you know your protective windows are correctly rated for your application?

In contrast to Personal Protection Equipment there is no requirement for 3rd party testing by a notified body, or a requirement for marking the protection windows with a rating.
The only option you have: short of testing the windows yourself, is to trust in the manufacturer. Trust that they are sourcing correctly rated protection windows.

How do you know you are working with a manufacturer you can trust?

Questions are your tools here. Aside all the other questions and points to check that we have covered on LaserMachineSafety.eu ask them what the windows are made of, what are their rating?
Manufacturers struggling to provide correct documents (DoC) or answers simple questions they should know often mean they don't want to answer or they don't know the answer. Neither inspire confidence or trust.

What is RAPEX?

Wed, 15 Jun 2022 16:30:15 GMT

The Rapid Exchange of Information System RAPEX

RAPEX was created in 2005 as a means to easily and quickly inform consumers, sellers and general EU/EFTA/EEA markets of dangerous, non compliant products, and to issue protective measures such as product recalls and ban on sales.

RAPEX alerts can be created by national bodies after an investigation has occurred and the product has been found to be non compliant. It also allows for manufacturers and distributors to voluntarily submit recalls if a problem with their product has been detected.

Below is a video from the EU commission on what RAPEX is for; Keeping Consumers Safe.

Source: Europa.eu

Not So Safe Safety Glasses

Wed, 15 Jun 2022 15:52:47 GMT

Safety Glasses not always what they appear

Cheap and unenclosed diode laser cutters have become very popular in recent years. Being low cost and sold by many online retailers, Amazon, Aliexpress, Bol.com to name a few, they are now used by 1000's of people across Europe of which many unaware of the risk to their vision and health.

The legality of these grey imported devices is one question we will cover in another blog. However for now we will focus on the more pressing matter of protecting yourself should you already own one.

While the importance to wear protective googles is known to many users, how many know the googles supplied and 'designed' to keep them safe from the laser radiation are in reality often not providing the protection needed!

A recent flurry of Rapex reports demonstrates how wide spread the issue is.

https://ec.europa.eu/safety-gate-alerts/screen (Search in the Free text for laser safety glasses)

How do you know if your safety glasses are really offering the protection you need?

Personal Protective Equipment is governed by the Personal Protective Equipment Directive 89/6866/EEC

As PPE is essentially the last resort in protecting you from the danger, if the danger is great enough, it is mandatory your equipment is tested by an authorised 3rd party.

Even though laser radiation can cause irreversible damage to heath in the form of lost vision, Non Ionising radiation is not mentioned under Category III and therefore PPE designed for protecting you from Laser radiation will fall under Category II.

According to the Directive, Category II PPE requires an EU notified body approval before they can be placed on the market.

List of E u ropean notified bodies approved for testing PPE

In addition to the European directive there is the European standard for Laser personal eye protection equipment: EN 207:201 7

While standards are not mandatory they are the easiest way to prove conformity and it is unlikely any notified body would approve Laser PPE without its application.

What to look for.

If designed according to EN207:2017, the glasses will bear the marks according to the images below.

In addition to the markings on the glasses you should also receive an EU declaration of conformity.

On the declaration of conformity you should check the certificate is issued by a registered EU notified body for PPE equipment, and the manufacturers name matches the markings on the product and certificates.
Most Notified bodies have a certificate look up. Here is an example from DIN CERTC O i ssuing a correct certificate for CO2 laser protection goggles to our preferred supplier of laser eye protection Laser Pair.

Where to order?

Contact info@lasermachinesafety.co m if you have any further questions or would like to order a pair of certified laser safety glasses from an EU supplier.