When it comes to electrical and electronic components and systems, the major difference between the US and European approach to product safety lies in the market surveillance process.
US vs. EU Market supervision is done more strictly in the USA, leading therefore to a sense of certification duty when it comes to E&E products. Due to geopolitical conditions, historically evolved fears and requirements, accessing the US market demands a more challenging product qualification process, which includes production checks, inspections and product certifications.
On the contrary, in Europe a lighter market supervision process is the natural continuation of various EU guidelines that only require the CE marking (http://www.ee.sgs.com/ee_index/safety_ee/general_inform ation_safety_ee/ce_mark_ee.htm) for a many products getting into the EU market. CE marking is not accompanied by any sort of mandatory production inspection or 3rd party testing and certification requirements.
The different approaches to market supervision have yielded different results. In the US there were 563 recalls of unsafe products in 2008, whereas in Europe there were 1866 in the same period. These figures form nevertheless only one indicator for which is the better system.
The goal is harmonization As a result, the controversial harmonization of norms with regards to the different product or environmental requirements, be it supply voltage, fire hazard requirements or product performance, is very difficult to achieve. The EU is slowly adopting more stringent requirements, especially with relation to hazardous substances, while the US is developing new pieces of legislations that include the requirements of EU norms.
Harmonization attempts are the best bet for a better future. Conformity with a standard is the key to worldwide market access.
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