European law lets you do E-Mark tests at home

Concerned about the huge investment in time and money a full E-Mark portfolio can cost you? Help is near. You just need to know who to ask.

As a parts maker, you are often faced with a dilemma: Do you want to enter the European market and/or the more than 100 countries of the world that are part of the ECE regime? If so, then many of your parts need ECE certifications, or E-Marks for short. A full portfolio of E-Marks can cost you a lot of time, and even more painfully so, it will cost you a lot of money. Without the investment, you are locked out of a huge market. With the investment, who guarantees that you will ever get your investment back?

Then, there is another matter that is bugging you: Your company has invested huge sums in testing equipment. A Link tester for brake pads for instance can cost you easily over a million US dollars. But when it comes to getting your E-Mark, that Link tester is worthless. The European lab that processes your E-Mark application insists that you use their equipment. Some European labs (especially the cheaper ones) don’t even have elaborate equipment like you have. But nevertheless, they insist on doing the work at their lab – for a lot of money. For how long have you been bothered by this?

Don’t worry anymore. There is a solution to this dilemma. A European technical service is no longer required to conduct the test in its own labs. They can perform the tests and measurements on your equipment, or in any lab that is capable to do the test. Understandably, they may not tell you this. You need to ask them.

The door to this was opened by the EU Directive 2007/46/EC. As with all EU directives, it takes a while for them to become effective. It just did. The directive requires that European labs are accredited under DIN EN ISO/IEC 17020: 2004. Once accredited, the lab can perform the measurements and tests “in the facilities of a manufacturer or of a third party,” as the EU Directive 2007/46/EC says.

All that technical service needs to do is to inspect your lab, make sure that the equipment is sufficient and properly calibrated. Then, your lab is entered into a list they keep. From now on, all tests can be performed on your equipment, as long as a representative of the European lab is witnessing the test.

Again, the European lab must be accredited and certified by their government to do this. Only a few labs are accredited so far. The ones who are accredited can save you a lot of time and money. When you shop for certification services, remember to ask this sentence: “Are you accredited to perform tests on manufacturer or third party equipment under the DIN EN ISO/IEC 17020: 2004 standard, as defined in the new EU Directive 2007/46/EC?” If the technical service representative looks at you as if you’ve just come from Mars, and if he has never heard of this, better look for another technical service.

Xaver Fackler, CEO of the FAKT testing and engineering center in Germany, who was recently interviewed by Gasgoo, said: “ECE testing at the manufacturer’s location can bring big savings in time and money. It also brings additional know-how for the manufacturer’s own personnel. If they pay attention, they learn all the steps we used in our own labs.” FAKT just completed the accreditation procedures with the German government and should be one of the first certification services that can test on your equipment.

Mr. Fackler revealed a well kept-secret: Even before the new directive, testing was possible under the ISO/IEC 17025 standard. Did anybody tell you this? “It involved a lot of paperwork and complicated procedures,” Fackler said. For the time of the test, the manufacturer had to sign over the testing equipment into the sole control of the technical service, which then performed the test. It required a lengthy application process, and also exposed the manufacturer’s lab to spot checks by European governmental agencies. With the new directive, this is a thing of the past.

Now if you could only do the CCC end ECE test at the same time, you would save even more time and money. In the meantime, the new European directive is a step in the right direction.

About the author: Bertel Schmitt, Gasgoo's columnist, is CEO of Hong Kong based parts sourcing company Sinamotive. Before founding Sinamotive, with the assistance of U.S. venture capital, Mr. Schmitt was a marketing consultant to Volkswagen AG.