Tricks of the ECE trade. Part 4

You invested a lot of time and money into getting your E-Mark. It can be easily lost. Here is how to keep it.

In the last three installments of this series, we talked about the general aspects of ECE certification, about how to successfully pass the initial assessment, and about how to submit your parts for certification. In the last and final installment of this series, let’s talk about how to produce and perform under ECE rules.

An ECE certification is a little bit like a driver’s license: Just like with a driver’s license, you must show your proficiency and successfully pass tests. Once the license is issued, the hard part begins: You must observe the many rules governing your license, or your license is gone.

Some people view a driver’s license as a license to drive recklessly and drunk. Those people usually lose their license quite quickly, often after having caused considerable damage.

Most people know that the right to drive a car is a privilege that must be earned by driving responsibly. Those people will drive a car for the rest of their lives.

The same holds for an ECE certification. Some companies think, an ECE certification is nothing more than a diploma which you hang on the wall, and which can be otherwise ignored. Those companies run the high risk of losing the certification, sometimes after considerable damage has been caused. Their company gets involved in law suits for product liability and violation of supplier contracts. Often, the company has to close its doors.

Most companies know that an ECE certification is a privilege that must be earned by manufacturing the products under the strict specifications of the ECE rules. Those companies have a long and bright future.

Here is a short list of the most important aspects:

Make your product as certified: Once ECE certified, the product must be produced exactly as described in the ECE certification. No ECE-relevant changes to the product are allowed. Even a small change to the product can mean that you lose the E-Mark. This must not stop you from making improvements to your product. Additions to the product are usually allowed if they don’t bring the product out of ECE spec. ECE-relevant deductions from the product are not allowed. If significant additions are made to the product, it is often wise to file an amendment to the certification. Changes to the basic characteristics of the ECE certified product are not allowed. Your technical service will advise you when an amendment is necessary, and when the change of your product demands a complete re-application.

Mind your markings: Proper markings of the product are essential for ECE compliance. Follow the specifications for how your product must be marked and packaged. At the minimum, the product must carry the E-Mark logo (Letter E with country code in a circle,) the E-Mark number assigned, the name of the company associated with the E-Mark number, a part number, and a batch number. Other rules apply for outside packaging. Even the size and shape of the E-Mark logo are tightly regulated. Make sure that the regulations are observed, that the markings are legible and permanent.

Often overlooked: Your product has an E-Mark. It is registered to your company. You manufacture the product for a customer who sells it under his name. You proudly put your E-Mark number on the product, and ship it. Big mistake. The product is illegal. The E-Mark number must be associated with the company name on the outside packaging and the markings on the product. If the E-Mark number is in your name, and if only the name of your customer is on the package, the product breaks the rules. There are two ways of solving it: You either put the name of your company in small letters on the outside of the package. Or you file an amendment that lists the name of your customer as a trade name on the certification. Overlook this little detail, and it can cost you your E-Mark. Also, it may turn into a nasty argument with your customer who contracted that you deliver the product with a valid E-Mark. Don’t assume that your customer knows this. He is no E-Mark specialist, he expects you to know the rules. We have to explain this rule again and again to manufactures. Again and again, manufacturers get suspicious and think, adding the name of the customer to the certification means giving away their E-Mark. An E-Mark cannot be given away or sold. But it can be lost if the rules are not followed.

And here is the most important part: Sadly, this is a part that must be explained again and again to manufacturers. Under ECE rules, it must be assured that the manufactured product is the same as the product that was certified. The manufacturer must be able to prove this, long after the product was manufactured. This involves systematic quality control and meticulous record keeping. This process is called “Conformity Of Production,” or COP for short. The process itself must be documented. Regular measurements must be taken from the running production. The results must to be documented and filed for easy retrieval. If there is a problem with a manufactured product, these COP documents will become very important.

An E-Mark is easily lost: Usually, when a product ships, all your troubles end. With E-marked products, the big trouble can come long after shipping. Someone could be involved in an accident. A newspaper could run a test and come to the conclusion that your part is not E-Mark compliant. The competition may not be happy with your product taking their market share. They initiate a test of your product. Your competitor claims that your product wasn’t in spec. If any of these come to the attention of the government agency that awarded your E-Mark, the government agency can order a surprise audit of your company. The first thing the auditor will ask for are your COP documents. If you don’t have them, the auditor’s job is completed. He will go back, and recommend that your E-Mark is revoked due to a lack of sufficient COP documentation. If you can show the documentation, and if the auditor finds no problem with the data, your position is much better.

Don’t even think of doing this: Once in a while we come across fake E-Marks. You don’t have to be an expert forger to fake an E-Mark, any fool with a computer can do it. Only a fool will do it. The forgery can be very easily detected: All E-marks are in a central database. A professional customer will check every E-mark number against the database. If the number does not exist, or is not in your name, then this will mean the end of a customer relationship and the beginning of a lot of trouble.

This concludes our four part mini series about the tricks of the E-Mark trade. We hope it will be profitable for you.
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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.