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有兴趣的还可以参考一下这个英文文章
Now that mandatory low-voltage requirements are the law in Argentina, manufacturers must ensure conformity or be denied access to this market. 0 I* t: y6 D. H' i: U! m. G
In recent years, many electrical equipment manufacturers have become accustomed to supplying to the various markets in South America, which has been relatively unhindered by regulations. Today, however, several countries in this region are considering enacting mandatory certification requirements. In Argentina, almost all low-voltage electrical equipment has been covered by the mandatory requirements of Resolution 92/98 of the State Department of Industry, Commerce, and Mining since August 1998./ l4 N& i+ B9 T2 X6 E1 w1 ?
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Before 1998 in Argentina, compliance with low-voltage electrical safety requirements was mandated for only a limited range of electrodomestic products. The new regulation is much wider in scope, as many manufacturers have already discovered by having noncompliant equipment impounded by Argentine customs.
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Resolution 92/98 covers all low-voltage electrical devices, equipment, or appliances that have a nominal voltage up to 1000 V ac or 1500 V dc. All products sold in Argentina that have an external power supply must meet the requirements of Resolution 92/98 with respect to the power supply. The main piece of equipment, provided it is rated below 50 V, does not require electrical safety certification., r. p+ H) D/ n: B: ?
5 _# l) h. V' X! dThe resolution establishes the essential requirements for compliance and sets out the procedures and time scales for safety certification of low-voltage electrical products. It is the responsibility of manufacturers, importers, distributors, and suppliers to ensure the certification of their products by demonstrating that they meet the essential safety requirements in place at that time. Failure to demonstrate compliance can result in having equipment held by customs.
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Essential Requirements
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The essential requirements defined in the resolution are grouped into three categories: general conditions, protection against harm originating from the electrical equipment itself, and protection against harm originating from external influences on the electrical equipment.
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According to the resolution, reference can be made to national technical standards, such as those produced by Instituto Argentino de Normalización (IRAM), Argentina's leading standards-writing and certification organization, or to international standards, such as those of the IEC, for the purpose of demonstrating safety compliance.
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; g7 l) }! O* G7 ]" Q+ @6 yGeneral Conditions. Any instructions for use that must be observed in order to ensure safe operation should appear on the equipment itself. If this is not possible, these should appear on an instruction sheet supplied with the equipment. In both cases, these instructions must be in the national language.
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The equipment must be marked with the manufacturer's name or registered trademark and address, the name and address of the local distributor or importer, and the name or model number of the equipment. If this is not possible, the manufacturer's name or trademark and the equipment's model number must be marked on the equipment itself, and the other details must appear on the packaging.
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The equipment and its constituent parts must be manufactured in a way that guarantees that it can be connected safely and correctly.8 f) J7 z! p: L8 G0 G7 ^. f0 Y
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The isolation class must be adequate for the intended use and the conditions of use of the equipment. Isolation classes 0 and 01 are forbidden.
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Protection against Harm Originating from the Electrical Equipment Itself. The design and manufacture of the equipment must ensure that people and domestic animals are adequately protected from the risk of injury or damage caused by direct or indirect contact with the equipment.$ E8 ? c/ H$ A/ d& C% u" L
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The design of the equipment must also not produce dangerous temperatures, arcs, or emissions.
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( K; n, X: Q' ^8 S# I' fThe design and manufacture of the equipment must ensure that people, goods, and domestic animals are suitably protected against any nonelectrical risks that the equipment might present.6 b( g: _; u/ W. R" r. m* G
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Protection against Harm Originating from External Influences on the Electrical Equipment. The equipment must meet all applicable mechanical requirements that are intended to prevent harm to people, goods, and domestic animals.) u2 b) Q% T+ I, h
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The equipment must resist all nonmechanical influences likely to be encountered under the environmental conditions for which it is intended, in order to protect people, goods, and domestic animals from harm.1 _. |/ {# y9 k1 j- a
0 l) N% X' y- ^ U5 tThe electrical equipment must not endanger people, goods, or domestic animals in overvoltage conditions.
8 |5 Z* X; e4 G7 T! d: `( KTransitional Plan
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Argentina's three-year implementation plan for Resolution 92/98 provides a transition period for electrical and electronic equipment manufacturers before their products must display a safety certification mark issued by a certification body accredited by the Organismo Argentino de Acreditación (OAA), the Argentine accreditation body.) m; i; i# j& V' a4 ?
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The resolution allows for three implementation stages, which vary depending upon the class of equipment (Table I).
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Product ; J* |& a& \2 l" N# I: n
Type Electrical Materials and Wiring Devices Rated below 63 A Rated below 50 Vand from 50 to1000 V ac or 50 to 1500 V dc- @. D- U% ^) T" G
Household Electrical Appliances A Rated below 50 Vand from 50 to1000 V ac or 50 to 1500 V dc Electronic Apparatus A Rated below 50 Vand from 50 to1000 V ac or 50 to 1500 V dc Electrical and Electronic Products Rated below 50 V and greater than 63 A (covered under Dispositions 1009 and 34)
6 y4 h7 B! b# S5 P8 \Stage One: Self-
; H6 F. { T% W9 F# F) J' C, x, A" jDeclaration August 18, 1998 August 18, 1998 August 18, 1998 August 18, 2000 ( [' W' ^" L6 K4 i% y
Stage Two: Type
7 ^2 V7 C9 g1 _* e+ w9 W; QCertification February 18, 1999 April 18, 1999 September 18, 1999 August 18, 2001
! S# A n- W4 P8 N2 ^7 [; t( NStage Three: Conformity
2 \( }1 s% o' d- M& bMark February 18, 1999 April 18, 2000 June 18, 2000 August 18, 2002 6 q; R: H+ I9 ^8 ^6 a0 w. O
Table I. Three-stage implementation of Resolution 92/98. ! G6 i6 S! [6 _% l( D
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Stage One: Declaration of Conformity. In this phase, the manufacturer or importing company must present the Dirección Nacional de Comercio Interior (State Office for Home Trade) with a Declaration of Conformity (DoC) to the essential safety requirements of Resolution 92/98.6 }' O1 E7 M) f+ S: i- t
' x" _$ d* h! @; V: K& zThe declaration, consisting of three pages, must be in Spanish and must conform to the example that is included in the resolution. An electronic copy of the declaration is available from the State Office for Home Trade. English translations of Resolution 98/92 and of the DoC, along with guidelines on how to complete the declaration, can be obtained by e-mailing info@icc-uk.com.
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For imported equipment, the declaration must be presented for every shipment, even though the information on the declaration is the same as that for previous shipments. Each declaration must indicate the quantity of equipment contained in that shipment. Any low-voltage electrical equipment entering customs will be stopped unless evidence can be provided that the DoC has been presented to the State Office for Home Trade.1 D$ |, ]) C' J) P6 q
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The State Office can usually provide the necessary information to customs. A copy of the declaration must be kept by the distributors and suppliers of the equipment so it may be produced upon request.
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For most equipment types, the resolution has already entered stage two of the transitional process. This means the only products that will need to follow stage one in the future are those electrical and electronic products rated below 50 V and greater than 63 A. Disposition 1009 has delayed the inclusion of these products into stage one of the resolution until August 2000.3 Y8 \# G {8 v$ W- H
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Stage Two: Certificate of Conformity to Type. After the previous stage has been completed, and for a period of one year, a Certificate of Conformity to Type must be presented to the State Office for Home Trade.
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This certificate must be issued by a certification body accredited by the OAA. IRAM is currently the only certification body accredited by the OAA to issue Certificates of Conformity to Type and also safety certification under the conformity-marking scheme. IRAM can be contacted at the following address: IRAM (Instituto Argentino de Normalización), Peru 552-556, 1068 Buenos Aires, Argentina; e-mail: iramelec@sminter.com.ar.
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Granting of the certificate is based on tests carried out by an accredited laboratory on product samples that are selected by the certification body and that are representative of normal production. These tests are performed against national (IRAM) or international (IEC) standards to demonstrate compliance with the essential requirements detailed.
9 Y* `' t6 m" a6 KThe certification body will periodically take product samples from the manufacturing premises or from the market to confirm that the manufacturer is continuing to fulfill the obligations resulting from the original Certificate of Conformity to Type.& e5 }( r4 e4 O( x, M+ s
. x6 j% s6 e, a1 ]" e9 G4 OIn the case of imported products, a Certificate of Conformity to Type issued by a foreign certification body may be presented, providing that mutual recognition agreements have been established with a national certification organization accredited by the Argentine accreditation body.
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6 V. b+ i: ?# q0 w- J9 NOn February 23, 1999, Underwriters Laboratories (UL) signed a Memorandum of Understanding with IRAM. Under this memorandum, IRAM will accept test reports for products evaluated by UL that bear one of UL's family of certification marks, such as a UL, DEMKO (the Danish testing agency), or Underwriters' Laboratory of Canada (ULC) mark, thus avoiding any further in-country safety testing. The UL test reports have to be revalidated in Argentina by a recognized laboratory, but IRAM will handle this on behalf of the foreign manufacturer.
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IRAM will also accept test reports from the Canadian Standards Association (CSA), as long as an IEC standard is specified in the test report. If this is not possible, IRAM will accept the report as long as the CSA produces a declaration to say that the standard it tested against is equivalent to an IEC standard.
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4 g9 n. B1 a" s) N; d* E. b, ^8 nSee "Mutual Recognition Agreements" sidebar for a list of foreign certification organizations with which IRAM has established mutual recognition agreements for the purpose of product safety certification. Safety test reports from such organizations will be accepted by IRAM, avoiding further testing, provided that they are revalidated by a recognized Argentine laboratory. The only institutions whose test reports do not require further validation are LCIE of France and CESMEC of Chile.6 Y8 R4 ]) R2 h7 \
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IRAM will take a maximum of 30 days to review the application forms and test reports in order to issue Certificates of Conformity to Type. IRAM's costs are currently $700 (US) for one product family; $1000 (US) for two product families; and $200 (US) for each additional product family.4 h4 ?, I1 L0 d: R1 |# j7 K( q
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These fees are applicable to each submittal. In addition to the fees above, there is a $300 (US) inspection fee (normally paid by the importer) to carry out a visit to the importer's warehouse, with the purpose of checking that the imported products are identical to the ones detailed in the relevant test reports. This amount is applied assuming that the inspection can be performed in half a day. If the inspection requires more time, there is an additional $500 (US) fee for each complete inspection day. A copy of the certificate must be kept by the distributors and suppliers. There will be no safety certification mark required during this stage.
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Stage Three: Product Certification and Marking Scheme. In this final stage, all products covered by the resolution must have a product certificate issued under a conformity marking scheme aligned with the model described in ISO/IEC 28 (IRAM 354) and issued by an Argentine accredited certification body.
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- O$ W- {3 G; [& J, N0 P, rAlternatively, the equipment could be certified under a marking scheme by a foreign certification body, provided that it has established mutual recognition agreements with an accredited Argentine body. Such a mutual recognition agreement must cover the assessment of equipment and accompanying technical documentation to ensure the validity and scope of the certification.7 T( z/ a+ a1 F% w
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Under this final stage, all equipment will be checked to ensure that it is marked with the appropriate safety mark when arriving in customs. The national safety mark has not yet been defined and will be the subject of future legislation.
- r8 u- ?7 X# h+ _) ~Temporary Exemptions and Other Amendments
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The State Office for Home Trade published Disposition 1009 on August 19, 1998. This disposition contained comments on Resolution 92/98 and established several articles to clarify its enforcement.
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To take greater advantage of available resources, the State Office for Home Trade decided that it would be preferable to allow additional time for certain types of equipment to meet the requirements of the resolution. It was also decided that there should be a transitional period in which manufacturers and importers would have the opportunity to prove compliance with the regulations after the arrival of the equipment in customs, if compliance had not been ensured prior to shipping.
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2 M9 e W: k5 g6 B6 @Temporary Exemptions. Disposition 1009 postponed the enforcement of Resolution 92/98 for all electrical or electronic products designed for use with voltages less than 50 V or nominal currents greater than 63 A until August 18, 2000.
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During the following year, those responsible for placing this equipment on the Argentine market will have to present the DoC, established in stage one of the resolution, to the State Office for Home Trade.
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+ o, d% O# W+ c0 t# d' yAfter August 18, 2001, these products will become fully integrated into the transitional procedures established by Resolution 92/98 and will be subjected to either the second or third stage of its implementation.
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Mutual Recognition Agreements & `# K2 Y1 q! M @- @% y
Instituto Argentino de Normalización (IRAM) has established mutual recognition agreements with the following certification organizations:
& }2 R! z8 [8 ~1 {; w3 [* m0 m1.UL: United States
( d/ Z' n* x! l2 e* E2.ITS: United States ; |2 `3 h6 n5 I. e7 F* B
3.CSA: Canada 4 _* v% m0 b# L! @
4.ANCE: Mexico*
9 C& V$ _4 p# ^/ M: @! ^5.INTECO: Costa Rica*
' q' A- c; A9 T/ `6.ICONTEC: Colombia* 2 U* o! {: [" Y+ x
7.UCIE: Brazil* : U6 i. `) y1 H; A/ A2 u
8.CESMEC: Chile
% o" r1 ^/ Z9 _. H3 Y$ }9 l9.UNIT: Uruguay* 8 F' i' H n' h! Y# T$ {! n
10.ASTA: United Kingdom
- p. U2 L% W- ?+ @( u, A11.AENOR: Spain
2 [1 U/ _1 c" J1 X9 o12.LCIE: France
( Z/ x' A5 f) V) E13.IMQ: Italy 8 C% g3 `) ^$ T7 b( O0 X
14.VDE: Germany
* q/ a0 _, w2 i/ G15.KEMA: Netherlands b- Z! h1 _- ]! W4 F/ C2 x @
16.CEBEC: Belgium
/ d# a2 I) \: L$ k! Q; u2 x17.DEMKO: Denmark (through UL)
+ U, k+ j: l5 a% x3 u) ~ [" z7 S18.SEMKO: Sweden (through ITS) : R2 b: Z# V3 v- j2 [; X j
19.SEV: Switzerland
( N% ]5 \1 u) V [20.NEMKO: Norway 8 u" P7 Y1 N& U/ a9 j# r5 b4 Y# [
21.ÖVE: Austria ! E! _7 C6 f* O! `
22.FIMKO: Finland
; B" T3 r) e$ _2 I a23.PSB: Singapore 4 ]. x! J$ Z" t! o
24.JET: Japan
p' e5 Q; T6 b5 ^6 w9 x; u. m25.JQA: Japan 5 t1 c# W9 P% \8 T
26.QAS: Australia**
; |" N K# k8 E1 F( k27.TÜV Rheinland (Germany, North America, and Asia)** . S, b0 L. R3 c) s3 f8 m H
28.TÜV Product Service 5 \6 G) T4 @: y. n1 ?, _7 h
*Agreements 4, 5, 6, 7, and 9 don't include Type Certification. 8 |' V Q( f2 v4 ]# O6 i
**Agreements 26 and 27 include only Type Certification.
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Other Exemptions. Components intended to be integrated through a manufacturing or assembly process into a product covered by the same legislation are not to be subject to the requirements of the directive when they enter the country. If they are to be sold on the internal market, however, they must meet the requirements of the resolution.. m: d4 v7 [9 k |" ~# b; m/ q) k
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This exemption also applies to those products that come into the country under a temporary import permit, such as product test samples.
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2 H# K T7 |( B2 J- WProcedure for Noncompliant Equipment Arriving in Customs. In cases where the State Customs Office verifies lack of compliance with the resolution's requirements, it will be possible to release the merchandise "without permission to be used" (under the terms of Law No. 22.802), as long as the importer takes the necessary steps to rectify the situation.
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To take the steps, the importer must inform the State Office for Home Trade, by means of a sworn declaration, of the quantity and type of merchandise, its country of origin, and the place where it will be stored until it is brought into compliance with the regulations that are in force.
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Within 60 days following the withdrawal of the merchandise under the conditions described, the importer must make the Declaration of Conformity to Type, or obtain a Certificate of Conformity, and present it to the State Office for Home Trade, which will authorize the release of the merchandise for sale and subsequent use, within 10 days of receipt of the correct documentation. 0 I1 x* J; w3 S9 i! W- e; |
Mandatory Regulations- Q$ R, n) Y* O0 S
# p6 Q( J: _# m9 A" U3 wLow-voltage equipment manufacturers who wish to do business in Argentina must understand that the rules for market entry have definitely changed. Since 1998, compliance with the requirements outlined in Resolution 92/98 is mandatory for any product sold in Argentina. Manufacturers must begin now to take the necessary steps to follow the transitional plan for conformity outlined in the resolution. & F+ G4 ~7 W, u8 F# c
Helen Jones is the South American expert at InterConnect Communications (Chepstow, UK; http://www.icc-uk.com). InterConnect offers global conformity assessment services to manufacturers of radio and telecommunications terminal devices throughout South America, Eastern Europe, Asia, the Middle East, Europe, and Russia. |
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