Supply chain shortages are forcing manufacturers to revise products by switching to materials and components that are more readily available. These revisions are requiring regulatory re-certifications, which are mandatory to sell in most markets. Re-certifying products (particularly in a hasty manner) can have adverse effects on both cost and time to market. Two common questions that arise are: Do all revisions require re-certification? How can the time and cost associated with re-certification be minimized?
Product changes affect certifications in three main ways:
- No Certification Change – The product’s model number does not change, and the modification to the product does not affect the overall certification.
- Paperwork Revision – The model number changed and/or the changes to the product can be assessed without requiring a sample for review or re-test.
- Re-Test Revision – Changes made are significant enough to require sample(s) to be sent for re-evaluation and testing.
Why Are These Categories Important
Getting the correct category can be critical in getting revised products to market on time and on budget. For instance a Category 1 revision does not require re-certification. There is no associated cost, and no delay in getting to market. A Category 3 revision on the other hand, requires one or more samples to be shipped (at a time when they may not be available) and could take months, not to mention the costs could be painful.
Determining Your Revision Categories
Products carrying multiple certifications can be affected in different ways by the same revision. It could be that a product change falls under a Category 1 revision for one type of certification, while coming in as a Category 3 for a different certification. The correct categories for a revision depend on how certification standards and scheme requirements are affected by the changes made to the product. Making the correct category determination requires a knowledge of: the product, the standard, and how the certification scheme is structured and implemented.
Technical knowledge of the product and what has changed in the product enables one to determine which standard and scheme requirements are applicable. Understanding the intent of the specific product standard is the key to unlocking the correct category. It enables one to determine how changes made would affect the original testing and/or evaluation conducted. Certification scheme requirements are also an important piece of the puzzle. For instance, some scheme types may view a certain component as critical and require it to have its own specific approval, while other schemes would not. Another factor is certification scheme structure. Some schemes are structured as self-declaration, where the manufacturer has the flexibility to determine compliance. Others are granted by certification bodies. All these variables can affect how revision categories are determined.
Ideally revision categories should be identified during the re-design process. Certification should be one of the factors in determining available options. That way all the variables mentioned above can be considered before the design is finalized. Designing for the lowest revision category is the ultimate spoiler to re-certification surprises.
Driving Your Categories with Certification Bodies
Most types of certifications are granted by certification bodies, such as UL, TUV, CCC, etc. In these situations, revisions must be processed and approved by the issuing body. These certification bodies don’t necessarily have seasoned experts scoping projects, nor is it in their best interest to try and minimize re-certification efforts. As a result, their tendency may be to error on the side of caution, resulting in higher category numbers.
Some believe that certification bodies dictate all aspects of certification including revisions. Although it is common for certification bodies to make revision category determinations, having your own strategy can be a game changer. For instance, submitting a revision to a certification body under a pre-determined category has a better chance of being processed under that category than if it were submitted care of the test-house. Such a revision request should be more along the lines of “here’s what we want you to do.” as opposed to “what should we do?”. In fact, not all product revisions even need to be reported to certification bodies. Certification reports are commonly granted with an inherent degree of flexibility. Understanding what flexibility is granted and why will help in identifying and driving the right category.
It can be said that revisions require a deeper understanding of certification requirements than new product submittals. New products generally proceed through a pre-determined path dictated by a standard test plan. A product revision on the other hand, may or may not affect the results of previous tests or alter the constructional requirements associated with the certification scheme in place.
Understanding which areas of certification are affected by a revision is critical, but not simple. In fact, this ability takes years of experience as well as some good old fashion horse sense. Having access to the right expert is truly invaluable. This individual or team can analyze product changes, identify potential pitfalls, and develop efficient strategies while minimizing costs. The old adage of being the master of your own destiny applies here, but does require a master.
If in-house expertise is not available or overwhelmed, an independent, unbiased, certification expert or organization such as G&M Compliance may be a good option. Having the experience and expertise in place to map the right path for re-certifications might just pay for itself.