Exporting to the USA and Canada – Common misconceptions and how machine manufacturers can avoid them

Dirk Meyer: The CE mark is very important in the EU, but in North America it simply plays no role. There, they have their own system of codes and standards as well as requirements from independent testing institutions. The USA and Canada do not have a Machinery Directive, but instead follow regulations such as the NEC, CEC, NFPA specifications, UL standards or OSHA specifications, as well as local state and county laws.

This means that a machine can be safe according to EU standards but still not meet the criteria that are relevant in North America. This does not mean that it is unsafe – rather, the requirements are simply structured differently and must be implemented differently. While the main focus of CE is the safety of the machine operator, in North America it is extended fire protection.
 

Dirk Meyer: That is a common misconception. There is no such thing as blanket ‘UL certification’ for complete machines. UL is just one of several organisations – known as ‘National Recognised Testing Laboratories (NRTL)’ – that certify electrical equipment. UL also develops US standards – components and control cabinets are usually certified.

At the end of the day, every electrical installation must be approved by the local authority (AHJ – Authority Having Jurisdiction). The National Electrical Code (NEC) and, if applicable, local codes are used as a framework for assessment. The operator is usually responsible for reporting to the AHJ. The local AHJ, in turn, may require certification by an independent third party (NRTL), but may also object to certified installations.

The differences to the EU therefore lie less in the level and more in the procedure: strict electrical requirements, mandatory listed components and a very clear separation between manufacturer responsibility and operator responsibility.
 

Dirk Meyer: The USA has a very strong culture of liability, which makes documentation all the more important. However, the effort involved does not necessarily increase, it just changes.

Warning notices must be designed in accordance with ANSI Z535, i.e. they must be more clearly visible, more structured and legally unambiguous than many European labels. Operating instructions must be written in English and clearly aimed at the typical US user.

Good documentation is not only expected in North America, it also facilitates approval by local testing authorities.
 

Dirk Meyer: It is important to make a clear distinction between fire safety and functional safety. Fire safety is usually assessed by government authorities and supported by certifications from independent NRTLs. During commissioning, an inspector (AHJ) visits the site to inspect the machine. Among other things, electrical equipment is checked in accordance with NEC, markings and warning notices, listed (certified) components used, installation and earthing, and, above all, documentation and operating instructions. The operator is responsible for correct installation.

The manufacturer must ensure that the machine complies with the relevant North American standards. Only when this interaction works can the acceptance run smoothly. The operator, in turn, has a strong interest in ensuring that the machine is also functionally safe, but for this purpose, the known safety standards such as (EN) ISO 13849-1 or (EN) IEC 62061 can be used in accordance with Annex A of NFPA79.
 

Dirk Meyer: The classic mistakes are: installing unlisted components, European cables and installation methods that are not approved in the USA, incomplete or non-ANSI-compliant warning notices, failure to consult local authorities at an early stage, and leaving it too late to deal with US standards.

All of these mistakes are avoidable – and they usually cost a lot of money if they are only noticed shortly before acceptance.
 

Dirk Meyer: Before designing or planning, there is one key question: What exactly will be installed where, and who is responsible? This includes clarifying the requirements in the federal state or province, knowing the customer's specifications or NRTL preferences, early determination of listed components, analysis of the relevant standards, or creation of a North American concept as early as the planning phase.

Planning all of this early on saves considerable costs later on and avoids delays.
 

Dirk Meyer: Not directly – safety standards remain in place regardless of customs duties. Indirectly, however, it certainly does: higher customs duties can influence the choice of components, lengthen supply chains or change procurement costs. If this results in different parts being used or delivery times changing, this in turn has an impact on certification.

It is therefore important to plan projects carefully with regard to the availability and compliance of the components used and to ensure compliance with North American codes and standards.