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Secretariat IECEE

From: [email protected]
Sent: 03 February 2017 12:59
To: Secretariat IECEE
Cc: D'Ornano, Marie-Elisabeth; Bourgès, Didier
Subject: RE: Follow-up on CMC Decision 45/2016 - To consider the Status of the acceptance
of CB Test Certificates based on CTF Programs

Importance: High

Categories: Sonia

Dear Sirs,

With reference to your below message, and according to our current position described on the IECEE website as
follows:

http://www.iecee.org/dyn/www/f?p=106:12:0::::FSP_ORG_ID:13343:
CTF Stage 4

This stage is not recognized by the French rules in order to deliver French National Mark of Conformity. 1. Objective Many manufacturers who use the ECS
Schemes have capable testing laboratories in terms of personnel, facilities and equipment, for testing the types of product for which they have
responsibility for design, development and production. In recognition of the market needs to utilise these facilities, procedures have been established for
obtaining Notification of Test Results (NTRs) or Marks, such as ENEC and HAR, under controlled conditions. These procedures can be an alternative to
testing at a TL. 2. Terms and References Customer’s Testing Facility (CTF): A CTF is a Customer’s Testing Facility used by the CB to test specified
products. The CB shall ensure continuous compliance with the relevant requirements of EN ISO/IEC 17025, ECS, all applicable Scheme Operational
Documents and OSM decisions. Manufacturer’s Testing Laboratory (MTL): an MTL is a testing laboratory that is owned by a "Manufacturer" who has full
responsibility for continued compliance of the MTL with the relevant requirements of EN ISO/IEC 17025 and ECS and all applicable Scheme Operational
Documents. Supervised Manufacturer's Testing Laboratory (SMT): A manufacturer’s laboratory being used by a CB to conduct agreed testing within
categories of products for which the manufacturer has design and production responsibility, generally with supervision of tests and quality processes.
Testing Laboratory (TL): A laboratory independent of manufacturing interests that has been recognised within an ECS Scheme to test specified categories
of products and to issue test reports. The following documents apply to the general arrangements for the CTF: • ISO/IEC 17025 • ISO/IEC 17065 •
Applicable ECS PDs and ODs • Applicable ENEC, CCA and HAR PDs and ODs • Applicable OSM Decisions 3. Principles The rules laid down in IECEE
document OD 2048 (available on www.iecee.org) apply to the European Certification Schemes with the exception of the limitations listed below: • For stage
3 or SMT, it is not necessary to witness every test programme for mature SMTs. The decision is left to the CB's appreciation. • Stage 4 is not applicable to
the European Certification Schemes. • The EEPCA Secretariat maintains and publishes a register of those manufacturers participating and the categories
of product involved. This document is referenced OD ECS 036 and is accessible on the website for registered users. The change of structure should not
impact the existing management of SMTs. The current contracts remain valid, the stage system will only be applied at renewal of the contract between the
CB and the customer’s testing facility.

we can confirm that CTF Stage 4 is not applicable to the European Certification Schemes (ref. current OD ECS 032
§3):

As a European and French National Certification Body we always have linked the issue of a NTR to the issue of a
1
National NF licence ; that is the reason why we have always considered that we can't accept the CTF Stage 4 status.

However, as a NCB participating in the IECEE CB scheme also, we actually have to accept the tests reports issued
by CTF Stage 4 MTLs and to recognize the relevant CB certificates for issuing our NF licences.
Therefore, we do have to reconsider our position, to comply with the IECEE OD 2048. We will shortly popose another
declaration to be published on the IECEE website in place of the current one regarding our acceptance of MTLs CTF
Stage 4.

Please acknowledge receipt.

Thank you.

Cordialement / Best Regards

Catherine LE GARLANTEZEC
DIRECTION DE LA CERTIFICATION / CERTIFICATION DIVISION

Tel : +(33) 1 40 95 63 83
Fax : +(33) 1 40 95 54 01
Email : [email protected]

LCIE Bureau Veritas


33 av. du Général Leclerc, 92260, Fontenay aux Roses - France
Web: www.lcie.fr

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Secretariat IECEE ---24/01/2017 11:10:00---Dear Marie-Elisabeth, Following CMC Decision 45/2016, the CMC
confirmed that NCBs not accepting CTF

De : Secretariat IECEE <[email protected]>


A : Marie-Elisabeth Dornano/FRA/VERITAS@VERITAS
Cc : Catherine Legarlantezec/FRA/VERITAS@VERITAS
Date : 24/01/2017 11:10
Objet : Follow-up on CMC Decision 45/2016 - To consider the Status of the acceptance of CB Test Certificates based on CTF Programs

Dear Marie-Elisabeth,

Following CMC Decision 45/2016, the CMC confirmed that NCBs not accepting CTF are required
to provide legal documentation, any other non-acceptance is an infringement of the rules. Full
compliance with OD-2048 is mandatory, unless legal basis is provided to support not accepting it.
Otherwise, GNCRs will be issued, which can lead to suspension and removal from the system.

You are therefore requested to provide legal documentation related to your non-acceptance of
CTF stage 4 by 2017-02-24.

Best Regards,

Sonia Alves-Polidori
2
Administrative Assistant

IECEE - IEC System of Conformity Assessment Schemes for Electrotechnical Equipment and
Components| 3 rue de Varembé | PO Box 131 | CH–1211 Geneva 20 | Switzerland | T +41 22 919
0223 | skype: sap_iecee
www.iecee.org
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