SWTC SWC · France

法国客户催着要CE ErP报告,你手头的测试报告为什么被退回来了?

Factory friends targeting the French market, pay attention: the CE ErP matter is not the same thing as ordinary CE (such as LVD, EMC). ErP stands for Energy-related Products, and it is the EU's ecodesign framework directive. Put plainly, it does not care whether your product is safe or whether it causes electromagnetic interference; what it regulates is whether your product "consumes electricity, consumes water, and can be disassembled for recycling." As an EU member state, France implements the specific implementing regulations under the EU ErP directive, such as standby power consumption, energy efficiency labels, and off-mode power consumption. If your product has a power supply, a motor, a heating element, or even just a standby indicator light, it may fall within this framework.

Which products need to comply? The scope is larger than you imagine. Home appliances (refrigerators, washing machines, air conditioners), luminaires and light sources, motors, water pumps, fans, televisions and monitors, set-top boxes, external power adapters, and even power tools and garden equipment are all governed by different implementing regulations. The most common pitfall is: many factories think that once CE-LVD and EMC are done, everything is complete, but when French customers clear customs, they ask for the ErP energy efficiency test report and declaration of conformity, and you cannot provide them. The second pitfall is standby power consumption—the EU has clear limits for off-mode/standby power consumption, and many small appliances exceed the limit just by being plugged in with a light on; if your own laboratory has not tested it, it will fail once it goes to external testing. The third pitfall is energy efficiency labels. For example, for luminaires and home appliances, France requires the new label under EU 2017/1369 and registration in the EPREL database. If your label format is wrong or the QR code cannot be scanned, the customer will directly reject it.

In terms of timeline, it depends on product complexity. If it is a single category, with complete documents, and the test is passed on the first try, from sample submission to issuing the report and declaration of conformity usually takes two to three weeks. But if energy efficiency label registration, EPREL data entry are involved, or if the test fails and the circuit or power supply must be modified, then you need to allow a buffer of more than one month. It is recommended that before accepting a French order, you first confirm whether the customer wants the ErP test report, a sample of the energy efficiency label, or the EPREL registration number; the workload corresponding to these three items is different. Do not wait until the goods arrive at the Port of Le Havre to supplement it; at that time, demurrage costs are much more expensive than certification fees.

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