Electrical appliances

Frequently asked questions

I make shades. I haven’t decided yet whether I will only sell shades or finished lamps. I would assemble the lamp from CE marked parts. Do I need Tukes’ authorisation for the manufacture?

The manufacture of electrical equipment is not a licensed activity, so no authorisation is required in this respect. The products must be compliant, and the legislation lays down requirements on how to verify this. The lamp is subject to several regulations such as the Low Voltage, EMC, RoHS and WEEE Directives. If the lamp is sold with a bulb, either fixed or removable, ecodesign and energy labelling requirements must also be considered.

You are the manufacturer of the lamp, even if you assemble it from CE marked parts. It is the responsibility of the manufacturer to verify the conformity of the product, to prepare the documents (technical documentation and EU declaration of conformity) and to label the product with the required markings such as the CE marking and traceability information. The maximum watts and the correct type of bulb must be marked on the lamp’s data plate or on another part of the lamp to guarantee the safety of the product.

The lamp must also come with user instructions in Finnish and Swedish, which contain at least the essential safety information.

If you sell the shade and other parts separately, you are only the manufacturer of the shade and the distributor of other products in accordance with the Electrical Safety Act. The legislation also imposes requirements on the distributor. A simple shade is a general consumer product and subject to the Consumer Safety Act. The Consumer Safety Act contains general safety requirements, i.e. the product must not pose a risk to anyone’s health or property. You must provide all information relevant to the safe use of the product. You must also add the product’s name according to commercial practice and the manufacturer’s name on the product.

Can I sell a self-made lamp at a flea market? My products are unique.

The legislation does not take into account whether only a single article of a product is manufactured or several articles. If you manufacture a new electrical appliance in your business, you will become a manufacturer, and the product you sell will be subject to several regulations such as the Low Voltage, EMC, RoHS and WEEE Directives, and in some cases, the Ecodesign and Energy Labelling Regulations. It is therefore the responsibility of the manufacturer to verify the conformity of the product, to prepare the required documents and to label the product with the required markings.

If you sell a lamp that you have made but do not do so in connection with your business (for example, you made the lamp for yourself as a hobby and are now selling it at a one-off event), the lamp is subject to sections 6 (General requirements for electrical appliances) and 7 (Demonstration of conformity of electrical appliances) of the Electrical Safety Act. The lamp you have made must therefore be safe and not cause harm to its surroundings. You must also be able to demonstrate that the electrical appliance meets these requirements.

There is a growing interest in reusing old electrical appliances, especially lamps, and in repairing and modifying them yourself. Even if an electrical appliance is modified solely for personal use, it must always comply with the relevant requirements. For example, when replacing or renewing a lamp shade, you must take care to ensure that the changes do not cause the shade or the lamp to overheat.

Can an assembler become a manufacturer?

The manufacturer is responsible for the safety and conformity of their product. The manufacturer’s responsibility passes to the modifying party if the product is modified in a way that affects compliance, and if the original manufacturer did not assign the modifications. Similarly, if an equipment is connected with a larger entity, the conformity of the individual equipment is no longer considered, but rather the new functional entity’s. This can happen in connection with assembly, for example.

The assembler is always responsible for their actions. In principle, the maker of a new functional unit (new electrical product) composed of several electrical equipment and components is considered the manufacturer. The assembler is not considered the manufacturer if the functional entity they made meets all the following conditions:

• The entity consists of equipment of only one/the same original manufacturer.
• The appliances in the entity are designed and intended to function together.
• The appliances have not been altered or modified in a way that deviates from the manufacturer’s instructions.
• The appliance was assembled in accordance with the manufacturer’s instructions.

New electrical products made by the assembler are not put on the market for sale. Instead, they are made for a specific fixed installation. Therefore, these appliances do not need a CE marking or an EU declaration of conformity, which are the cornerstones of free movement. However, the products must comply with the requirements of the Electrical Safety Act, and they must be identified, equipped with a type plate and contain the name and address of the manufacturer (=assembler).

What does an IPX4 label on a lamp require?

In tests carried out in connection with market surveillance, several lamps failed to meet their required class of enclosure against harmful water penetration. Many lamps classified as IPX4 (splashproof) failed the tests as water entered the lamp, even though the lamps had no drain holes, meaning that water must be kept from entering the lamp.

The enclosure class is determined with a standardised test method. For example, in the IPX4 test, the lamp is mounted on a rotating stand, and water is splashed at it from all directions. At the beginning of the test, the lamp is on, and it is switched off halfway through the test. The test on the lamp’s sealing is quite demanding. As the lamp cools down, a vacuum may easily form inside it, which can cause water to be absorbed into the lamp, even if it would not enter a cold lamp when immersed under water, for example.

I’m planning to start importing travel adapters. I am interested in what typical defects can occur in travel adapters.

You can find a travel adapter, or more formally a conversion adaptor, in almost every traveller’s cupboard. However, this simple appliance often has significant or serious defects that pose a risk of electric shock.

Between 2003 and 2019, Tukes tested approximately 100 travel adapters, and the sales of more than half had to be restricted. However, most faults can already be detected visually, so companies can easily inspect the travel adapters themselves before placing them on the market. Typical defects are:

• The plug can be inserted into a travel adapter so that the other pin can be touched.
• Insufficient mechanical structure/insulation of the travel adapter creates a risk of electric shock when the plug is only partially inserted into the adapter.
• The travel adapter converts the protection class, which means that a class 0 plug can be connected to a socket with protective grounding, for example.
• The travel adaptor’s socket lacks shutters (finger protectors).
• There are shortcomings in the USB charger integrated in the travel adapter, which may cause an electric shock or fire hazard.

Can I sell the product in Finland if it has a foreign plug?

In terms of plugs, the most common shortcoming today is related to devices ordered from foreign online stores, which are delivered with a plug that is not suitable for Finland. In these cases, a travel adapter may also be provided with the appliance. In general, only products with a suitable plug for our system may be sold to and in Finland.

Can I send a product to Tukes for inspection?

Unfortunately, this is not possible. Product surveillance does not approve products in advance or assess documents. Instead, Tukes’ role is to simply assist in the interpretation of the legislation and to guide operators on where to find the right sources of information in addition to actual random market surveillance. Ensuring product compliance is the responsibility of businesses, and they can get help from commercial operators such as testing facilities if they wish.

I make LED lights, but I buy needed transformers from the market. Is it enough that I only EMC test the luminaire?

The transformer is an integral part when assessing the electromagnetic compatibility of a LED light. The EMC assessment must therefore be performed for the whole unit on sale, i.e. the luminaire + transformer unit. Of course, the manufacturer of the transformer has already made an EMC assessment for the product. However, a resistive load has been used in the EMC tests, as the transformer manufacturer does not know where it will be used. However, the disturbances caused by transformers depend very much on the load used, and as load, the LED lights are anything but resistive.

I use a charger from another manufacturer in my product. However, the manufacturer of the charger has stopped producing the charger in question, so I have purchased another charger for my product. Does the product need to be EMC tested again, as the charger is already CE marked?

The charger is an integral part when assessing the electromagnetic compatibility of a product. The EMC assessment should always be performed for the entire device combination on sale. Changes in the product must be considered in the conformity assessment. A combination of two CE marked devices does not automatically produce a compliant assembly. The change of the charger is significant enough that the EMC assessment of the product must be performed again.

Why does my product contain lead?

Lead is still found in the solder joints of electrical products, although its use has been restricted since 2006. Lead is typically found in the solder joints on circuit boards, but also in the solder joints on USB connectors, for example. Lead concentrations range from a few to several tens of percentages, with a limit value of 0.1 p-%. Leaded soldered joints are the most common cause of non-compliance with the RoHS in Finland and elsewhere in Europe.

The use of lead can be permitted if exemptions have been used in the manufacture of the product. Any exemptions used must be listed in the technical documentation of the product.

Does a battery need to be CE-marked?

Batteries are covered by the Directive on Batteries and Accumulators. This directive is not the same kind of CE marking directive as many other directives, such as the Low Voltage Directive – it has slightly different requirements. The Directive on Batteries and Accumulators contains requirements on restricted substances, labelling and producer responsibility. However, the Electrical Safety Act requires that all appliances are safe.

The Directive on Batteries and Accumulators requires:

• a separate collection marking
• if necessary, an indication of any chemical substance (Pb, Hg or Cd) the battery contains
• capacity marking (for portable and vehicle batteries).

Most batteries contain protective electronics, so they are covered by the EMC Directive, which requires CE marking, traceability information and the preparation of technical documentation, and an EU declaration of conformity.

If the appliance is a backup power source, it is also subject to the RoHS Directive in addition to the EMC Directive. The RoHS Directive also requires CE marking, traceability information, technical documentation and the EU declaration of conformity.

Does a battery need to be CE-marked?

Batteries are covered by the Directive on Batteries and Accumulators. This directive is not the same kind of CE marking directive as many other directives, such as the Low Voltage Directive – it has slightly different requirements. The Directive on Batteries and Accumulators contains requirements on restricted substances, labelling and producer responsibility. However, the Electrical Safety Act requires that all appliances are safe.

The Directive on Batteries and Accumulators requires:

• a separate collection marking
• if necessary, an indication of any chemical substance (Pb, Hg or Cd) the battery contains
• capacity marking (for portable and vehicle batteries).

Most batteries contain protective electronics, so they are covered by the EMC Directive, which requires CE marking, traceability information and the preparation of technical documentation, and an EU declaration of conformity.

If the appliance is a backup power source, it is also subject to the RoHS Directive in addition to the EMC Directive. The RoHS Directive also requires CE marking, traceability information, technical documentation and the EU declaration of conformity.

Should wires/cables be CE marked? Does it make any difference whether the cables are sold at specific lengths or by the metre?

Wires/cables are covered by both the RoHS Directive and Low Voltage Directive, and they must therefore be CE marked. Some of the cables used in buildings also fall within the scope of the Construction Products Regulation, which requires a declaration of performance in addition to the CE marking. 

If the cable is an integral part of the device (television, extension cord), the cable does not need to be CE marked separately, as the CE marking of the article also includes the cable.

In addition to the CE marking, cables must bear:

• A type, lot or serial number that allows its identification
• The name, registered trade name or trademark, and address of the manufacturer
• The name, registered trade name or trademark, and address of the importer
• A separate collection label in the case of a loose cable that falls within the scope of the WEEE Directive

If this is not possible due to the size or nature of the equipment, the required information must be specified on the packaging or in a document included with the equipment.

What are the labelling requirements for the packaging of electrical appliances if there are any?

The consumer must be able to make a purchase decision for an electrical product without opening the product’s packaging. In other words, consumers must be able to determine whether they can use the product safely. The information provided must not be misleading (for example, the package of an electrical product that is intended for indoor use must not contain an image of the appliance in outdoor use).

The information to be provided includes:

• Operating voltage: Whether the appliance is connected to the power grid or operates on batteries or an accumulator.
• Warnings
• Age or size restrictions (for example, toys)
• Restrictions related to the conditions of use (e.g. for indoor or outdoor use only)
• The product is intended for professional use only
• Only a qualified professional is allowed to install the product
• Due to its EMC properties, the product is unsuitable for use in a residential area
• Implementation of the product requires additional parts or devices which are not delivered with the product
• The need for special tools during assembly, for example

In the case of a product subject to an energy labelling requirement, the energy label must be displayed on the packaging of the product only if there is no display unit of the product and its energy labels, or if it is a light source.

An electrical product does not need packaging if the necessary information, safety information and user instructions that might affect the purchase decision can be provided on the product or on a sticker attached to the product, for example.

Does the electrical appliance need to contain user instructions in paper form?

The legislation requires that electrical products must be accompanied with the necessary safety information and instructions for operating it safely and as intended. Not all instructions need to be provided in paper form. Instead, they can also be provided in an online or other data storage format. However, the paper version should be available free of charge at all times upon request of consumers. For more information, see the Instructions section.