2021 was a busy year for laser product safety standards. Two new European Standards (EN) were issued, adding new laser product requirements to what manufacturers currently expect from existing standards. Manufacturers will need to familiarize themselves with these new requirements as key dates for implementation approach. This article will provide some guidance and explanation on the new requirements and dates.
EN 60825-1:2014/A11:2021 – Safety of Laser Products – Part 1: Equipment Classification and Requirements
The EN 60825-1 laser product safety standard has historically not differed from the base IEC 60825-1 laser product safety standard. Therefore, compliance with IEC 60825-1 could help cover any EN 60825-1 requirements. However, with Amendment 11 (A11) of EN 60825-1 issued in February 2021, additional requirements have been introduced that are not in IEC 60825-1. (Note: Amendment 11 is a reserved Amendment number that applies to the EN version of a standard but not the IEC version.) As a result, laser product manufacturers will need to make sure they meet those additional EN requirements to confirm compliance with both IEC 60825-1 and the latest EN 60825-1. The additional requirements to consider for EN 60825-1:2014/A11:2021 include:
- Compliance with the new EN 50689 standard for consumer laser products (refer to requirements for EN 50689 below).
- New testing and classification considerations for 1250-1400 nm wavelengths.
- More specific emphasis on protective housings preventing human access to radiation in excess of the accessible emission limit (AEL) for Class 1.
- Inclusion of the IEC 60825-1:2014 interpretation sheets in an annex.
In December 2021, the amendment EN 60825-1:2014/A11:2021 was listed as a harmonized standard under the Low Voltage Directive (LVD) in the Official Journal (OJ) of the European Union. The date of withdrawal of EN 60825-1:2014 without A11 in the OJ is June 21, 2023. Therefore, laser product manufacturers should consider June 21, 2023, as the date by which EN compliance relies on the new EN 60825-1:2014/A11:2021 requirements to grant presumption of conformity with the essential requirements to the LVD.
EN 50689:2021 – Safety of Laser Products – Particular Requirements for Consumer Laser Products
A second EN laser product safety standard issued in November 2021 is EN 50689, a brand-new standard that provides additional requirements for laser products defined as consumer laser products. Based on the definitions in EN 50689, a consumer laser product is defined as one intended for consumers or that is likely to be used by consumers under reasonably foreseeable conditions, even when it may not be intended for them. Therefore, manufacturers of laser products that meet this definition shall also consider EN 50689 in addition to IEC/EN 60825-1.
Examples of consumer laser products that could fall into the scope of EN 50689 include laser printers, bar code readers, laser projectors, smart phones, laser pointers, laser levels, robot vacuums and lidar.
Note: There is no corresponding IEC standard for EN 50689, so these requirements apply to EN compliance only.
Additional requirements contained in EN 50689 for consumer laser products include:
- Compliance with the new EN 60825-1:2014/A11:2021 (see above for more information on this standard).
- Defining consumer laser products along with classification restrictions on such products.
- Defining child-appealing consumer laser products along with classification restrictions on such products.
- Additional testing and classification considerations for consumer laser products.
- Limitations on laser pointers.
- Additional requirements for Class 3R consumer laser products, including requirements for deliberate actions prior to laser activation, emission indicators, limitations on wavelength and peak power, and the use of the simplified (default) method for classification, i.e., C6 = 1.
- Requirements for labeling and user information content.
In May 2022, EN 50689:2021 was listed as a harmonized standard under the LVD in the OJ of the European Union, and it can be used to provide presumption of conformity with the essential requirements of the LVD. Since EN 50689 is a new standard, there is no transition period from a previous version to the new version. To comply with the LVD, manufacturers can choose whether to apply this harmonized standard or parts thereof. However, if manufacturers choose not to apply the EN 50689 harmonized standard, they need to demonstrate that the products conform with essential requirements by using other means of their choice, e.g., using any existing technical specifications, including all other available standards. Harmonized standards are not mandatory, but they can simplify the process to meet the essential requirements set by the directives and regulations. For this reason, when EU harmonized standards exist, manufacturers often use them.
Furthermore, EN 50689 may be used to confirm compliance with the general safety requirement set out in the General Product Safety Directive (GPSD), which applies to consumer products when there are no specific provisions about the safety of the products in the rules of EU Law.
As a result, manufacturers should consider complying with EN 50689 to help eliminate any potential questions about compliance with applicable requirements. Manufacturers should also keep in mind that EN 60825-1:2014/A11:2021 requires the use of EN 50689, and EN 60825-1 with A11 is required as of June 21, 2023. Hence, manufacturers can infer that they will need to comply with EN 50689 by June 21, 2023.
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