Guide to
Regulation of Electrical Products

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Introduction

The National Regulator for Compulsory Specifications (NRCS) came about in May 2008 with the introduction of the NRCS Act of 2008.
At its inception in 1965, the Regulator was part of the South African Bureau of Standards (SABS) and shared all the skills and expertise that the Bureau had at its disposal. Many aspects of this compulsory regulatory function have changed since 2008, when the NRCS was effectively ‘stripped away’ from the SABS.

The SABS was then reconstituted as a commercial undertaking with limited funding from Government while the NRCS, on the other hand, became a ‘non-profit’ Government agency reporting to the DTI, and separate from the SABS.

The following are some of the more visible consequences, as seen from the point of view of clients of these institutions:

out

Regular interaction with industry and relatively easy access to the Regulator.
The Authorisation Committee process.
Regular inspections at outlets for non-compliant products.
‘In-house’ testing of products.

in

A LOA (Letter of Authority) system with long lead times and more restricted access to the NRCS.
Web-based applications for approvals.
Rejection of the SABS mark as a qualification for compliance with regulations.
Focus on the ports of entry of goods (and an implication that locally-produced products deserve no – or much less – policing).

Roles of SABS and NRCS

SABS

Provide a product certification scheme – such as the SABS mark scheme
Provide ISO listing and auditing facilities
Manage the Standards Division and produce national standards
Sell national and international standards
Report to the DTIC via the SABS Board
Provide and manage laboratory facilities for Electrical and Electronic products and appliances

NRCS

Manage the National Compulsory Safety and Minimum Energy Regulations
Collect levies for regulated products
Conduct market surveillance through inspections and may arrange for analysis and testing by conformity assessment laboratories as required
Adopt national standards as compulsory specifications or develop own compulsory specifications
Process and issue Letters of Authority (LOAs) and Sales Permits
Report by the National Regulator to the Minister DTIC *
* NRCS specifications include reference to standards and administrative requirements
* NRCS Board was dissolved on 19 May 2014

Products that are regulated in terms of compulsory specifications

The NRCS has an informative, although not well-known website which, amongst other useful information (dealt with in this guide), lists and publishes Compulsory Specifications under the VC series of documents. A visit to the NRCS Website is recommended: www.nrcs.org.za. Follow the ‘Electrotechnical’ selections.

The table below contains a consolidated list of products that are regulated in terms of the Compulsory Specifications. The list has been updated to the latest issued amendments as at October 2023 with the applicable standards referred to in the VC documents.

These specifications are available on the NRCS website and can be downloaded at no charge. Each specification covers the procedural and technical requirements, such as the applicable standard. Affected entities are urged to read these carefully and to purchase the referenced product standard(s) in order that the correct test report is obtained from an accredited test laboratory.

Certification systems

The Conformité Européenne or CE mark is generally a ‘self certification’ mark, which was introduced in Europe to serve as a common certification within the European Economic Area.
Download the guide for a comprehensive table on the different elements of product certification systems.
Download Guide

CE Certification Process

Products are listed in EU directives/regulations and these cover the specific requirements of the CE certification process together with the specific duties and responsibilities of manufacturers and distributors of products.

The CE certification process is based on standard ISO/IEC 17050 – Parts 1 and 2 “Supplier’s Declaration of Conformity”. This standard has also been adopted as a South African National Standard – SANS 17050.
Correct CE Mark
Correct CE mark
Examples of fake CE marks
Fake CE Marks
Elements of Product Certification Systems
Product certification system types
1a
1b
2
3
4
5
6
Selection or sampling as applicable
Determination as applicable by: Testing: (ISO/IEC 17025) Inspection, design appraisal or assessment of service: (ISO/IEC 17020)
Review or evaluation
Decision on certification, which includes granting, maintaining, suspending and withdrawing
Licensing or attestation
Surveillance:
a) Testing or inspection of samples from the open market
b) Testing or inspection of samples from the factory
c) Quality system audits combined with random tests or inspections
d) Assessment of the production process or service
Safehouse CE testing
The system is regulated by a process of market surveillance – which works very well in Europe, together with the various EU consumer protection laws and by EU Harmonised Standards, which are vigorously applied by the EU community.

The misuse of the CE mark is well known in the EU and elsewhere, notably by unscrupulous manufacturers who, by adding the CE mark to electrical products without justification, deliberate intent to dupe unsuspecting users. To give the CE mark credibility the self-regulation concept (ISO/IEC 17050) is implemented under EU regulatory supervision. EU Regulators apply extreme penalties for false Declaration of Conformity and publicly notify member countries of false declarations.

It should be noted that, as it is a self-certification scheme, even genuine CE-marked products have not necessarily been tested by an independent 3rd party as the scheme also accepts in-house testing. The self-certification concept under regulatory supervision, has the advantage that manufacturers take full responsibility for compliance and sign a Declaration of Conformity for all products covered. This declaration is legally binding. Under a regulatory model that supports ISO/IEC 17050, legal action can be taken against false declarations and public disclosure can be issued to alert consumers against non-compliant or unsafe products.
Due to the incapacity and flaws in the NRCS regulatory model, various shortcomings have been identified that significantly hamper the effectiveness of the regulator. Due to rapid decline in access to local test facilities, the lack of market surveillance testing due to a “no-test policy” of the NRCS, only superficial inspections are conducted. The imbalance between key elements of the regulatory model, Monitor, Verify and Enforce (MVE) have allowed a proliferation of non-compliant products available on the South African market.

Excessive delays in LOA processing, non-response to registered non-compliant product, and the inability to detect non-compliance of electrical products through inspection only have resulted in an untenable situation. On-line sales of regulated products are aggravating the situation and create an unfair trading environment for compliant manufacturers and suppliers, placing consumers at risk.

It is important to note that Type 5 product certification in accordance with ISO/IEC 17067 is again being introduced in some of the NRCS’s compulsory specifications. The SABS mark scheme and even the Suppliers Declaration of Conformity (SDoC – SANS 17050) concept, if applied under regulatory supervision both promote regular manufacturer testing and enhance continued product compliance.
The SABS certification mark is an example of a Type 5 certification scheme as defined in ISO/IEC 17067 and includes conformity assessments such as manufacturer and 3rd party testing of factory or open market samples as well as auditing of the manufacturers quality management system.

Governing Legislation
For Electrical Products and Installations

The sale and installation of electrical products are governed in South Africa by the following:
National Regulator for Compulsory Specifications Act No. 5 as amended 2014:
  • Refers to product standards and administrative requirements in VC documents relating to electrical products.
  • Is managed by the NRCS (National Regulator for Compulsory Specifications), reporting to the Department of Trade and Industry.
  • Covers the sale of products.
  • Applies to electrical products, including those for fixed installations such as sockets, as well as plugs, adaptors and cord extension sets.
  • Sets out the process for LOA and SP approvals.

    THE OCCUPATIONAL HEALTH AND SAFETY ACT NO 85 OF 1993:
  • Refers to the Electrical Installation Regulations of 2009 and the Code of Practice for Wiring of Premises SANS 10142-1.
  • Is managed by the Department of Labour and Employment.
  • Covers the use of products in electrical installations, generally applicable to products for fixed installations such as socket outlets, wall switches, stove isolators and circuit breakers.
  • Prescribes the Wiring Code (SANS 10142-1) for the wiring of fixed installations in the work environment.

    THE CONSUMER PROTECTION ACT NO. 68 OF 2008 (CPA):
  • This deals with consumer products and states, under Section 55 (d) regarding consumers’ rights to safe, good quality goods “… every consumer has the right to receive goods that … comply with any applicable standards set under the Standards Act, 1993 (Act No. 29 of 1993), or any other public regulation”.
THE ELECTRICAL INSTALLATION REGULATIONS: GOVERNMENT NOTICE R242 MARCH 2009:
These regulations are in the custody of the Department of Labour and Employment.
  • Sets out the regulations applicable to domestic, commercial and industrial installations. All the components used therein must comply with the Code of Practice for Wiring of Premises, SANS 10142-1, which also covers the installation approval process for the issuing of Certificates of Compliance (CoCs) for new and existing installations. Incidentally, a CoC is required for the sale and registering of properties.
  • This regulation also sets out the Registration of Electrical Contractors. This registration was, for many years, in the hands of the Electrical Contractors’ Board (ECB), which no longer exists in its original form. Consequently, some of the previous control functions are now significantly reduced.
  • This regulation also includes the Notice of Commencement of Installation Work provision, whereby all electrical installations are registered at Department of Labour with particulars such as location, type of installation and the identity of the registered contractor
  • It also has provisions for the appointment of Approved Inspection Authorities (AIAs) whose tasks are not unlike the original municipal ‘electrical inspectors’ but more complex now in terms of their function and duties under the Department of Labour.

    INDEPENDENT COMMUNICATIONS AUTHORITY OF SOUTH AFRICA (ICASA):
  • Electromagnetic interference (EMI) and electromagnetic compatibility (EMC) are applicable to a number of electrical products such as certain lighting products and electronic switches, dimmers and sensors.
  • Such products require compliance with certain standards in respect of electromagnetic emissions and compatibility which, if left without any control and suppression, could interfere with specific broadcasting and essential signalling systems, such as in air traffic control, security communication systems and pacemakers in healthcare applications.
  • These standards are in accordance with international standards under the CISPR series of documents and broadly within the jurisdiction of ICASA.
Download the guide for a comprehensive table on the different products and their VC Specs, issues, standards, and LOA status.
Download Guide
VC SPEC.
ISSUE
PRODUCT
STANDARDS
LOA
VC 8003
6 Feb 2015
Manually operated switches for fixed installations including:
  • Switches having facilities for the outlet and retention of flexible cables
  • Combinations of switches and other functions (with the exception of switches combined with fuses)
  • Switches that incorporate pilot lights
SANS 60669-1
LOA
  • Electronic switches including dimmers
  • Electronic remote control switches
SANS 60669-2-1
LOA
  • Electromagnetic remote control switches
SANS 60669-2-2
LOA
  • Switches incorporating a time-delay device
SANS 60669-2-3
LOA
  • Switches and related accessories for use in home and building electronic systems (HBES)
SANS 60669-2-5
LOA
VC 8006
19 Nov 2010
Flexible cords for electrical appliances
SANS 1574 SANS 60227-5
LOA
VC 8008
19 Nov 2010
Plugs, socket outlets and socket outlet adaptors
SANS 164-0 SANS 164-1 to -6
LOA
VC 8011
2 Jul 1999
Lamp holders:
  • Edison screw type
  • Bayonet type
SANS 60238 SANS 61184
LOA
VC 8012
19 Nov 2010
Appliance couplers
SANS 60320-1
LOA
VC 8029
3 Feb 2012
Cord sets, interconnection cord sets and cord extension sets
SANS 60884-2-7 SANS 164-0 SANS 1661
LOA
VC 8035
16 Oct 1987
Earth leakage protection units
Complete VC8035 standard
LOA
VC 8036
23 Oct 2015
Circuit breakers
SANS 556-1 SANS 60947-1 SANS 60947-2
LOA
VC 8039
14 Jul 1989
Starters for tubular fluorescent lamps
Complete VC8039 standard
LOA
VC 8043
Withdrawn w.e.f. 24 May 2024
Incandescent lamps Tungsten filament lamps
SANS 60432-1 SANS 60064
LOA
VC 8052
15 May 1998
Manually operated switches for appliances
SANS 61058-1
LOA
VC 8055
6 Feb 2009 & 31 Oct 2014
Electrical and electronic apparatus Household electrical appliances
SANS 60335-1 SANS 60335-2
LOA
Audio, video and similar electronic apparatus
SANS 60065
Luminaires (including LED light sources – amendment)
  • Power factor requirements
  • Emergency lighting
  • Electrical supply track luminaires
SANS 60598 -1 SANS 60598-2 SANS 475 SANS 1464-22 SANS 60670
LOA
Handheld motor or magnetically operated electrical tools
SANS 60598 -1 SANS 60598-2 SANS 475 SANS 1464-22 SANS 60670
LOA
Transportable motor operated electric tools
SANS 61029-1 SANS 61029-2

LOA

Electrical equipment for test, measurement and laboratory use
SANS 61010-1 SANS 61010-2
LOA
VC 8075
15 Aug 2003
Multicore electric cables – for fixed installations 300/500 V to 1 900/3 300 V
SANS 1507
LOA
VC 8077
15 Aug 2003
Medium voltage electric cables 3.3 kV to 33 kV
SANS 97 SANS 1339
LOA
VC 8079
10 Oct 2003
Gaming devices and related apparatus
SANS 1718
LOA
VC 9006
16 May 2014
Hot water storage tanks
SANS 151 (part)
LOA
VC 9008
28 Nov 2014
Energy efficiency and labelling of electrical and electronic apparatus, Air conditioners; audio and video equipment; large electric ovens; small and medium electric ovens; refrigerators; freezers; dishwashers; washing machines; washer dryer combinations; tumble dryers
SANS 941
LOA
VC 9087
6 Feb 2009
Lamp controlgear
SANS 61347-1 SANS 61347-2
LOA
VC 9091
Withdrawn w.e.f. 24 May 2024
Compact fluorescent lamps
SANS 61199 SANS 60968 SANS 60901 SANS 60969
LOA
VC 9105
Published for comment
Compulsory specification for electric motoroperated hand-held tools, transportable tools and lawn and garden machinery (vc 9105)
SANS 60745-1 SANS 60745-2
LOA
VC9109
24 May 2023 Effective date 24 May 2024
Compulsory specification for energy efficiency and functional performance requirements of general service lamps (GSLs)

*Please note: Due to the minimum efficiency requirement of general service lamps of 90 lumen/Watt the use of incandescent lamps and compact fluorescent lamps has physically been phased out and reference to standards for these lamp types is misleading.
IEC/SANS 60064 CIE 84 / IEC 60357 IEC/SANS 60969 IEC/SANS 62612 CIE S025 IEC 63103 CIE 13.3 CIE S015 IEC/SANS TR 61547-1 IEC/SANS TR 63158 CISPR 15 or SANS 215 IEC 61000-3-2
LOA
VC9110

24 May 2023 Effective date 24 May 2024

3 Effective date 24 May 2024 Compulsory specification for safety requirements of general service lamps (GSLs)

*Please note: Due to the minimum efficiency requirement of general service lamps of 90 lumen/Watt the use of incandescent lamps and compact fluorescent lamps has physically been phased out and reference to standards for these lamp types is misleading.
SANS 60432-1 SANS 60432-2 SANS 60432-3 SANS 61199 SANS 60968 SANS 62560 SANS 62838
LOA

LOA and SP applications

All applications for NRCS approvals are made online and require the following steps:
The LOA administration procedure, downloaded from the NRCS website, explains the registration process and first time applicants are required to complete the form under Annexure 2. This application must be submitted by fax or email under a covering letter where a ‘username’ is proposed for the responsible person acting on behalf of the applying entity.
After about three days, the account is activated, online applications are available to the newly registered client, and a password is issued online. To make this easier, it is recommended that this is done at the NRCS in Pretoria, in the recently established client centre
By selecting the appropriate tab, the product is registered. One should include every possible version of the product in terms of ‘model numbers’ and descriptions. Failing this, subsequent variants of the product will necessitate additional approval applications.
As a general guide, all listed products require an LOA. There are, however, some exceptions (see table on previous page).
Where there are products that deviate from one or more standards, it would be necessary to apply for a SP. This may or may not be granted at the discretion of the NRCS, depending on the seriousness of the non-compliance.

The type of service request (SR) is selected on the applicable tab and the following documents are uploaded:
  • Completed application form Annexure 1 of the LOA procedure.
  • Test report(s).
  • Proof of payment of application fees
Until April 2016 the LOA process time was stated as 120 working days. At an information forum in April 2016 the NRCS announced that this would change to 120 calendar days. The actual experience of many organisations is that it could take longer.

One way to reduce the risk of lengthy delays is to understand the process and to ensure that all requirements to support the application are properly completed and submitted.

Amongst other measures, the current NRCS strategy is to concentrate its limited resources on the ports of entry, so containers will be held up by the Department of Customs if there is no LOA or other approval included with import documents.

Another aspect of the NRCS strategy is to profile suppliers into risk categories in terms of their knowledge of the regulations and their record of adherence to them. Understanding the regulations and building up a record of compliance would thus be helpful.

The fact that current NRCS resources are limited along with a move to more electronic automation of the approval process, makes personal intervention in the process much more difficult, if not impossible.

There is currently much lobbying to reduce the application processing time but it is recommended that ample time be allowed for the approval process.

Test Report requirements by NRCS

  • Product families: In certain products, characteristics may be grouped together and tested as a ‘family’ provided that the structure and design is consistent across the group. For example, miniature circuit breakers (MCBs) may, under the same design and characteristics, have several nominal current ratings (6, 10, 16, 20, 25, 32, 40, 50 and 63 A). The test report may encompass all these ratings.

    The applicant must ensure that the test report reflects all the ‘type numbers’ for each of these ratings, which may then be transferred to the LOA application. Check that the issued LOA reflects all the types listed.
Without exception, the approval process requires a full test report to the referenced standard for the regulated product and there are some specific clauses covering this aspect, these are:
  • Accredited laboratories: The laboratory must be appropriately accredited and internationally recognised by an accreditation body, which is a member of the IAF/ILAC/ IECEE mutual recognition scheme.
  • Test reports: A full test report, in the IEC format, is usually about a 30 page document covering every clause of the standard and, in some cases, covering more than one standard. For example, cord extension sets are covered under VC 8029, SANS 60884-2-7, SANS 1661 and SANS 164-0. It also requires photographs of the product.
    • On first application, the test report may not be older than three years.
    • On renewal of the LOA, the test report may not be older than five years.
     
Accreditation Logos
  • International Laboratory Accreditation Cooperation.
  • International Accreditation Forum.
  • International Electrotechnical Commission –
  • Electrical Equipment Conformity Accreditation.

‘Cheap’ Electrical Products

Electrical products are required to meet strict safety standards for the simple reason that, without extensive safety precautions, they may injure or kill users. Assets, such as buildings and other possessions, are also at risk but the purpose of the regulations is to protect users.

These precautions are embodied in the various clauses of Technical Standards and conforming to these standards often requires specialised materials: specially selected metals and metal coatings; strict manufacturing processes including testing; and ongoing proof of conformance. All in all, these measures add to the cost, even for a relatively simple product, such as a plug, for example.

Significant differences between prices of products offered should be a warning sign. Low prices might mean compromised quality and reduced safety and this has often proved to be the case. The location where the products are sold, combined with low prices may also be a warning of possible sub-standard quality.

What can end-users do?

  • Buy known and trusted brands.

  • Buy from reputable suppliers and outlets. Beware of copies of prominent brands.

  • Be suspicious of prices substantially lower than other, similar products or services on offer.

  • Try to make contact with the seller’s supplier and judge responses critically.

  • Be suspicious of lack of information on or with the product packaging and on the product itself. Specifications require certain minimum markings and packaging should describe the electrical capacities and the correct application of the product. Look out for contradictions between data provided, for example, different voltage ratings for the same product. If the purchase is substantial enough, ask the supplier for references to other users and contact them.

  • When dealing with an electrical contractor, ask about membership of the ECA(SA) (Electrical Contractors’ Association of South Africa) and/or call the ECA(SA) in your region to check credentials.

  • Be wary of suspect installations or of Certificates of Compliance (CoCs) that are issued too easily.

  • Ask the supplier to prove compliance with regulations and NRCS approval.

  • Look for certification marks such as SABS, VDE and UL. Beware of fraudulent use of well-known marks, such as the SABS mark.

  • A CE mark in its own is not proof of conformity or of independent testing – be careful.

  • Report any electrical product failure to the dealer, manufacturer, the NRCS and, if applicable, the National Consumer Commission.

  • If in doubt, check with the SAFEhouse Association for possible information it may have to help you

About Safehouse

Safehouse is a non-profit organisation that protects South African businesses and people from preventable harm caused by unsafe electrical products and services.

We’re a voluntary group of electrical industry stalwarts, technical experts and leaders of our respective businesses and fields.We believe it’s our civic and commercial duty to protect our industry and fellow South Africans from suppliers of unsafe electrical products and services.

We work to eradicate dangerous products from the market, to make electrical safety information understandable and accessible and to hold one another, and our industry, to the highest standards of excellence.

Safehouse members have signed a code of conduct that commits them to dealing only in safe electrical products and to responsible behaviour.

If you have doubts about a particular product or service, contact Safehouse for guidance info@safehousesa.co.za.
Also brought sharply into focus were the following:

  • NRCS specifications and regulatory approvals –such as the Letter of Authority (LOA) became compulsory, and

  • SABS certification, such as the long-standing and ubiquitous SABS mark, became entirely voluntary.

    The changes caused some confusion in the market as many entities were, and still are, under the impression – due to years of SABS visibility – that they are protected by the SABS mark of approval. On the other hand, the different (and lesser known) profile of the NRCS is one of policing, funded by fees levied on suppliers.

    The NRCS has the mandate to impound, confiscate and destroy non-compliant regulated products, and regularly demonstrates where they are destroyed.
Guide to Electrical Products