TÜV Rheinland Blog

Questions About the Duty of Notification of SVHC in Articles/Sub-Assemblies?

Posted by TUV Rheinland on Fri, Oct 02, 2015 @ 09:00 AM
The interpretation of Article 7 Clause 2 and Article 33 of REACH regulation Nr 1907/2006 lead to a conflict between the ECHA and some of the EU member states. In February of this year we informed you about a preliminary decision of the Court that would bring this conflict to an end. In order to understand this decision, we have put together a Q&A to help with understanding the impact of the decision. Click here to read the decisions: Preliminary and Final.

What is the effect on the assessment of the articles?

According to REACH and CLP a product is an object which during production is given a special shape, surface or design which determines its function to a greater degree than does its chemical composition. An article often is not a homogenous material, in most cases it is already a combination of different materials. An article still is an article even when it is used together with other articles to be assemble to a final product. The German BAuA used the short definition "Once an article, always an article". These interpretations are illustrated in the guidelines issued in 2011 and 2013, please refer to the following links: 



Guideline published in the name of the following member states:

  • Belgian Federal Public Service, Health, Food Chain Safety and Environment
  • German Federal Institute for Occupational Safety and Health
  • Danish Environmental Protection Agency
  • French Ministry of Ecology, Sustainable Development and Energy
  • Norwegian Environment Agency, Swedish Chemicals Agency

What is the effect of the judgment on selected articles?

The guidelines mentions above list several examples, like bicycle, couch, shirt, electric cable, computer parts, computer and a coated fry pan If articles (frame of bicycle, saddle, handle bar, bell) are assembled to one complex article all the sub-assemblies still are considered to be articles themselves. During production of a printed textile the color (if liquid) is a mixture before being printed on the shirt. The printed shirt is an article, the color is not. The color becomes part of the article after it has been printed on the shirt.

For more explanation and additional details please refer to the page 20-29 of the guidance document:http://mst.dk/media/mst/9106895/guidance_for_suppliers_of_articles_en.pdf 

What will be the impact on the REACH regulations?

In the REACH regulation it is stipulated that there is a duty of notification when the concentration in the article exceeds 0,1% by weight. In RIP 3.8 a detailed explanation of what is considered to be an article can be found and how to deal with more complex articles, which consists of more than 1 subassemblies. The judgment of the Court therefore is not an update or amendment of the REACH regulation, it only requires an update of the guideline RIP 3.8. The calculation of the content of SVHC now follows the assessment of other regulations. The approach stipulated in RIP 3.8 that the limit is calculated by the weight of the final article and not by the weight of subassemblies or homogenous material was unique. Other regulation like Annex XVII of REACH or RoHS limit the concentration per homogenous material. 

Will there be any impact on how products need to be tested on SVHC?

Since REACH took effect testing on SVHC became a regular test for the big majority of clients. During testing different materials are mixed to one test group and screened on their content of SVHC where on inconclusive results the materials will be tested again separately. After the new judgment the assessment of the results changes. In the past the result was calculated by weight of the complete article, from now on it will be calculated on the subassembly or the material that is considered to be an article itself. If during screening no SVHC are detected – which reflects the typical test result – then the assessment of the article does not change. Materials of subassemblies could have been excluded from testing in the past due to their low weight compared to the weight of the overall article. These now need to be tested as well.


Topics: RoHS/REACH, Green Services

Is Your Workplace Safe from Electrical Fire and Shock Hazards?

Posted by TUV Rheinland on Thu, Oct 01, 2015 @ 10:03 AM

TÜV Rheinland's FES Blogs are authored by Greg Smith.

Electronics and electrical equipment are everywhere these days, both at home and in the workplace. At home most of our consumer products have been tested and certified, mainly because major stores will usually not buy or sell non-certified products. 

Our workplaces are a different story! It is not illegal in North America to import or purchase non-certified equipment, but it is a violation of Federal Law (OSHA / DOL) for the workplace. Please see our Reference Tab on our Field Evaluation Services Page for helpful links and resources.

Would you be able to identify this potentially hazardous equipment? Many people are familiar with the Marks from testing labs accredited for North America such as TÜV Rheinland, UL, CSA, ETL. These Certification Marks are easy to verify with the testing Labs on their websites. Certification marks are usually on or near the electrical nameplate of the equipment.

What about the “CE marking”? CE is legal in Europe, but even the EU is seeing some problems with this because actual inspection, evaluation and testing are not monitored or verified. “CE” marked products are now manufactured in many countries across the globe. In the testing laboratory business, we see these “CE” products every day. Some of them have no evidence of evaluation or testing, and some of the documents even have the incorrect product standards. If someone is representing a “CE” product as certified for North America, you can’t simply ask them for proof on the “CE” website. It does not exist.

Testing laboratory field evaluation inspections show that non-certified electrical equipment can have multiple risks, including: failure and burning of incorrectly protected components and motors, risk of shock and electrocution to operators, risk of explosion, and fire from equipment not suited for the environment. In most cases, these risks can be corrected.

If there is an electrical shock or fire incident in a US workplace, OSHA will check the certification status of the equipment, and if it is non-certified or only has a “CE” mark, the owner of the equipment will be held liable. Injured parties will also have a firm basis for successful lawsuits, since noncertified electrical equipment in the workplace is a violation of federal law. Facility owners, equipment owners, sellers and manufacturers could potentially be involved. Each piece of equipment without the proper NRTL certification could be a ticking time bomb and an unnecessary risk.

Protecting our workplaces from these potentially hazardous products is not difficult. The best way is to make sure these products are not purchased. In cases where this is unavoidable, as in custom or special equipment, Field Evaluation and Labeling can be a practical option. If this is the only option, be sure to check with your product safety experts to see if this equipment has ever been field labeled.

For more information, Email TUV Rheinland or call 1-888-743-4652


Latest Edition! FES Newsletter


  About Greg Smith

Greg Smith is a Senior Field Evaluation Inspector for TÜV Rheinland. A veteran of the TIC (testing, inspection & certification) industry, Smith brings more than 23 years of leadership experience in testing laboratories and field evaluations to TÜV Rheinland. Greg has been involved in the International Association of Electrical Inspectors (IAEI), from committee work to state and regional committee chairman, with his distinction of being the first non-government IAEI Inspector Member to be President of the North Carolina Chapter (2011-2012). He has also been a long time Board of Director Member for the NC Association of Electrical Association (NCAEC) and an active member of the Carolinas Electrical Contractor Association (CECA).

Topics: Field Evaluation Services

RoHS/REACH Questions Answered by TÜV Rheinland Experts, Part 2!

Posted by TUV Rheinland on Wed, Sep 30, 2015 @ 11:32 AM

Q&A with TUV Rheinland's Green Experts Part 2

Our popular green webinar Series, "Ask The Experts", featured Geoffrey Bock and Scott Sagamang. In case you missed it, the webinar can be viewed on demand here

After the conclusion of the webinar, we received many questions which Scott and Geoff will answer below.

Please find the next question in the series!


What is expected for RoHS and REACH compliance for AIMD products in 2019 and beyond?

There are very few things exempt from the RoHS directive, and almost nothing is exempt from REACH, save natural resources, cosmetics and some other instances. However, AIMD products (Active Implantable Medical Devices), including programmers, continue to be exempt from RoHS. 

Programmers used for the AIMD do not fall under the scope of ROHS2 as supported by the directive and the medical device sector CE marks and practices. An AIMD means any active medical device which is intended to be totally or partially introduced, surgically or medically, into the human body, or by medical intervention into a natural orifice in which it is intended to remain after the procedure. 

A programmer is a device for communicating with an actively implantable device, and consequently the level of risk associated with a programmer is similar to that for the AIMD because a malfunction in the programmer may lead to a malfunction in the device. Therefore both the device and the programmers remain exempt and there is no word on the market or in the EU of any inclusion of AIMDs in the near future. 


Latest Edition! GREEN Newsletter







Topics: RoHS/REACH, Green Services

RoHS/REACH Questions Answered by TÜV Rheinland Experts, Part 1!

Posted by TUV Rheinland on Wed, Sep 23, 2015 @ 11:03 AM

Q&A with TUV Rheinland's Green Experts Part 1

Our popular green webinar Series, "Ask The Experts", featured Geoffrey Bock and Scott Sagamang. In case you missed it, the webinar can be viewed on demand here

After the conclusion of the webinar, we received many questions. Over the next few weeks, Scott and Geoff will provide some expert answers. 

Below, please find the first question in the series!


What are documentation and process requirements for internal testing program of samples using XRF?

Buying a hand-held or benchtop XRay Fluorescent Spectrometer? Don’t forget, you are subject to IEC 62321, which is widely recognized around the world for RoHS. IEC 62321 will let you know what a homogeneous material is, how to get to a homogeneous material, and what methods can be used to test. It will also give you discrepancies—for example: If there’s a high tin content in an alloy, it might give you a false pretense of Cadmium in the sample. Another example would be for flame retardants. The test might come up hot for Bromine, but you won’t know if it’s the banned bromines or not. It will ID PVCs, or detect that there are some banned phthalates in there. As a screening tool, it’s very effective. 

To make sure your internal program is successful, you’ll need to remember a few things:

  • Make sure your documentation is always correct
  • Make sure calibrations are correct
  • Make sure the people using the equipment are knowledgeable and have been trained in how to use and how to foresee if something is going to be in non-compliance or not.

Read TÜV Rheinland's Green Newsletter and Stay up-to-date with all things Green!


Latest Edition! GREEN Newsletter







Topics: RoHS/REACH, Green Services

GCC Technical Regulation for Low Voltage Electrical Equipment and Appliances

Posted by TUV Rheinland on Mon, Sep 21, 2015 @ 11:00 AM

The GCC ( Gulf Cooperation Council) is a cooperation council for Arab states of the gulf consisting of six countries in the Arabian Gulf region. The countries consists of:

  • Kingdom of Bahrain
  • State of Kuwait
  • Sultanate of Oman
  • State of Qatar
  • Kingdom of Saudi Arabia
  • State of United Arab Emirates

Yemen is in negotiations for GCC membership with targeted date to join by 2016. 

The new GCC Technical Regulation Low Voltage Electrical Equipment and Appliances will be enforced in the 1st of June 2015 in an experimental way while the full enforcement will be in the 1st of July 2016.

Under this regulation, after July 1st 2016 – product in scope, which are: electrical product,  this means all electrical and electronic devices and appliances and fixtures that contain electrical and/or electronic components designed for use with a voltage rating of between 50 and 1000V for alternating current and between 75 and 1500 V for direct current must have G marking. The requirement for G Mark follows CB reports, however the reports should include national differences which is voltage and frequency of each member state, as well as type of shape of plugs and socket outlets used in each member states.

TUV Rheinland HK is one of the firsts in Asia to be accredited notified Body for Low Voltage Electrical Equipment and Appliances.

Learn More!

For more information on G Mark, please call 1-888-743-4652 or email us at info@us.tuv.com  



Topics: International Approvals

TÜV Rheinland Launches Field Evaluation Services Newsletter!

Posted by TUV Rheinland on Thu, Sep 10, 2015 @ 11:35 AM


TÜV Rheinland has lauched a new Field Evaluations Services Newsletter. Greg Smith, one of our FES experts, will be supplying relevant industry news like product recall information, and industry resources. In addition to Greg's expertise, other TÜV Rheinland industry experts will contribute to ensure that we are providing interesting, relevant and timely information!

 The first edition contains information on:

  • Top Product Safety Recalls
  • Robotics and Automation 
  • NFPA70E Compliance Training
  • Resources on regulations for non-certified electrical equioment
  • Cutting Edge Technology News

To read the latest issue of the Field Evaluation Services (FES) Newsletter, please click here.

Topics: Field Evaluation Services

RoHS2 Updates: Changes coming to RoHS2 (2011/65/EU)

Posted by Jen Picardo on Mon, Jun 15, 2015 @ 10:00 AM
The day is coming when the infamous 6 restricted substances will be increased.  Annex II will have 4 phthalates added in the near future per the draft proposal.  Pack 8 exemption evaluations also began on March 13, 2015.


The draft proposal for the addition of 4 phthalates has been published by the European Commission:

  • DEHP
  • BBP
  • DBP
  • DIBP

The restriction limit for the above mentioned phthalates will be 0.1% for each of the substances.

The evidence regarding the use of the 4 phthalates has found that when used with EEE, a negative impact is the result for recycling processes as well as human health and the environment.

As there are currently substitutes for the 4 phthalates which have less of a negative impact, a restriction will be implemented via the 2011/65/EU Directive.

The provisions of the restriction will come into effect on July 22, 2019 for categories 1-7, 10 and 11. For categories 8 & 9, there will be an extended effective date of July 22, 2021 for the following: 

  • medical devices
  • in-vitro medical devices
  • monitoring and control instruments
  • industrial monitoring and control instruments

Pack 8 RoHS evaluations started on March 13, 2015 and will run a period of 9 months.  Pack 8 will cover 3 new exemption requests:

  • Lead in thin film electronic sensor elements such as pyroelectric sensors or piezoelectric sensors
  • Lead in high voltage cables and cable assemblies for a rated voltage higher than 250kV DC, containing up to 4% lead by weight” (for industrial monitoring and control instruments, Annex IV)
  • Lead as activator in the fluorescent powder (1% lead by weight or less) of discharge lamps when used as phototherapy lamps containing phosphors such as BSP (BaSi2O5:Pb) (Annex IV)

The phthalates to be included may be present in your product.  Getting a head start to assess the current content is critical as this new restriction could require a product re-design or re-formulation.   TÜV Rheinland is a service provider that can assist with determining the phthalate content in youproduct and give you a head start on this upcoming restriction. Call 888-743-4652 or email us!


Topics: RoHS/REACH

TÜV Rheinland is in the forefront of wireless technology with regulatory testing and industry driven marks (such as Wi-Fi®, Bluetooth, ZigBee®, and others)

Posted by Hope Mascott on Thu, Jun 04, 2015 @ 04:28 PM

Offers Wide Range of Testing Programs as a Result of Relationships with Major Wireless Industry Alliances


When it comes to testing and certifying wireless products for global markets, it pays to find a provider with expertise across all networks, technologies and standards, both existing and still in development. Along with our government mandated testing (FCC, CE, and others), we can provide the interoperability to wireless technologies in our Pleasanton California location.

With so many safety, acceptance, interoperability, and market development pieces in the compliance puzzle, TÜV Rheinland can help you figure out the best way to get the product to market. The company’s experts sit on committees of standard development organizations and are members of multiple industry groups to keep abreast of the latest in the wireless regulation area. TÜV Rheinland is an active member of the industry alliances listed below and tests a multitude of products for conformance to their certification programs.

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Wi-Fi Alliance®

Today, billions of Wi-Fi® products carry a substantial portion of the world’s data traffic in an increased variety of applications. As one of only two Wi-Fi Alliance® authorized testing laboratories in the US and one of 19 worldwide, TÜV Rheinland North America helps bring Wi-Fi to homes and businesses. Along with other members, TÜV Rheinland is an active participant in the Alliance’s interoperability and spectrum, and regulatory programs and market development efforts.

Recognized worldwide, the Wi-Fi certification program aims to ensure the best user experience. TÜV Rheinland tests any and all Wi-Fi enabled devices to make them eligible for a Wi-Fi CERTIFIED™ seal of approval, which tells the consumer that the product has passed tests for interoperability and industry-standard security protections. 


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ZigBee® Alliance

The Internet of Things is making headway across all areas of our life: Smart Home devices monitor energy use, control heating and cooling and ensure security. Utilities use smart metering and smart grid solutions to manage the delivery and use of water and energy. Retailers keep customers coming back with faster checkouts, in-store support, and in-store item location. Many of these interoperable devices speak the wireless language of ZigBee®, the only open, global wireless standard that provides the foundation for the Internet of Things by enabling everyday devices to connect to one another.

TÜV Rheinland is a member of the ZigBee Alliance and contributes to development of innovative, reliable and easy-to-use ZigBee standards. Experienced engineers and technicians test a wide variety of ZigBee products for use in consumer, commercial and industrial applications.


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Wi-SUN Alliance™

Wi-SUN Alliance™ strives to advance seamless connectivity by promoting the IEEE 802.15.4g™ standard-based interoperability for international regional markets. TÜV Rheinland is an independent authorized test laboratory for Wi-SUN Alliance and evaluates a wide range of consumer, business, and operator-specific products to ensure that they deliver the best user experience and meet the industry standards. Specifically, TÜV Rheinland tests networking infrastructure, smart meter communications devices, consumer electronics and modules to the relevant protocol standards and for interoperability with other Wi-SUN CERTIFIED equipment operating in the same frequency band.

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Open ADR Alliance

According to Open Automated Demand Response (Open ADR) Alliance, successful adoption of ADR requires standardization allowing wholesale electricity producers to communicate with utilities and aggregators, who, in turn, communicate with their customers, who can then decrease demand during peak hours. Without an ADR standard, automated DR would be problematic and expensive to implement. 

OpenADR is an open and standardized way for electricity providers and system operators to communicate DR signals with each other and with their customers using a common language over any existing IP-based communications network. As a member of Open ADR Alliance, TÜV Rheinland is working with standard development organizations, user groups, and other Smart Grid industry stakeholders to develop a conformance, certification, and testing program for OpenADR standard by employing existing standards from OASIS, UCA and NAESB. We will be able to perform Open ADR Testing in our Pleasanton CA location.


Topics: Electrical

Canada Approves SOR/2014-254 Products Containing Mercury Regulation

Posted by Bindu Subramanian on Thu, May 14, 2015 @ 09:45 AM

by Scott Sagamang, Business Development Manager - Environmental Services, TUV Rheinland of North America.

The effective date of this regulation is November 8, 2015

ChemicalsMercury also known as quicksilver is a heavy, silvery-white liquid metal. It is considered a highly toxic element that is found both naturally as well as through manufacturing use or disposal activities. While consumption of fish is considered to be the most significant source of ingestion related to mercury, coal-burning power plants, metal production, waste disposal, chemical production are also known to cause mercury poisoning. Studies and research has found that even minimal exposure to mercury can cause adverse effect to the environment as well as human health.

Several countries and government agencies have issued a ban limiting the use of Mercury. In 2008, the United States, ranked the world’s top exporter of mercury, introduced the Mercury Export Ban Act, implementation of which would remove a significant amount of mercury from the global market. Several other nations including EU and China has followed suit.

The most recent of such a ban comes from Canada. The Governor General of Canada, approved the SOR/2014-254: Products Containing Mercury Regulations under the Canadian Environmental Protection Act. The effective date of this regulation is November 8, 2015.


According to the SOR/2014-254, subject to section 2, these Regulations apply to any product that contains mercury and its compounds. The new regulation also provides a list of products that are exempt from this regulation, as long as they fall within the categories listed:

  • waste
  • a product that is at the end of its useful life and that is intended to be recycled
  • a food, drug, or cosmetic as defined in section 2 of the Food and Drugs Act
  • a veterinary biologic as defined in subsection 2(1) of the Health of Animals Act
  • a surface coating material as defined in subsection 1(1) of the Surface Coating Materials Regulations or a surface coating material applied to a toy regulated under the Toys Regulations
  • a pest control product as defined in subsection 2(1) of the Pest Control Products Act
  • a feed as defined in section 2 of the Feeds Act
  • a fertilizer as defined in section 2 of the Fertilizers Act
  • an explosive regulated under the Explosives Act
  • ammunition and explosives under the direction or control of the Minister of National Defense
  • a product, other than a battery, that has a mercury concentration of 0.1% or less by weight in homogeneous materials
  • a battery, other than a button cell battery, that has a mercury concentration of 0.0005% or less by weight in homogeneous materials
  • beginning on January 1, 2016, a button cell battery that has a mercury concentration of 0.0005% or less by weight in homogeneous materials
  • from January 1, 2016 until December 31, 2019, a button cell battery that is incorporated into a medical device that is intended to remain in the body for at least 30 consecutive days
  • ores, concentrates and by-products of metallurgic operations
  • an on-road vehicle as defined in subsection 1(1) of the On-Road Vehicle and Engine Emission Regulations that is of the 2016 model year or of a previous model year as determined under section 5 of those Regulations.

The regulation prohibits the manufacture or import of any product that contains mercury, unless the product belongs to the list of products specified in Column 1 of the schedule (see above bullets), the amount of mercury contained is within the specified limits, if the product is manufactured or imported before the end date set, or if the person holds a permit issued under subsection 5(1).

Mercury Periodic Table resized 600Labeling Requirements

The regulation also specifies Labeling Requirements. All products containing mercury or its compounds must be listed and should be clearly visible on the product and packaging.

  • The statement “Contains mercury / Contient du mercure”;
  • Safe handling procedures and the measures to be taken in case of accidental breakage, the address of a website where that information is available, or contact information for a person who can provide that information;
  • The options available for the disposal and recycling of the product in accordance with the laws of the jurisdiction where the disposal or recycling is to take place, the address of a website where that information is available, or contact information for a person who can provide that information; and
  • A statement to the effect that the product should be disposed of or recycled in accordance with the applicable laws.

The information must also appear in both official languages, and must be presented in a font size of at least 10 points with character that are at least 3mm in height, legible, indelible and are impressed, embossed or in a color that contrasts the label background or the color of the product. 

If the product is too small, or is not packaged, a notice must be attached to the product or the manual that accompanies the product with the relevant information.

Products containing mercury must ensure that the symbol Hg is indicated in the clearly specified font and size requirements in addition to it being legible and indelible.

Testing Requirements

Any determination of total quantity of mercury made for the purposes of these Regulations must be conducted by a laboratory that is accredited by a Canadian Accrediting body under International Organization for Standardization standard ISO/IEC 17025:2005 or a laboratory that is accredited under the Environment Quality Act, R.S.Q., c. Q-2.

Other significant features of this regulation include:

Any person that manufactures or imports a product that contains mercury other than the ones excluded, must submit a report to the Minister starting 2016 calendar year and every third calendar year after that year, on or before March 31 of the calendar year following the year in respect of which the report is prepared.

The new regulation will go into effect later this year, giving very little time for manufacturers or importers to comply. TUV Rheinland of North America is an ISO/IEC 17025:2005 accredited laboratory that can assist with determining total mercury in your product and developing a compliance path to comply with the requirement.

Contact us today for a quote or for more information!

Call us at 1-888-743-4652 | Email Us | Request Quote

Source: http://gazette.gc.ca/rp-pr/p2/2014/2014-11-19/html/sor-dors254-eng.php

Topics: RoHS/REACH, Green Services

What is an Industrial Control Panel?

Posted by Hope Mascott on Fri, May 01, 2015 @ 02:56 PM

Written by: Ryan Braman

What is an Industrial Control Panel?
According to the National Electric Code (NEC) 409.2, an Industrial Control Panel (ICP) is defined as “an assembly of a systematic and standard arrangement of two or more components such as motor controllers; overload relays; fused disconnect switches; and circuit breakers and related control devices including pushbutton stations, selector switches, timers, switches, and control relays, with associated wiring, terminal blocks, pilot lights and similar components.” 

Regulatory Requirements 
In the United States, Canada and the European Union, Industrial Control Panels (ICP’s) are required to meet a number of regulatory requirements including compliance to specified standards and listings. In the US, the ICP’s must comply with NEC Article 409 and section 110.3(B) and ANSI/NFPA 70. A panel without approvals which gets tagged by the local AHJ (Authorities Having Jurisdiction) can prove costly to a manufacturer.

Regulatory standards that are applicable to the ICP’s include:

  • UL508A (US)
  • CSA C22.2 No. 14 (Canada)
  • EN 60204-1 and EN 61439-1 (Europe)

Regulatory Challenges
Manufacturers mass produce as well as custom build ICP’s, making it very difficult and expensive to carry a typical listing or to utilize field evaluations for each panel. The goal of a manufacturer of ICP, especially when manufacturing a custom ICP, is to provide the most cost effective solutions based on client specifications. However, sometimes the best designed ICP’s are found to be non-compliant to regulatory requirements. A few reasons which have been cited for this non-compliance include: lack of consideration of panel application, component selection, and sometimes minor oversights.
Control Panel

How can TÜV Rheinland help?
by utilizing TÜV Rheinland’s panel shop program, manufacturers can now build ICPs and apply the widely accepted and recognizable TÜV Rheinland mark. This signifies to local AHJs that the panel meets the applicable safety standard for that location. Each label is serialized, allowing interested parties to verify the validity of the label using TÜV Rheinland’s Certipedia website. Our Panel Shop program offers shops the flexibility to produce a wide variety of custom panels without the necessity to evaluate each individual panel. When field evaluation and labeling services are required, TÜV Rheinland can offer next-day service to most locations in the U.S. and Canada.

Learn more about TÜV Rheinland's industrial control panel shop program.





Topics: Commercial, Industrial Control Panels