After compulsory testing was changed to the voluntary CE scheme, testing services were outsourced to China. In the past 2 decades we set up great test and certification bodies in China and caused a total lack of experience and knowledge in the European test houses.
The end of the Notified Body is near
Currently notified bodies have been closed and more are likely to be closed. The knowledge of test houses and Notified Bodies is at an all time low, but also market surveillance is suffering hard. Experienced engineers are retiring and being replaced without transferring their knowledge. Nearly anyone is able to give interpretations of standards and directives, and more people will refer you to the legal system. However, a judge is not an engineer, let alone an expert in that specific area.
Product compliance is innovation
An experienced test and certification body, means products comply and keep consumers safe. However, it also means understanding of products that do not comply, yet are still able to be marketed. That knowledge is vital for innovation, since innovations usually deviate from the current standard.
Compulsory testing in the EU
So we urgently need to transfer the knowledge back into the European Notified Bodies, and for this, there is only one method. Testing, testing, testing. Doing the job is understanding the standards. We saw this in China. Within 10-20 years we build up a strong engineering force in the various test houses there. So now we need to transfer that knowledge back to Europe. Since the production location and the cost of testing, make it logical to test local, this means this must be done by force. So the only way to achieve this, is to make testing compulsory and done only by notified bodies, inside the EU.
Online sales safety
The second problem we solve with this, is the hard to handle safety of online trade. If products coming into the EU must have a compulsory test report tested within the EU, it will be much easier to control the flow of online traded goods. In the International trade many countries have compulsory systems. However, I would urge to add the testing in the EU too, snce that is critical to build up knowledge.
How to do this?
I suggest a gradual method, starting with certificates that must be updated and new certificates. Since the EU Notified Bodies need time to recover. Finding and hiring more staff and train them, will take at least 10 years.. In this way we gradually integrate all products into the EU test scheme. When that is done, we all have the same costs. So from a trade perspective there is no real change, after the transit period.
Finally, the Accreditation Bodies must undergo a vital change. Their work is questionable at least. The knowledge is flowing out of the Notified Bodies, which all people in the business clearly see. Yet they keep their accreditation. We even have seen labs lose their Notification, who still had their accreditation…