There is more and more confusion about chosing the correct standard for product testing. This increases the risk of accidents and recalls. So here a quick run through on how it is done. The above light chain is our example. Below we explain why it is actually NOT a light chain.
Step 1: choosing directives
In Europe, compliance with standards is only the second step. The first step is always compliance with the European directives. So we first need to assess which directives are applicable for our product.
What is our product?
At first glance our product looks like a light chain, which is the reason most labs will send it to their lighting department. However, until otherwise decided, it is a battery operated product, with LED bulbs and a metal wire to connect the bulbs.
Because of very low voltage, the Low Voltage Directive does not apply. It is not a toy, so that is out of the way too. There are no electronics, making the EMC directive useless. So in the end nothing remains, except the General Product Safety Directive (and RoHS/REACh, but for this example that is irrelevant).
Step 2: choosing standards
Regardless if we chose a directive or not, when choosing standards, we always look at the highest risk level for the leading standard. We may include other standards to cover other or similar risks.
The highest risk of this product are the 2x CR2032 batteries and with that the risk is in the battery compartment. They can be highly dangerous for children and animals. Since it is not a toy, the risk of strangulation is not something we need to cover. There is no further risk in the light chain. It does not become warm, there is no electric shock and no risk of fire (although extremely thin copper PVC wire could be a risk, it is naked wire which is without that risk).
Step 3: All of the standard or just a part?
So in our case the light standard (EN60598-2-20) is irrelevant. Since now no standard is relevant, we either need to do our own risk assessment, or use a reference standard. Looking at the battery compartment there is only one standard covering this, the EN62115, which is a toy standard. Since this is not a toy, the standard may be too strict. Of course you can follow the complete standard, but you can also use the delicate art of analyzing the risks per paragraph and see if that risk is covered inherent in the product and its use, or if the paragraph is still relevant. Keep in mind that logic takes you a long way. Products must be idiot proof, not mad men proof and the user may be given a certain amount of responsibility, but this is limited. So, keep in mind that distribution channels and warnings are not enough to guarantee safety and even sane people can do weird things.