Initial Type Testing (ITT, or more accurately, Initial Type Assessment) is a requirement on all products, as part of the Evaluation of Conformity process, in order for them to bear the CE marking. Even well-known products which have been in production for a long time need to be shown to comply with the requirements of harmonised European Standards or ETAs.
ITT may involve:
· direct testing,
· the use of tabulated or 'deemed to satisfy' provisions, with or without indirect testing,
· calculation,
· compliance with a particular prescriptive requirement.
Depending on the Attestation of Conformity system, some ITT may be performed by the manufacturer and some by a Notified Body.
For products covered by standards, the requirements for ITT will generally be indicated in the standards themselves. But problems may still arise. For example, is the standard unclear about the sampling rules and how many products need to be tested, what constitutes a 'pass' if one or more products initially fail, and how is the ultimate value (to be declared by the manufacturer with the CE marking) derived from the ITT tests?
If you are a manufacturer having difficulty with any aspect of ITT, or if you are being asked by a Notified Body to perform tests which you do not wish to perform or in a way different from described in the standard, APSR Associates can help you resolve these. Contact us via our Consultancy, Advocacy or Representation Services. |