Nkom: Inadequate quality assurance in connection with sales of smart watches for children
The purpose of Nkom’s inspection was to check whether the manufacturers had performed a correct conformity assessment towards the requirements in the Radio Equipment Directive, or not. This includes that the manufacturers must declare that the equipment meets the essential requirements in the directive. The inspection comprised checking the marking of the equipment, packaging, documentation, and the mandatory information supplied with the equipment.
None of the watches met all of the requirements
Eighteen different smart watches were checked in the inspection. It was found that none of them satisfied all of the documentation requirements laid down in the Radio Equipment Regulations. The non-conformities ranged from inadequate marking of the equipment, such as lack of CE marking, manufacturer or type designation, to more serious non-conformities such as lack of documentation indicating the standards pursuant to which the equipment was tested. Many of the watches did not refer to standards for testing of Specific Absorption Rate (SAR), meaning it is unclear whether they meet the requirements for user exposure to radio waves.
“The result show that for some products, there is thus considerable uncertainty as to whether they actually meet the technical requirements. Since these watches are intended to be worn by children, we find it especially serious that there is no information about SAR, i.e. whether the equipment meets the requirements regarding radiation levels,” says Nkom Director General Elisabeth Aarsæther.
Notification of decision
Nkom is issuing a “notification of decision” to the distributors and/or importers of the inspected watches. For most models, the notification is requiring rectification of the identified non-conformities. This means that the distributor and the importer to Norway, together with the manufacturer, will have the opportunity to propose a solution to rectify the non-conformities.
“Importers and distributors of radio equipment are responsible for ensuring that the equipment they import or sell complies with the European regulations. They thus have a duty to check that the equipment and packaging is properly labelled, that there is sufficient information for the user, and that a declaration of conformity is provided whereby the manufacturer declares that the equipment complies with the regulations,” Aarsæther emphasises.
Non-compliance with the technical requirements may have serious consequences; for example, the equipment might transmit on the wrong frequencies, have unwanted radiation that can interfere with other equipment, or have insufficient immunity to interference from other equipment and thus not function as intended. In addition, the equipment might have higher than permitted radiation levels.
Nkom performs systematic market surveillance as part of its responsibility to monitor that sales of radio- , telecommunications terminal and network equipment are in accordance with Norwegian regulations. In this context, selected products are checked for compliance with the applicable requirements for frequency use, safety, and emission of electromagnetic noise. Smart watches for children contain radio transmitters and receivers for GSM, WiFi, and GPS, etc. They are therefore subject to the Radio Equipment Regulation, in which Norway implements the requirements of the European Radio Equipment Directive. This Regulation lays down administrative and technical requirements for radio equipment that is imported and sold in Norway.