What is mark ?
In order to ensure the safety of industrial products on the Moroccan market, the law24-09 on the safety of products and services, as well as its operative texts, represent a legal framework that is setting the requirements to be fulfilled by these products.
The Cم mark certifies the compliance of the products placed on the market with the regulatory requirements in force in Morocco.
What is the product scope of the mark ?
The Cم mark applies to industrial products covered by the 24-09 Law, as well as by specific technical regulations.
Three product families are concerned by this marking, and are the subject of specific Ministerial Orders published in the Official Journal:
- Electrical equipment designed for use within certain voltage limits (so-called low voltage (LV)) ;
- Equipment affected by electromagnetic compatibility (EMC) ;
In order to accurately identify the products concerned by the Cم mark, it is necessary to check the scope of application of these Ministerial Orders. Exclusions are defined generally in the regulations in question :
- For EMC, exclusions are specified in Article 3 of the Ministerial Order about Electromagnetic Compatibility of Equipment.
- For LV, the exclusions are specified in the appendix 1 of the Ministerial Order relating to equipment intended to be used within certain voltage limits,
- For toys, exclusions are provided in Annex 1 of the Toys Safety ministerial order.
These orders are identical to the European Low Voltage, EMC and Toys Directives.
Who is responsible for affixing the mark ?
Any person responsible for placing on the market a product covered by the specific technical regulations in force..
What are the mark form requirements ?
- The mark includes the initials (C) and (م) , and in accordance with article 18 of the 24-09 law, it must respect the conditions of form, appearance and presentation determined in the particular technical regulation.
- It is displayed in a visible, legible and indelible way on the product
- It should not be confused with other distinctive signs.
- The vertical dimension of the letter "C" must not be less than 6 mm.
- The logo must be affixed to the product. Where that is not possible or not warranted because of the nature of the product, it could be affixed to the packaging and to the accompanying documents.
What are the documents that importers or producers must submit to comply with the regulations and affix the marking?
During local and import control operations, those responsible for placing the product on the Moroccan market must submit a technical file containing the relevant technical dossier to prove the conformity of the products.
The technical dossier must provide the following elements::
- The declaration of conformity (in Arabic or French).
- Documentation for performing conformity assessment procedure with technical requirements and specifications:
- A general description of the product;
- Conceptual design and manufacturing drawings and schemes of components, sub-assemblies, circuits, and the list of components and materials used ;
- Descriptions and explanations necessary for the understanding of those drawings and schemes and the operation of the product;
- A list of the harmonized standards applied in full or in part, descriptions of the solutions adopted to meet the safety objectives of the ministerial order in case the harmonized standards have not been applied;
- Results of design calculations made, examinations carried out.
In which language should the technical file be drawn up?
The technical file could be written in Arabic, French or English, however it should be noted that in accordance with Article 31 of Law 24-09, all information intended for users must be in Arabic at least.
How to assess the conformity of a product to affix the mark ?
For the conformity assessment and in accordance with the regulations in force, it is possible to apply the internal control procedure or the conformity to type procedure as for the EU directives.
For this, it must be ensured that the product complies with Moroccan standards (NM) and establish a technical documentation that proves compliance with Moroccan regulations and NM standards (it is not acceptable to mention only European regulations and standards or standards of other countries).
In the absence of Moroccan standards, the producer can rely on international standards.
Can the producer call on a third party for conformity assessment?
For conformity assessment according to the internal control procedure, as for EU directives, if the producer does not have the means to evaluate his product himself he can rely on an external body.
For evaluation according to the type conformity procedure, this body must be recognized by Morocco (equivalent to notified bodies in EU regulations).
How can we find the Moroccan standards to be applied? What should be mentioned in the declaration of conformity?
The Moroccan institute of standardization (IMANOR) publishes the references of the Moroccan standards. The product owner is responsible for identifying the relevant standards for carrying out the evaluation
In case the Moroccan standards (NM) used to prove conformity are identical to the European standards (EN), it is sufficient to attach a cross-reference table of the NM / EN standards and to mention the Moroccan standards in the declaration of conformity..
If this condition is not fulfilled, the technical documentation must show that the product comply with the NM standard.
Could “CE” marking replace the Moroccan marking ?
CE marking is a condition for the EU to place a product on the EU market. It cannot, under any circumstances, replace the Moroccan marking, which is a Moroccan regulatory tool that must be abided by to put the related products on the Moroccan market.
Is it necessary to attach a picture of the product to the technical dossier ?
It is not mandatory to attach a picture of the product to the technical dossier. The company can choose the appropriate solution that helps identifying the product.
Are importers allowed to affix the marking ?
The marking is the responsibility of the manufacturer. However, facilities are granted to importers who are then authorized to proceed to home-marking (in their warehouses) until 31 December 2019, as long as they prove that their products comply with the safety requirements of the regulations in force, by submitting technical documentation during control operations. Beyond that date, the manufacturers themselves must mark the products, which means before their entry into the country.
When the supplier is importing various products, is it mandatory to prepare a technical dossier for each product?
Each product reference must have its technical dossier, as the EU requires it for the CE marking process.
If the product subject to several specific regulations, a single declaration of conformity stating all the regulations and standards applied is sufficient.
What is the deadline for archiving the technical dossier?
The responsible for placing products subject to specific technical regulations on the Moroccan market must keep the technical dossier for 10 years from the date of the last placing on the market and make it available, on request, to the national authorities for inspection purpose.
When a product is imported by several importers, each importer must keep the declaration of conformity concerning the batch he has imported.
What about products that do not have a specific technical regulation yet: how can we prove their compliance?
For products that do not have specific regulations, the general safety principle applies. Their conformity assessment is based on Moroccan standards or, failing that, international standards.
Products covered by a mandatory standard could be checked before customs clearance.
- Law24-09 on safety of products and services
- The official journal about Cم marking:
- The graduated graphics of the marking
- List of the above-mentioned orders
What to remember from the marking
- is a mandatory conformity marking, which is considered as a certificate of compliance of the product with the Moroccan regulatory framework.
- Any product subject to a specific technical regulation under Law 24-09 may be placed on the market only if it bears the marking.
- Three product families are currently covered by specific technical regulations.
• Electrical products intended to be used within certain voltage limits;
• Equipment affected by electromagnetic compatibility;
- The marking is the responsibility of the producer. Exceptionally, the importer is authorized to proceed to home-marking (in their warehouses) until 31 December 2019.
- The Moroccan Institute for Standardization (IMANOR) has set up a service to assist operators in the process of compliance with the provisions of the technical regulations and marking.
Access the presentation slides