Market Entry in Saudi Arabia – with Obstacles

SASO Standards at a glance:

SASO 2870/2018:  Energy efficiency/functionality requirements and labelling requirements for lighting products - Part 1
The standard refers to indirect (diffuse) and direct (directional) general light sources of the above-mentioned technologies with a luminous flux of more than 60 lumens and less than 12,000 lumens. It applies to incandescent lamps, halogen lamps, compact fluorescent lamps with integrated ballast (CFLi), LED lamps as incandescent lamp retrofit and LED lamps as halogen lamp retrofit.
One note:  The CB test required implicitly also includes control gear. An efficiency of at least 91% is assumed for them. Luminaires with a rather low output may not be able to achieve the corresponding nominal values.

SASO 2902/2018:  Energy efficiency/functionality requirements and labelling requirements for lighting products - Part 2
This standard applies to light sources with a light output of 12,000 lumens or more (products not covered by SASO 2870). These include:
●    Filament lamps with a luminous flux of 12,000 lumens or more
●    Halogen lamps with a luminous flux of 12,000 lumens or more
●    Compact fluorescent lamps with integrated ballast (CLFi), having a luminous flux of 12,000 lumens or greater
●    Compact fluorescent lamps without integrated ballast (CFLni)
●    Fluorescent lamps (all types)
●    High-pressure discharge lamps, such as mercury vapor lamps, high-pressure/low-pressure sodium vapor lamps, quartz metal-halide lamps or ceramic metal-halide lamps
●    LED lamps (including retrofit LED lamps with a luminous flux of 12,000 lumens or more)
●    Directional and nondirectional integrated luminaires (with nonreplaceable lamps)

The UL and IEC Standards for lighting products facilitate international market access. Many countries use self-declaration, for example the CE mark within the European Union. However other countries vary and are setting the bar even higher. One example of this, currently challenging manufacturers, is Saudi Arabia.

The country insists on a declaration of conformity, the SASO IECEE (IEC standards for electrotechnical devices and components) Recognition Certificate. This is issued by the standardization authority of Saudi Arabia, the Saudi Standards, Metrology and Quality Organization (SASO), provided that energy efficiency and safety requirements are met. To be awarded the energy label, an endurance test of 2,000 hours is required – corresponding to just under 84 days. SASO is thus setting relatively high hurdles to market entry.

Even assuming that the relevant processes of the Saudi Arabian authorities are running at top speed, manufacturers can anticipate a delay of at least three months between application and approval. Since the regulation only came into force at the beginning of the year, there is limited experience at the moment. The next few months will show just how quickly such an approval procedure can be handled in practice.

Hurdles to market entry in Saudi Arabia

In particular cases, this creates real difficulties for companies. For mass products such as retrofit LED lamps with common light bulb sockets (such as G13), a test phase lasting several months is at least half plannable. However the project business in particular is facing considerable difficulties. This impacts building projects or interior design projects for which specialist lighting products, not yet certified by SASO, are planned. In this case, the producer must initially take on the entire procedure and the general contractor must incorporate this into the initial project planning. 

Of course, the long-term test of a light source is not a difficult task, but test laboratories usually have capacity limits. Particularly since the test requirement applies to all light sources using common technology with a lighting current of 60 lumens and above. In practice, this will mean that companies interested in the Saudi Arabian market will have to test their entire product range, or at least define an export product portfolio.

Unfortunately, SASO has established another hurdle:  Certification and testing must be repeated regularly. The energy label is valid for one year, after which all product documents, including the test results, must be submitted again. The actual tests in the test laboratory must be repeated every two years. This makes market access in Saudi Arabia a constant issue for manufacturers, as a three-month test phase must now be planned into product cycles every two years.

Planned action makes sense

With its unusually high requirements on a long-term basis, market entry to Saudi Arabia requires a planned, multilevel approach from producers. The first step is to apply for a Saudi energy efficiency (EE) certificate and label. The label will only be issued if the information in the application documents is verified by tests carried out by a registered testing body (Certification Body or CB) (these tests include the long-term test of 2,000 hours described above). 

Subsequently, the security check can be addressed. A valid CB test certificate and a CB test report are required. This certifies the conformity of the product to the current IEC standards for electrotechnical devices and components (IECEE), whereby the national differences of Saudi Arabia are also taken into account.

On the basis of these documents (EE + CB), SASO then issues the IECEE Recognition Certificate. This process has been in force since last year for various electronic devices and since Feb. 1, 2019, for lights and lamps.

Now that the Saudi authority carries out the examinations, it can also make comments and suggestions for improvement. Manufacturers should therefore not necessarily rely on the application going through smoothly.

This rather elaborate approach shows that the process is complex in comparison to the formalities for other countries. With such specifics it's not easy for manufacturers to have an overview of the regulatory frameworks across the global market. A product must comply with numerous different rules, regulations and requirements, as well as needing various evidence of product compliance.

Manufacturers should act now and apply for certificates

The lighting industry is well advised to have its products or the planned export range for Saudi Arabia certified by an external expert. There are, of course, exceptions and special cases where proof of energy efficiency can be omitted, such as infrared heat lamps and others, but UL's specialists can also provide advice here.

In the short term, product qualification is not possible due to the long test phase. Companies otherwise face a high risk of losing their Saudi Arabian business partners or not being able to enter the market, as ultimately product registration in Saudi Arabia's online system, SABER, is still required. UL can also help here. Once the SASO Shipment Certificate is present, product import at customs should go smoothly.

To learn more, visit UL.com

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