Product Compliance in Morocco

IMANOR (Institut Marocain de Normalisation) is the national standards body of Morocco and is responsible for standardization in Morocco.  It was created in 2010.  Its mission is to, among others:

• Issue Moroccan standards
• Certify compliance with standards and normative references
• Publish and disseminate standards and related products and information

The Moroccan standards are in most cases harmonized with international and European EN standards.

The CMIM marking is one of the pillars of the product compliance in Marocco.

The Cم (CMIM) mark certifies the regulatory conformity of products offered for sale on the market in Morocco. The certification marking is mainly used to ensure the safety of industrial goods on the Moroccan market. Its operative texts set out the legal requirements for those products.

Once obtained, the CMIM mark approval doesn’t need to be renewed as long as the following two conditions are met:

• the company (e.g. manufacturer) has the appropriate means and controls in place to ensure ongoing conformity with the applicable regulations
• the relevant regulations allow for it and don’t state otherwise.

The scope of the Cم (CMIM) mark includes industrial products covered by Law 24-09 on the safety of products and services and some specific technical regulations. Overall, there are three product groups that are concerned by this certification marking and are the subject of certain Ministerial Orders:

• electrical equipment intended for use within certain low voltage limits (Decree No. 2573-14)
• electrical products subject to electromagnetic compatibility (EMC) testing (Decree No 2574-14)
• and toys (Decree 2575-14).

Please note that not all electrical products and toys should comply with the Cم mark regulations. So please check the scope of application of the relevant Ministerial Order before placing the logo on your product.

Exclusions in the regulations can be found in, as follows:

• Article 3 of the Ministerial Decree relating to Electromagnetic Compatibility of Electrical Equipment.
• Appendix 1 of the Ministerial Decree concerning products designed to be used within certain low voltage limits,
• Annex 1 of the Ministerial Decree on toy safety.

These three Decrees are identical to the following European directives – Low Voltage Directive, EMC Directive, and Toy Safety Directive.

Documentation requirements

You must compile a technical file and create a Declaration of Conformity to comply with the Moroccan regulations and affix the Cم (CMIM) mark to your products.

The technical documentation must show that all relevant conformity assessments have been carried out successfully and provide information about the product itself. In this regard, the documentation should include at least the following information:

• A general description of the product in question
• Conceptual product design
• Manufacturing drawings and schemes of safety-critical components, circuits and sub-assemblies
• A list of all components and materials used
• Descriptions and explanations required for the understanding of the above-stated drawings and schemes and the operation of the product
• A list of the harmonised (EN) standards applied in full or in part
• Descriptions of the solutions used to meet the safety objectives of the Ministerial Order if harmonised standards haven’t been applied
• Results of any design calculations made and examinations carried out.
• Although not obligatory, it’s recommended that you include a photo of the product in the technical file. Otherwise, you need to use other appropriate means allowing the product’s identification.

As mentioned above, you can apply EN standards to prove conformity. That’s because the Moroccan standards (NM) are often identical to the EU harmonised standards (EN). Please note that the Declaration of Conformity should mention the NM standards instead of the EN standards. Additionally, a cross-reference table of the EN/NM standards should be added to the technical documentation. If you don’t fulfil the latter condition, ensure that the technical documentation shows the product’s conformity with the Moroccan standards. For references to the NM standards, check the Moroccan institute of standardisation (IMANOR).

The technical documentation must be written in either Arabic, French or English, while the Declaration of Conformity must be in Arabic or French. All information meant for end-users (e.g. instructions for use) must be in Arabic, at a minimum, according to Article 31 of Law 24-09.

CMIM Marking

From January 2020, the responsibility of placing the Cم (CMIM) mark on a product’s surface is solely given to the manufacturer. This means that products must be fully compliant and adequately labelled before entering Morocco.

Until December 31st, 2019, importers could also label products as long as they were authorised to do so.

When affixing the CMIM mark to products, you must comply with the following label requirements:

• The product marking must be displayed in a visible, legible and indelible way on the product’s surface
• It should include the initials (C) and (م) and respect the conditions of form, appearance and presentation defined in the specific technical regulation.
• No other markings should affect the visibility, legibility or meaning of the Cم (CMIM) mark
• The vertical dimension of the letter initial “C” must be no less than 6 mm.
• The logo must be displayed on the product’s surface. Where the nature of the product doesn’t allow for that, the Cم (CMIM) mark may be placed on the packaging and in the accompanying documents.

The European CE marking cannot be used instead of the Cم (CMIM).   CE marking is a European product certification marking that is mandatory for various products sold on the EU single market, and it cannot replace the Moroccan Cم mark. Thus, your products need to be Cم mark compliant to be sold on the market in Morocco.

However, please note that if your goods are already CE compliant, the Moroccan regulatory process is simplified. In such a case, the following should be done:

• perform a study to identify the Moroccan regulations and standards that correspond to the European regulations and EN standards relevant to your product,
• ensure compliance with any requirements that aren’t covered by the European legislation.

Parallelly with the Cم (CMIM) mark, the Moroccan Ministry of Industry, Trade, Green and Digital Economy (MCINET) recently established a ‘Verification of Conformity (VoC)’ program to certify that products imported into Morocco comply with the national regulations for product quality and safety. The VoC program is effective since February 1st, 2020 and was established in the Avis du Ministere de l’Industrie de 16.12.2019.

Specific consumer and industrial products aimed for import into Morocco shall undergo testing acc. to local NM-standards, which are partially harmonized with ISO- or EN-standards. A pre-shipment inspection needs to be performed either in the country of export or on Moroccan territory (Destination Inspection) – depending on the regulated product categories (see ‘Products in Scope’ above). In both cases, the conformity assessment concludes with a Certificate of Conformity (CoC) – demonstrating that the products meet the applicable standards and regulations. Three different certification routes may be chosen from, according to the nature and frequency of imports.

The programme verifies the conformity of all regulated products in the respective exporting countries within a range of sectors, including:

• Chemicals such as detergents, paint, bitumen, matches, lighters
• Construction Materials such as (pipes, sheets, sanitary equipment, insulation, wooden panels, cement, windows, glass…)
• Electricals and electronics
• Gas, Oil Appliances
• Textiles, leather, shoes and clothing
• Personal Protective Equipment, motorcycle helmets
• Food contact materials such as kitchenware and crockery
• Plastics
• Automotive spare parts including tyres
• Building products
• Toys, parks and baskets for children, baby diapers, furniture

Specified products will require local verification through a destination inspection.

These are:

• Motor vehicle spare parts – Tyres, batteries, Brake linings (brake pads), Glazing, Filter elements, Mechanical control cable, Leaf springs
• Motorcycle spare parts – Air chambers
• Construction products – Ceramic tiles, Cement, Sanitary products, Taps, Sealing sheets, Plastic tubes
• Gas appliances – Gas heaters, Gas water heaters
• Construction materials – Wire rod, Steel bars for reinforcement of concrete, Wood panels
• Electrical products – Mobile phone chargers, Circuit breakers
• Blankets, Rugs & carpets, Furnishings, Articles of clothing other than work clothing, Footwear other than personal protective equipment footwear, baby diapers, Non-woven fabric protective masks for non-medical use, Protective fabric masks for non-medical use.

The telecommunications equipment to be connected to a public network and radio installations are subject to pre type approval by the National Telecommunications Regulatory Agency (ANRT).

The application for Type approval entails submitting the following:

• The application form (Appendix 1);
• Technical documentation to determine the interfaces contained in the equipment, all of its features and standards. For radio installations, this documentation must indicate the relevant radio characteristics of the equipment (frequency band, power, the SAR value or equivalent field-level).
• A prospectus or short technical report identifying the interfaces contained in the equipment.

This request can be sent electronically to ANRT.

Type approval is granted for a period of 10 years.

ANRT Certification standards are based on the European EN standards under the RED Radio Equipment Directive 2014/53/EU, which defines requirements for health and safety, EMC and the efficient use of radio frequencies.

Labelling is mandatory and shall be carried out according to ANRT/DG/N°12/04 (dec. 2014) for all imported and ap-proved terminal equipment or radio installations.

Any terminal equipment or approved radio installation shall be, prior to its commercialization, be labelled with an irremovable tag – see the model in Annex 4, pursuant to decision ANRT/DG/N° 12/04 of December 29, 2004.

Any equipment for sale to the public and not properly la-belled is considered unauthorized.