CE approvals & compliance testing a PCB containing a module

[nali]

OK firstly apologies if this has been covered before - searching "CE" brings up anything with words containing those 2 letters.

I have a product which we intend to sell consisting of a board which is essentially a (CE-marked) Bluetooth LE module, some glue logic and interface chips: RS485/RS232 drivers and a FTDI USB. It will be sold as a PCB for other manufacturers to fit inside their own products, and will be powered from a DC supply either via the USB or an external power jack.

Would you say this requires CE marking? From  http://www.ce-marking.org/what-product.html the only applicable part seems to be "Radio Equipment & Telecommunications Terminal Equipment (R&TTE)". Although wouldn't that part be covered by the module's own declaration?

Irrespective of that, we will probably  at least get it tested anyway for our customers to assimilate into their own technical files. So as above, would I need to get it tested as an Intentional Radiator?

Finally has anyone any recommendations  for test houses or CE consultants - or ones to avoid? I 'll be needing the latter sometime as we will later be bringing out another product - this one will be a finished item, connected to the mains etc, and include the board above.

Thanks
Nick

[Neilm]

The fact that you are using a CE marked module does not mean it automatically pass EMC tests. How the device is mounted could mean you will have reflections or conducted noise. Also, depending on the antenna you may find the frequency has shifted (I have seen that on a pooly laid out PCB). I don't pretend to know the legislation but I believe that you would have to have it tested as unit containing an intentional radiator. It would still need to comply with the Radio Equipment Directive (RED). This is a new directive that superceeds the R&TTE - mostly similar but there are a few gotchas in the differences.

Safety wise, if you are providing the mains adaptor make sure you have a report from the manufacturer, don't just rely on the fact it has a CE mark. For safety sake, open one up and see if you see anything horrible in there and try to tie up the safety document to the features in the adaptor.

As far as test houses are concern the company I work for do in house testing (we have our own EMC facility) but we do use Intertek in Leatherhead for some of our EMC testing.

[nali]

The fact that you are using a CE marked module does not mean it automatically pass EMC tests. How the device is mounted could mean you will have reflections or conducted noise. Also, depending on the antenna you may find the frequency has shifted (I have seen that on a pooly laid out PCB). I don't pretend to know the legislation but I believe that you would have to have it tested as unit containing an intentional radiator. It would still need to comply with the Radio Equipment Directive (RED). This is a new directive that superceeds the R&TTE - mostly similar but there are a few gotchas in the differences.

Safety wise, if you are providing the mains adaptor make sure you have a report from the manufacturer, don't just rely on the fact it has a CE mark. For safety sake, open one up and see if you see anything horrible in there and try to tie up the safety document to the features in the adaptor.

As far as test houses are concern the company I work for do in house testing (we have our own EMC facility) but we do use Intertek in Leatherhead for some of our EMC testing.

OK thanks for the input. The module in question has a U.FL connector for an external antenna so in theory there's no RF on the PCB although of course there's always the chance of stray pickup, leakage through the supply / GPIOs et al. I'm not trying to avoid EMC, just clarifying my understanding of it really... the last time I had anything remotely to do with the subject was when the regs were introduced, I think things have probably changed a bit since then!

Regarding safety there's no mains supply as such. This will be for others to fit into their own equipment and an example of the target market is a street information display, so the host equipment will supply the power typically 12V.

Last time I enquired about this for an unrelated project I got the hard sell from the EMC house for probably a couple of years. It sometimes felt we were under investigation by Ofcom  In the end we decided not to bother as in hardware terms the project size wasn't worth the pain of designing/manufacturing/approving the kit.

I'll try Intertek, they could be handy as they're actually pretty local to me, thanks.

[Benta]

Would you say this requires CE marking?

EVERYTHING sold in the EU requires CE marking and conformity.

There are a couple of other directives you'll need, apart from R&TTE, which is expiring and being superceded by RED (Radio Equipment Directive):
Low Voltage Directive
RoHS

[nali]

EVERYTHING sold in the EU requires CE marking and conformity.

That's not true. From https://www.gov.uk/guidance/ce-marking "Not all products must bear the CE marking. Only those product categories subject to specific directives that provide for the CE marking are required to be CE marked."

I can't find an "official" source but from http://www.emcfastpass.com/could-your-product-be-exempt-from-emc-testing-altogether/ "Components, sub-assemblies or other units which are intended for incorporation into apparatus, but which have no “direct function” for the end user, are not considered to be apparatus for the purposes of the EMC Directive."

There are a couple of other directives you'll need, apart from R&TTE, which is expiring and being superceded by RED (Radio Equipment Directive):
Low Voltage Directive
RoHS

LVD only applies for equipment operating at 75-1500V DC (50-1000VAC)