Author Topic: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?  (Read 24354 times)

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Offline johnnyfpTopic starter

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FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« on: August 17, 2014, 10:49:49 pm »
If for argument sake, I wanted to sell a Finalized product that had WIFI, a built in Switch mode PSU, and various other RF noisy things and that the modules I used within that product where not FCC/CE certified, then I would assume that I would need to get the product FCC/CE certified if I wanted to sell it in large quantities.

However, what if I wanted to sell a DIY KIT of the same product, just with all the components either not soldered on, or partially soldered, but the end product is not complete until the hobbiest finishes it. Would I still need to get it certified or is that now down to the end user to do that.

For example, If I designed a module that is a WIFI SPI adaptor that would, say, be compatible with an Ardiuno development board, what I put together and sell is the WIFI chip, PCB antenna, on a PCB module, then the end use you put together the MCU (Arduino), PSU etc. IE they would need to solder it or jumber it to thier circuits.

Your thoughts?

 

Offline Richard Crowley

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #1 on: August 17, 2014, 11:17:12 pm »
If you want to sell it in "large quantities" then presumably you can afford the compliance testing costs.
Many people use "wall warts" to avoid built-in power supplies and the attendant testing requirements.
Likewise using an external (USB) plug-in WiFi "dongle" puts the burden on the maker of the USB WiFi gadget.
 

Offline johnnyfpTopic starter

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #2 on: August 17, 2014, 11:21:16 pm »
Yeah, maybe Large Quantities was a pipe dream, more like sell more than 5 is Large quantities for me  :-DD Sad I know.

 

Offline Cside

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #3 on: August 17, 2014, 11:41:11 pm »
In my industry, 5 is considered mass production
 

Offline T3sl4co1l

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #4 on: August 18, 2014, 12:54:43 am »
AFAIK, kits have no particular restrictions; the onus is on the builder to obey all relevant laws.  I guess because, anyone can always build something, you're just supplying the parts and some helpful instruction.  And besides, even if you provide instructions to build a device which proves to meet requirements, there's no guarantee that the end user has built it correctly, or made any variations (skipped parts here, extra / modded parts there, etc.) that ended up screwing with that.

If it actually came to court, I doubt this reasoning is exactly iron-clad.  There have been cases involving kit suppliers, but I don't remember what any of them were about; worth a look I suppose.

You would at least want to provide a 'good faith' effort to control things: a line filter, shielding (grounded enclosure?), some ferrite beads, etc.

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Offline AndyC_772

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #5 on: August 18, 2014, 05:57:01 am »
Only if you're talking about a mains PSU, and only an idiot would build a mains PSU from a kit, or sell one.

Offline SirNick

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #6 on: August 19, 2014, 08:00:55 pm »
The forums here are full of PSU designs.  I don't know how many of those (on the Internet in general) make it to a kit, but I wouldn't be surprised to see a few.
 

Offline Richard Crowley

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #7 on: August 19, 2014, 09:10:44 pm »
Only if you're talking about a mains PSU, and only an idiot would build a mains PSU from a kit, or sell one.
Well, then there are "idiots" out there selling mains-supplied PSU kits. 
My main field is audio/video and this vendor sells PSU kits, for example....
http://www.fivefishstudios.com/diy-kits/psu-2448mk2-kit



I'm sure there are several (many?) other vendors of similar mains-supplied PSU kits.
 

Offline mcinque

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #8 on: August 19, 2014, 09:26:19 pm »
If it's for the end user (even if its a module), it's an apparatus, and it's mandatory to have a CE/FCC compliance.

If it's NOT for the end user (i.e. a module that should be installed by qualified personnel)  doesn't need any compliance.

Read here about this, IMHO it's very clear.

For me, the basic concept to understand is that the regulations basically wants to avoid EMI (conducted or radiated) in any device that is not specifically excluded (some medical devices, security devices etc.) so:
  • the manufacturer must comply with the directive, and
  • the end user should receive a product that is compliant, not caring about the emissions or any else related to the directive
It's sad but it's true.  :(
 

Offline johnnyfpTopic starter

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #9 on: August 19, 2014, 09:30:37 pm »
Would that then not apply to anyone buying a Wifi Component from Digikey or the components to build a powersupply?

They are the end user, so the ownest is on the component manufacture to make sure it's compliant, not the end user?

Or are Hobbiest not the norm?
 

Offline mazurov

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #10 on: August 19, 2014, 09:35:16 pm »
Only if you're talking about a mains PSU, and only an idiot would build a mains PSU from a kit, or sell one.

That would depend on the definition of "idiot" - I'd love to hear yours. While you're at it, explain the difference between building a PSU from the kit vs. using loose parts acquired in the store or salvaged and what makes kit approach specifically idiotic.

The electronic surplus shop I frequent get their supply from garbage bins of companies like Ball Aerospace, LM and Raytheon. They're seling all kind of potentially deadly stuff - for many years.
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Offline SirNick

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #11 on: August 19, 2014, 11:11:15 pm »
Would that then not apply to anyone buying a Wifi Component from Digikey or the components to build a powersupply?
They are the end user, so the ownest is on the component manufacture to make sure it's compliant, not the end user?

Components can't be certified - they're not self-contained systems.  (At what range of frequencies does a 100uF capacitor radiate?  What is the voltage across its terminals?)

Modules can.  If you buy a WiFi module, it'll be covered in compliance stickers.  Same with a modem.  Not the case with an 802.11 IC by itself.
 

Offline mcinque

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #12 on: August 20, 2014, 11:17:33 am »
Would that then not apply to anyone buying a Wifi Component from Digikey or the components to build a powersupply?
Consider that like in weapons, where noone can prevent you to purchase steel (you can use it to build a cannon or a gun), noone cannot prevent you to build in your garage an EMI generator or a strong radio trasmitter by properly putting together various components, but of course you cannot sell it, or if you're get caught using it, you'll be legally pursued.

Quote
They are the end user, so the ownest is on the component manufacture to make sure it's compliant, not the end user?
In that case (components) the manufacturer comply with the generic directive (the one which applies to everyone): RoHs. When a product it's not compliant, it cannot be sold to an end user (i.e. mercury tilt switches are not available to the end user but companies can purchase them).

Following the attached chart you'll find the right destination of your device.

Quote
Or are Hobbiest not the norm?
I guess the difference is that hobbyst does not produce and sell an item in large scale.

EDIT: re-uploaded the attached image since it was only the preview...  :palm:
« Last Edit: August 20, 2014, 06:44:10 pm by mcinque »
 

Offline johnnyfpTopic starter

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #13 on: August 20, 2014, 08:15:41 pm »
So from that Diagram (Very nice by the way if you created it), If I produce a Wifi enabled Development board, that the end user is going pay with or incorporate in thier own project, then I will have to get it EMC/FCC certified.

Which means that all these addon boards/shields (Wifi, Bluetooth, Zigbee, Other RF) made by Adafruit, Sparkfun, Seeedstudio etc, they have all had to have been EMC/FCC certified?
 

Offline coppice

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #14 on: August 21, 2014, 02:58:37 am »
So from that Diagram (Very nice by the way if you created it), If I produce a Wifi enabled Development board, that the end user is going pay with or incorporate in thier own project, then I will have to get it EMC/FCC certified.
Well, in theory engineers working with unapproved RF designs are supposed to be working in screened rooms, so those RF designs can't disrupt legitimate users of approved products. Anything being used outside such a screened room should be approved, whoever is using it, and however it came to exist. In practice, of course, the use of screened rooms is very limited.
 

Offline Neilm

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #15 on: August 21, 2014, 06:46:14 pm »
Which means that all these addon boards/shields (Wifi, Bluetooth, Zigbee, Other RF) made by Adafruit, Sparkfun, Seeedstudio etc, they have all had to have been EMC/FCC certified?
They should have been certified to the standard they are designed to meet - it is just that when it is incorporated into a device the whole device then has to be re-certified as the complete unit.
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Offline mcinque

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #16 on: August 21, 2014, 07:10:38 pm »
So from that Diagram (Very nice by the way if you created it)
That IS NOT my job! It's inside the "Guide for the EMC Directive 2004/108/EC" document.

Quote
If I produce a Wifi enabled Development board, that the end user is going pay with or incorporate in thier own project, then I will have to get it EMC/FCC certified.
Definitely yes.

Quote
Which means that all these addon boards/shields (Wifi, Bluetooth, Zigbee, Other RF) made by Adafruit, Sparkfun, Seeedstudio etc, they have all had to have been EMC/FCC certified?
Yes, they MUST be certified. Seedstudio instruments like DSOnano, RFexplorer are CE/FCC certified (I've searched for their declaration of conformity).

The fact that many items probably does not have compliance and that noone recourse against the producer (or the seller, who is responsible for what he put on the market) is another matter.

Of course a document itself doesn't prove anything about the effective compliance, but since signing a paper saying a lie brings you much more troubles, I doubt that that devices weren't be tested properly and passed the compliance.

Nevertheless, many engineers firmly believe that since any compliance test it's valid only for the device tested (and NOT all the production, you can find it well written in any test report), testing a single item it's useless since it says very low about the entire production.

Of course, doing a test and pass the compliance will help you in any legal action you would be involved.

The very bad thing about the CE/FCC compliance is that you should have proper equipment to do a pre-compliance test in your lab, otherwise you could fail even at 1st try, wasting money (much money). That equipment is very expensive, and most important, you need also the proper knowledge to realize a perfect test setup and to read correctly the results.

Mee too must pass compliance tests for a device I'd like to sell, but is very expensive. And when you don't know how many items you will sell...
« Last Edit: August 21, 2014, 07:55:42 pm by mcinque »
 

Offline SirNick

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #17 on: August 21, 2014, 07:47:31 pm »
I do wish there were some sort of inexpensive pre-screening test.  One that is cheap enough to evaluate design decisions even for (determined) hobbyists.  Even if it would not provide compliance certification upon passing.. or did not conduct tests as thorough or rigorous.  Just to know if you have a prayer in passing the real thing.
 

Offline chicken

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #18 on: August 21, 2014, 07:59:18 pm »
I do wish there were some sort of inexpensive pre-screening test.  One that is cheap enough to evaluate design decisions even for (determined) hobbyists.  Even if it would not provide compliance certification upon passing.. or did not conduct tests as thorough or rigorous.  Just to know if you have a prayer in passing the real thing.

After having had the same thought, a bit of googling brought up this article series about DIY EMC testing:
http://www.compliance-club.com/pdf/EMCTestingPart1.pdf
Change the URL from 1-7 to get the other articles in the series, or register on the website and look for it in the archive.
 

Offline mcinque

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #19 on: August 21, 2014, 08:19:04 pm »
I do wish there were some sort of inexpensive pre-screening test.
Me too.

But - as example - when the speed limit is 50Km/h and you MUST know if your car is faster or not, you have to read its speed with a instrument.

With an inexpensive, uncalibrated instrument you can say with confidence if the car reaches 30Km/h or not, but you cannot trust the reading when the car speed is around 47Km/h. Your car could be at 52 or at 42 Km/h...

To have a "green light" you must use a precise, calibrated instrument, probably the same expensive device the test lab are using...  |O

Moreover, RF emissions are physical phenomenon that cannot be read correctly without a proper setup (anechoic RF chamber, calibrated antenna etc) because even with a good spectrum analyzer, FM radios and DVBT emissions make you blind in that frequencies; without a proper antenna with a "flat" response you cannot measure all the emissions linearly (the antenna could have much positive gain over some frequencies while having negative gain on others).

It's a PITA. Seriously. Kidding, the best thing to do is to power your device with batteries and close it on a sealed metal box. :-DD
« Last Edit: August 21, 2014, 08:20:37 pm by mcinque »
 

Offline johnnyfpTopic starter

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #20 on: August 21, 2014, 08:20:24 pm »
So I quized sparkfun about the CC3000 breakout board and it's certification,

Quote
Me:
Is this board fcc certified? Or is it just inheriting the certification from the cc3000 module?
 ShawnHymel(Sparkfun employee) / about 5 hours ago /  1
    It is inheriting the certification from the cc3000 module.

And they have loads of products in the similar catagory. So I suspect that Adafruit, sparkfun or any of these smaller firms (but a hell of a lot bigger than me) don't actually have the really expensive equipment and don't actually get anything certified, and they are still in business. Is that pure luck on thier part? Or more likely the fcc don't really care about small fish?
 

Offline mcinque

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #21 on: August 21, 2014, 08:28:43 pm »
That's exactly what I thought of that companies. But hey, a competitor could report a product of them to the authorities and they could be in troubles. If you run a business, would you accept this?

To have a good test lab, you'll need probably 10-11k $. not more. It's not a fortune for them. It's a fortune for me.

However, if Sparkfun are a small fish, I'm less than a plancton.

 

Offline johnnyfpTopic starter

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #22 on: August 21, 2014, 08:38:23 pm »
Single cell amoeba here  :-DD
 

Offline SirNick

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #23 on: August 21, 2014, 09:46:33 pm »
To have a "green light" you must use a precise, calibrated instrument, probably the same expensive device the test lab are using...  |O

Right, that's clearly true.  As such, I have my doubts that any DIY solution is going to be worth the trouble.  (Although it could possibly point out hot spots on your device.)

In an ideal world, I would like to see it work a little like some of the vehicle emissions places do.  "If you don't pass, you don't pay."  No (or little) cost to put your device on the table in front of the antenna, but if you want any certification of compliance, you have to pay up.  Could be quite the value-add business.

Just the chance to hand them your widget, and have some lab coat come out and say "you're about 10dB hot at 200MHz" would be incredibly valuable.  I'd pony up $200 for that.  If I wanted to know whether that's coming from the Ethernet jack or the main oscillator, I could pay a little more for a detailed survey.  That would be nice.

Makes me wonder if this business model could be exploited by the same kind of people who run OSH Park or OSH Stencils?  (Although I've never done this before... does the test facility even give you a certificate, or is it all scout's honor, like CE?)
 

Offline MagicSmoker

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Re: FCC/EMC/CE compliance, Product vs Kit, do I actually need it?
« Reply #24 on: August 21, 2014, 10:02:42 pm »
...
The electronic surplus shop I frequent get their supply from garbage bins of companies like Ball Aerospace, LM and Raytheon. They're seling all kind of potentially deadly stuff - for many years.

Not to veer too much off topic, but what surplus store is that? I may be a professional EE, but I love a good surplus store, probably because I got introduced to one that is fantastic when I was in my teens (and now I'm in my 40's, and the store is still around...): http://www.skycraftsurplus.com/index.aspx

If you are ever in the Orlando, FL, USA area (you know, to endure Disney, etc.) then you should definitely check out Skycraft.
 


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