EEVblog Electronics Community Forum
Electronics => Beginners => Topic started by: Fcolor04 on August 18, 2024, 10:22:37 am
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Hi, I am building many gizmos, but I'd like to actually sell things so it's self sustainable, I am aiming for audio products for now because they seem to have lowest barrier to entry. Where is the line where I should certify my products? Should I just print CE mark on it and worry about it when I sell a 100? 10 000?
Certification is not cheap and It'd be stupid to get my questionable product certified if I don't know if there's even market for it, what would you do? :-// I don't want it to bite me in the ass in the future
Technically easy option would be to sell kits right? I have hard time finding any guidance on this topic
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Boutique producers of audio gear in the UK often don't bother if they sell directly to the public. Obviously, it's a good policy to build to the minimum required standard even if you don't send the equipment for approval. Whether it's a totally legal loophole IDK.
One I know, sells his built products with an independent PAT safety certificate, which is not expensive.
Kits can be a very good way as you only have to make them minimal assembly to complete, and that then shifts the whole safety responsibilities to the customer, you just have to make sure your pre sale disclaimers are watertight.
You have to enter a whole world of regulation if you supply your products through third party sellers, though if you're successful and have the sales volume will save all the arse aches of dealing with customers.
It's up to you to check if this advice is applicable in your country.
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Certification doesn't cost anything but then you have to do it yourself!
If your supplying a mains powered product and are just going to stick a CE label on it without getting it certified you will be asking for trouble.
Im self certifying an RF product, sure its mains powered but Im not supplying the (48V) power supply.
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Just adding my 2¢ as I think this topic is worth some clarification.
The CE logo is in no way a certification declaration or indication. It is no more than an indication the manufacturer accepts being liable (should that be demanded) for the product, in conformance with European Regulations. So, technically, you could stick that logo to your products but then you must be able to provide the required documents that explicitly show your products conform with European Regulations. The logo is also required for a product to be sold within the European Economic Area.
See https://en.wikipedia.org/wiki/CE_marking (https://en.wikipedia.org/wiki/CE_marking) for more details.
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To start with: don’t get too stressed. See directive 2014/35 Annex I (https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0035#d1272e32-368-1) as an example of what horrible requirements you are facing! ;)
The CE mark is a declaration from you, not a certificate (attestation) from a third party. Basically you say “I don’t break the law.” And the regulations have to be obeyed regardless of this mark. Whether you put those two letters on your product or not, if your product is not conforming, you get smacked.
While in some product categories(1) involvement of authorities is required for conformity,(2) for most cases this isn’t true. Sometimes it may be more convenient or cheaper to just hire somebody to do the evaluation. But this is not a requirement: just your free choice, the same like deciding if you want to design it yourself or hire another person.
The Commission (https://single-market-economy.ec.europa.eu/single-market/ce-marking/manufacturers_en) has a small guide, that should clarify a bit, what you have to do. I suppose “Low voltage” is what you are interested in. Possibly also “Ecodesign of energy related products” and “Electromagnetic compatibility”.
(1) Like fertilizers and explosives.
(2) They still don’t give you any “CE certificate” or put CE marks on your product. The mark is still your declaration, which in that case includes saying “I contacted authorities as required by law”.
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That information is unfortunately outdated.
The CE marking rules have been tightened significantly (due to all the "smart guys" using contortions to avoid conforming).
Go to any of the EU directive pages, example EMC Directive:
https://single-market-economy.ec.europa.eu/sectors/electrical-and-electronic-engineering-industries-eei/electromagnetic-compatibility-emc-directive_en
Jump to section "Unregulated ceertificates warning" and read thoroughly.
The CE mark requires qualified backup from a notified body, at least for products in the EMC/RED/LV area.
Sorry guys, that "loophole" is closed. The only option is selling your stuff without a CE mark, which is a bad idea.
Or sell kits.
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Is there any example of CE marking enforcement being done?
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Is there any example of CE marking enforcement being done?
The focus is on volume products, of course.
Low-volume products won't be checked routinely.
But your life will be ruined if someone gets injured or even killed due to non-conformance with the LVD. Or if your non-conformant product oscillates and disturbs everyone in the neighborhood, or even worse, emergency services.
That's the real risk. And forget about liability insurance, you won't find any company that will cover it. People seem to forget about liability.
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That information is unfortunately outdated.
The CE marking rules have been tightened significantly (due to all the "smart guys" using contortions to avoid conforming).
Go to any of the EU directive pages, example EMC Directive:
https://single-market-economy.ec.europa.eu/sectors/electrical-and-electronic-engineering-industries-eei/electromagnetic-compatibility-emc-directive_en
Jump to section "Unregulated ceertificates warning" and read thoroughly.
The CE mark requires qualified backup from a notified body, at least for products in the EMC/RED/LV area.
Not true. Self-certification is still an option. The above seems to be certificates being issued in areas for which the issuer is not a notified body
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Placing CE marking may not help you in some cases. When there are 5-10 or more units in an international shipment, customs may inspect and request test reports for 2014/30/EU, 2014/53/EU etc directives. They usually don't care about CE marking. That is expected since every electronic product from all around the world have CE marking nowadays either legal or not.
Before sending your prototypes for testing, you may test some of the aspects with DIY methods. That may save money. Check the documents on this site:
https://www.emcstandards.co.uk/diy-emc-testing-series-2001 (https://www.emcstandards.co.uk/diy-emc-testing-series-2001)
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Is there any example of CE marking enforcement being done?
No recall I heard of, but that’s pretty expected. If you follow regulations, a missing CE mark is just a minor case of failing at formalities. Something to be fixed in the next batch. If you don’t follow regulations, then CE mark is the last thing authorities are going to be concerned with. It’s as if you stabbed somebody with a knife, but police was most interested in whether the seller placed the right “Made in” information on knife’s packaging.
Unless you ask if safety regulations, for which the CE mark is merely a declaration, are being enforced. Yes, they are, including product recalls. The main problem is not what happens after a detection, but the detection itself. People simply fail to or even actively refuse to exercise their freedom, which means many non-conforming items are in sale.
Placing CE marking may not help you in some cases. When there are 5-10 or more units in an international shipment, customs may inspect and request test reports for 2014/30/EU, 2014/53/EU etc directives. They usually don't care about CE marking. That is expected since every electronic product from all around the world have CE marking nowadays either legal or not.
They would do the same even if 1% of products had that mark. That’s because they are doing verification. If making a declaration on a packaging would be sufficient to convince border guard, every smuggler would write “this package contains no illicit drugs” on their shipments. ;)
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put a fuse on it and you should have the most peace of mind. The thing that you should worry about is fire, I assume its low voltage. That should bring it into any informal minimum standard. Oh and standoffs.
You will be up ahead of china if you put a fuse. The other stuff is usually pretty minor in comparison to fuses.
All the EMC crap etc, it does not hold a candle to the problem that can be caused by a electric fire.... a universal concern. A fuse says "I don't want this to start a fire"