I am looking for information about CE marking and trying to learn about the exemptions (for common, not special things) in the regulations; EMC, RoHS and low voltage. I wonder particularly if anything sold:
* not as a final product (such as an expansion board for an MCU board)
or
* as a kit (PCB+components)
is still covered by the directives. RoHS and low voltage is I think easy to figure out but not sure about the EMC.
The blue guide (2022/C 247/01) says the legislation applies to finished products but what is regarded as a finished product is defined in the specific legislation. A component, spare-part or sub-assembly can be classified as a finished product in the specific directive.
For the EMC directive, "kits of components to be assembled by radio amateurs and equipment made available on the market and modified by and for the use of radio amateurs are not regarded as equipment made available on the market.", and the directive does not apply to them. To me this sounds vague, I understand the point but still it is not clear what type of kits can be considered as such. But categorizing something under this which is not directly a radio-amateur equipment would not be OK.
Again for the EMC directive, evaluation kits and things regularly used for R&D (lab equipment etc.) is explicitly said to be covered, as well as components/sub-assemblies such as plug-in (computer) cards. I guess this means any evaluation boards (arduino/rpi/nucleo etc.), and expansion boards for these (plug-in card) and anything (even without an enclosure) used regularly for R&D purpose (like a signal/pulse generator on a PCB, not in an enclosure) is covered by EMCD. The electrical and electronic components, like transistors, are explicitly said to be benign and they are exempted. I do not understand if something sold as a kit (PCB+components) is exempted or not ? I do not understand how to classify something like this under this directive.
The Guide to EMCD document says, the components/sub-assemblies (not in a proper enclosure, probably to be fit into another product) are considered for EMCD if they are considered as "placed on the market". The latest blue guide has more information about "placing on the market" and it says the product is not placed on the market if it is "displayed or operated under controlled conditions (53) at trade fairs, exhibitions or demonstrations (54)" with the footnotes:
* (53) The prototype must be safe and under complete control and supervision. Controlled conditions would mean expert operators, restrictions to public contact with the product, avoiding inappropriate interaction with other neighbouring products etc.
* (54) However, in such circumstances a visible sign must clearly indicate that the product in question may not be placed on the market or put into service until it has been made to comply.
The footnotes are very relevant for the products I mentioned but it is for events (trade fairs, demos etc.) not for regular use. So I guess not applicable.
For RoHS 2, only the "equipment specifically designed solely for the purposes of research and development only made available on a business-to-business basis." is said to be exempted (for the purpose of my question, there are other things). This is pretty broad for B2B sales for R&D but RoHS is not hard to comply with anyway.
The low voltage directive applies to anything 50-1000Vdc and 75-1500Vac, so anything under 50Vdc, running with an external adapter etc. is out of scope for this one. So this directive is not applicable to most of the things I have in my mind (MCU based kits, expansions etc.) asking this question.
So my question is basically, is an expansion board (for example an stm32 nucleo expansion board) or a kit (of a simple signal generator or of a more complex eurorack synth module) exempt from EMC directive ?
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