EEVblog Electronics Community Forum
General => General Technical Chat => Topic started by: fuesel on February 17, 2019, 02:27:18 pm
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Hi,
Does every bit of commercial electronics in a car need certification? E.g. if I do not modify anything on the car and use only existing, user accessible connectors, do I need to have a full-fledged quality management system and company certification?
I want to build a simple datalogger for the CAN bus in a car, with some custom functionality behind it. The device is in a listen-only mode and when a specific message is sent over the CAN bus, something happens. Sorry for being vague, but I am currently investigating if there could be actual commercial interest behind it. If not, I will probably release it as open source (or trash it if it is a dumb idea). So bear with me.
Anyway, my background is in medical devices. There you need a QMS and a certification, which is obtained by following normative requirements and then being audited. Then you are allowed to either certify your device yourself or have it certified, depending on the class of the device. I imagine it being somewhat similar in automotive, which would mean that developing even a small product becomes very expensive. On the other hand, I cannot imagine that every OBD2 datalogger, every cigar lighter charger and other gadgets commonly used in cars are manufactured by certified companies. After all, they are plugged in into sockets which are accessible to everyone and are also meant to be accessible.
I am not afraid to read norms, so if someone could point me in the right direction I would already be quite happy.
Thank you!
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I'm in the not-California part of the US, which is about at the opposite extreme from Switzerland as far as certifying of things attached to cars.
That said, for anything that plugged into the OBD2 connector in the passenger compartment, I wouldn't even consider pursuing certification for it.
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I suggest at least reading the UN ECE R10 to check whether such a device could be in its intended scope.
You could start here: https://www.unece.org/trans/main/wp29/wp29regs1-20.html (https://www.unece.org/trans/main/wp29/wp29regs1-20.html)
If it is, I think self-marking is not possible.
One point to consider is also whether your product could have any impact on the vehicle's safety (I suppose not). Or whether it has any powered moving parts (in which case it would have to comply with the machinery directive), which again I guess not.
Otherwise your product will have to comply with the base EMC directive (2014/30/EU) and the general product safety directive (2001/95/EC), and related ones (RoHS directive, etc), and I see no reason you'd have to go through a notified body, so self-marking should be alright. This list is not exhaustive, if your product has got any radio link, it should also comply with the RED directive (2014/53/UE) which is a PITA. This is for the CE mark obviously but should get your started.
Then whether you have a QMS is up to you really. I'd suggest at least being ISO9001 certified, but I don't think it's even mandatory in your case. It does look better for your customers though.
From my understanding so far, a "scanner" device connected to a standard OBD2 plug should be considered outside of the scope of regulations for vehicles and vehicle components as long as it can be removed easily without any specific tool. Not knowing more about your project, of course I'd suggest asking a testing lab specialized in vehicles conformity as they will probably answer this much more accurately.
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Does every bit of commercial electronics in a car need certification? E.g. if I do not modify anything on the car and use only existing, user accessible connectors, do I need to have a full-fledged quality management system and company certification?
I want to build a simple datalogger for the CAN bus in a car, with some custom functionality behind it. The device is in a listen-only mode and when a specific message is sent over the CAN bus, ...
There are exemptions for test equipment, as it may not be made in volume, prove impossible to meet EMC standards etc.
Likely your datalogger meets the definition of test equipment.
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Thank you for your replies.
I will certainly check the UN ECE R10 and go from there. I am familiar with EMC and other directives for medical devices, so I really hope I do not have to go through this. The amount of money required just to go through with the tests in a reasonable time is crazy. Regarding safety, I think I can make a good point in my case as it is in listen-only mode and uses automotive components designed for interfacing with the CAN bus. I am also quite confident that I can show that my device is not safety relevant with an FMEA and risk mitigation.
The point about test equipment is a good one, I will investigate there as well.
Again, thank you for pointing me in a good direction. I might report back with some findings for others or with more questions, but we all have a day job as well ;), so it might take a day or two.
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Typical answer is: "When the customer or law requires it"
We cannot help you either way, as we dont know what the customer wants (typically they dont know either)
And we shouldn't tell you what is legally required from you, as this is a legal problem, and should be handled by a professional. You wouldn't want to go into jail because Steve123 on a forum said that you dont need to comply with something (sorry Steve).
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Typical answer is: "When the customer or law requires it"
We cannot help you either way, as we dont know what the customer wants (typically they dont know either)
And we shouldn't tell you what is legally required from you, as this is a legal problem, and should be handled by a professional. You wouldn't want to go into jail because Steve123 on a forum said that you dont need to comply with something (sorry Steve).
As mentioned, I am in medical electronics. I am completely aware of these legal issues and one cannot justify a decision with a forum post. Nevertheless, reading norms is always an interpretation. If your interpretation matches the one of the NB and the test house remains to be seen and it certainly helps if you can make a point that something is industry standard (whatever that means). What I am asking here is a pointer to the right direction, e.g. which norms exist and how to handle them.
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Everything that I have and that plugs in to the OBD II connector carries a CE sign.
So, I would think that at least you have to get a certification to be CE conform.
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IANAL etc - but I think it comes down to the type of equipment. Is it passive? (No). Does it connect to the vehicle's system in a way that might affect safety, e.g. brake failure? (possibly)
These might help:
https://www.unece.org/trans/areas-of-work/vehicle-regulations/agreements-and-regulations/un-regulations-1958-agreement/un-regulations-addenda-to-the-1958-agreement/old-version-of-regulations-pages/regs-1-20.html (https://www.unece.org/trans/areas-of-work/vehicle-regulations/agreements-and-regulations/un-regulations-1958-agreement/un-regulations-addenda-to-the-1958-agreement/old-version-of-regulations-pages/regs-1-20.html)
https://ec.europa.eu/docsroom/documents/16513/attachments/1/translations/en/renditions/native (https://ec.europa.eu/docsroom/documents/16513/attachments/1/translations/en/renditions/native)
One thing's for sure, you definitely can't self-certify.
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I haven't seen any certifications on the aftermarket car electronics I've dealt with. Bigger brands would do the usual CE/FCC like any other piece of electronics. Most parts that modify suspension or engine, etc. usually came with a "Off Road Use Only (wink wink)" note.....
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Hi all,
Sorry for the long delay. I found some answers and I want to post them here for posterity.
I called a guy from SQS, which is a notified body here in Switzerland. After briefly explaining what I intend to do, he asked me to whom I intend to sell to. After I told him it would most likely be B2C, at least in the beginning, he mentioned that this is no problem and does not require automotive certification. Certification is only necessary if you intend to sell parts to the big automotive companies as an OEM. And even there it is only because they force their suppliers to have these certifications at hand because, well, they can. My fundamental misunderstanding was, that opposed to medical devices, you do not need a certification to gain market access (actually you can, but how are you going to prove all you need to prove? In the end it is almost impossible to not be ISO 13485 certified).
However, this does not mean that you can do whatever you want, you still have to follow 2014/30/EU for EMC compliance or 2014/35/EU low voltage products and maybe 2006/42/EG Machine guidelines. But you might be able to self-certify in these instances. I could not do proper research there yet, but this is a question for antoher thread.
Cheers