EEVblog Electronics Community Forum
General => General Technical Chat => Topic started by: Cside on August 11, 2014, 04:48:28 am
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Hi guys
Long time viewer of EEVblog videos but never posted.
I have a bizarre question. I have recently gone professional in my business designing smaller machines for customers. I have a background in science/engineering but always worked for myself in some way so I have no real knowledge of EE certification. I am mostly concerned about selling a product that may require some form of certification which I have not done. I know there are some stricter rules which apply for anything with higher EMF generation for example.
Anyway I would really appreciate a push in the right direction on where info exists on the subject. Dave has not posted any videos on the topic as far as I am aware.
Boring topic i know.
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To answer this question usefully, we'll need to know where you're located, what type of product it is you're looking to sell, and which countries you're looking to sell into.
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Thanks
I am in Australia.
My products are usually mechanical/mechatronic in nature simillar to parking meters, active display cabinets, vending machines and the like.
The only PCB's I ever design are low voltage (<12V), either as sensor boards and mpu/mcu/fpga powered devices.
The problem is that most of my projects - up untill recently - have been very small production runs for purposes which are totally off the radar and hence I haven't bothered with compliance but this cannot go on, Moreover I want the peace of mind to know that everything is compliant. However I am a tiny fella on a budget which complicates the issue.
The machines will probably go international judging from the enquiries received, but I would be mostly concerned with Australian compliance. I am not a certified EE which amplifies my paranoia about unkown unkowns.
I would definately prefer to have my own certification but not being a certified electrical engineer makes this unpractical
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Sounds like you'll need some local advice as to what rules apply in Aus, I'm afraid.
Here in Europe there's no such thing as a 'certified' electronic engineer - at least, not in a legal sense as far as regular industrial, commercial and domestic products are concerned. Anyone can make and sell a product provided it's CE marked.
Be aware that the costs of demonstrating compliance are not insignificant, and there's no good 'cheap route' to compliance other than not bothering at all and hoping you get away with it. This can, and does, prevent the 'little guys' getting products to market.
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As someone who is an electrical engineer in Australia, it doesn't mean jack in terms of electrical safety law (in QLD anyway). The only real protected class is those with an electrical work license, and if you try to do some of the training, no one will even listen (yes, I tried ;) ) unless you are signed up to be an electrician apprentice for 4 years. If you are a chartered engineer (I don't think it actually says anything about "electrical") then you can sign off on big government projects.
But I have talked with the state government about this, and my very basic understanding is that as long as you don't touch fixed wiring, anyone can do anything as long as it is "part of your profession" in an "OH&S certified workplace". So people with no degree or anything can build electronics that plugs into the mains, so long as these are in place. This makes sense, because no business could afford to pay electricians' rates to do basic pcb assembly. I never fully went down this path, because the law around this area is both very clear and extremely confusing at the same time (I don't really know how else to explain it!) so I decided it wasn't worth it.
In terms of certification for your device: you should be able to dodge a lot by buying pre-certified components. For example, power supplies are fairly easy to get that already come with C-Tick (that's us), UL from the US, CE from Europe and TUV from Germany. Just be careful as some cheap chinese outfits are known to forge these numbers.
of course: IANAL, don't quote me, YMMV, etc
I hope this unconfused you more.
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Thans Andy and Jeremy
Jeremy I think you answered more questions than you realized. I always used OTS power supplies when connecting to mains, to at least 12VDC if not lower. Once there, some simple pcbs with processors.
I'm very careful with production and design there is no way that I can see any safety problems even remotely being an issue, but still I am not sure if I still need to do some certification testing. I just dont want to sell a product at some point in the future, where a savvy user notcies "Hey, this hasn't got the FingyBob sticker, Im going to sue them for no reason other than I can".
As for safety for users, Never is an issue.
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If you're selling into Europe, it's not end customers that will take action against you, unless your product actually causes damage or bodily harm.
What they - or your competitors - might do is complain to the local Trading Standards or equivalent authority, whose job includes enforcement of the CE marking regime. They in turn might request a copy of the Technical File which you're required to keep, but since you're not actually based in Europe yourself, in practical terms the worst I can see happening even if you don't have one is that your products will be stopped in Customs.
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Here in Europe there's no such thing as a 'certified' electronic engineer.
Maybe, but there are plenty of electronic engineers there who are certifiable. :)
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If you're selling into Europe, it's not end customers that will take action against you, unless your product actually causes damage or bodily harm.
What they - or your competitors - might do is complain to the local Trading Standards or equivalent authority, whose job includes enforcement of the CE marking regime. They in turn might request a copy of the Technical File which you're required to keep, but since you're not actually based in Europe yourself, in practical terms the worst I can see happening even if you don't have one is that your products will be stopped in Customs.
I am not trying to avoid necessary certification though, I am however trying to learn exactly what is the minimum certification, and what are the requirements for certification in house. I just hate outsourcing anythign.
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I just hate outsourcing anythign.
Why? This sounds like a perfect opportunity to outsource to genuine experts leaving you with more time to develop the next product (which,it seems, is your skill).
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I just hate outsourcing anythign.
Why? This sounds like a perfect opportunity to outsource to genuine experts leaving you with more time to develop the next product (which,it seems, is your skill).
Outsourced compliance testing may also help protect you better from a liability standpoint vs. in-house certification (may also qualify you for lower liability insurance premiums). Certainly worth checking into IMHO.
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If you're selling into Europe, it's not end customers that will take action against you, unless your product actually causes damage or bodily harm.
What they - or your competitors - might do is complain to the local Trading Standards or equivalent authority, whose job includes enforcement of the CE marking regime. They in turn might request a copy of the Technical File which you're required to keep, but since you're not actually based in Europe yourself, in practical terms the worst I can see happening even if you don't have one is that your products will be stopped in Customs.
As I understand it, it depends on how the product is getting to Europe. The company responsible for the certification is the company that is placing the product on the market. So if the product from company A is sold to a 3rd party (company B) who then sell it in Europe Company B is the one responsible for ensuring compliance.
One question for the OP - are they complete units or sub assemblies? Sub assemblies have somewhat relaxed requirements, you would have to look at the relevant specs. I don't have too much experience with sub assemblies as I generally end up testing full system.
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If you're selling into Europe, it's not end customers that will take action against you, unless your product actually causes damage or bodily harm.
What they - or your competitors - might do is complain to the local Trading Standards or equivalent authority, whose job includes enforcement of the CE marking regime. They in turn might request a copy of the Technical File which you're required to keep, but since you're not actually based in Europe yourself, in practical terms the worst I can see happening even if you don't have one is that your products will be stopped in Customs.
As I understand it, it depends on how the product is getting to Europe. The company responsible for the certification is the company that is placing the product on the market. So if the product from company A is sold to a 3rd party (company B) who then sell it in Europe Company B is the one responsible for ensuring compliance.
One question for the OP - are they complete units or sub assemblies? Sub assemblies have somewhat relaxed requirements, you would have to look at the relevant specs. I don't have too much experience with sub assemblies as I generally end up testing full system.
guys I have no plans for Europe.
These units are complete unfortunately.
The reason I dont like outsourcing is because businesses charge far-too much. Especially compliance testing. Businesses are out for blood hence I prefer to keep inhouse.
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As I understand it, it depends on how the product is getting to Europe. The company responsible for the certification is the company that is placing the product on the market. So if the product from company A is sold to a 3rd party (company B) who then sell it in Europe Company B is the one responsible for ensuring compliance.
That's my understanding too - though if company B is just a box-shifting reseller, they'll contractually pass the burden of demonstrating compliance straight back to the manufacturer.
The reason I dont like outsourcing is because businesses charge far-too much. Especially compliance testing. Businesses are out for blood hence I prefer to keep inhouse.
I'm afraid you might be surprised at just how straightforward and possible this isn't.
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As I understand it, it depends on how the product is getting to Europe. The company responsible for the certification is the company that is placing the product on the market. So if the product from company A is sold to a 3rd party (company B) who then sell it in Europe Company B is the one responsible for ensuring compliance.
That's my understanding too - though if company B is just a box-shifting reseller, they'll contractually pass the burden of demonstrating compliance straight back to the manufacturer.
The reason I dont like outsourcing is because businesses charge far-too much. Especially compliance testing. Businesses are out for blood hence I prefer to keep inhouse.
I'm afraid you might be surprised at just how straightforward and possible this isn't.
I know just enough physics and enough real life experience to understand how much more difficult testing - with confident results - is. But like any niche-market industries there are high inefficiencies - because they can. So it may not be cheap but It shouldn't require a mortgage.
Anyway ive done enough research now to realize how ignorant my above question was and I apologize for the stupid question.
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i tried to ask Daves personal opinion on this, hasn't responded, but I F&^*^&$ hate Australia's method of certification. It is unusually slow and extraordinarily expensive. Now that the CSIRO, the main test house is reducing staff the process will take even longer.
One of my distributors has tested a smoke alarm worth about $15.00 to $20.00 in the general market with a special modification for enhancement and charged nearly $15,000 plus took 18 months to receive compliance. >:(
No wonder things in Australia cost so F&#^*%^ much.
If you haven't figured this out this is my pet hate >:(, along with patents.
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Yeah exactly and they wonder why no one makes things here anymore.
There are so many great talented young minds that are prohibited from building their own successful projects. This forces most to work for the man, so sad.
I am looking into the consequences of open sourcing everything, and thus only providing "assembly" service or some variant of that.
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i tried to ask Daves personal opinion on this, hasn't responded, but I F&^*^&$ hate Australia's method of certification. It is unusually slow and extraordinarily expensive. Now that the CSIRO, the main test house is reducing staff the process will take even longer.
One of my distributors has tested a smoke alarm worth about $15.00 to $20.00 in the general market with a special modification for enhancement and charged nearly $15,000 plus took 18 months to receive compliance. >:(
No wonder things in Australia cost so F&#^*%^ much.
If you haven't figured this out this is my pet hate >:(, along with patents.
How does it work in Oz for testing of devices? Does the CSIRO have to test/approve electronic devices for sale in Oz, or is CE or UL considered an equivalent mark and automatically approved? Nothing against Australia, but it's just not a big enough market for most companies to bother having products certified for sale there, I'd think. I know a lot of smaller countries will just accept approval marks of other nations. So, for example, Bosnia won't have their own testing authority but will just accept CE marking even though they are not part of the EU.
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You're probably ok on safety but the part that could bite you is EMI compliance.
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i tried to ask Daves personal opinion on this, hasn't responded, but I F&^*^&$ hate Australia's method of certification. It is unusually slow and extraordinarily expensive. Now that the CSIRO, the main test house is reducing staff the process will take even longer.
One of my distributors has tested a smoke alarm worth about $15.00 to $20.00 in the general market with a special modification for enhancement and charged nearly $15,000 plus took 18 months to receive compliance. >:(
No wonder things in Australia cost so F&#^*%^ much.
If you haven't figured this out this is my pet hate >:(, along with patents.
How does it work in Oz for testing of devices? Does the CSIRO have to test/approve electronic devices for sale in Oz, or is CE or UL considered an equivalent mark and automatically approved? Nothing against Australia, but it's just not a big enough market for most companies to bother having products certified for sale there, I'd think. I know a lot of smaller countries will just accept approval marks of other nations. So, for example, Bosnia won't have their own testing authority but will just accept CE marking even though they are not part of the EU.
Everything *has* to have a C-Tick logo on it. I'm not sure as to whether or not you can pay some money to transform your UL into a C-Tick.
I know that for medical stuff, having FDA approval fast tracks your TGA approval (the Aus equivalent), but it isn't instant.
Also, correct me if I am wrong, but CE stuff can be "self-certified", meaning that you take on the liability of the product yourself but you can otherwise just put the mark on (I think mikeselectricstuff said that one). This is not the case for c-tick, UL or TUV.
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Anyone can design main powered devices, however:
You should exercise due diligence in your designs.
Read and know safety standards, like UL-60950.
Perform risk analysis and an FMEA on your device and document all of this.
Consider public liability insurance, although it has become a ripoff in Australia. Nothing beats due diligence.
The most important benefit of being an EE is helps you get a job and teaches you about control theory (the "key" to good design), but you won't become a chick magnet with an EE degree.
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Anyone can design main powered devices, however:
You should exercise due diligence in your designs.
Read and know safety standards, like UL-60950.
Perform risk analysis and an FMEA on your device and document all of this.
Consider public liability insurance, although it has become a ripoff in Australia. Nothing beats due diligence.
The most important benefit of being an EE is helps you get a job and teaches you about control theory (the "key" to good design), but you won't become a chick magnet with an EE degree.
This is total nonsense. I think you should do your reasearch before you make a comment like that and make a fool of yourself on the public forum. Everybody here knows and it totally goes without saying that all the hottest chicks go for electrical engineers ;)
sorry bad joke. As for the Ctick issue, Ive seen products on the market simillar to the type of work I do - niche and small market - with Cticks on them. This confuses me because the cost I presumed would ouweigh any profits made. Are people faking these Cticks?
I would imagine commercialising a product without compliance may bare a heafty penalty, but faking a Ctick would be outright criminal. Yet unless I have misunderstood the costs involved I cannot see how it would be economical for said products.
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AFAIK the two main things you need to comply with are electrical safety and EMC.
Safety, which IIRC is the Australian copy of UL-60950. (actually i dug it out it is AS/NZS 60950).
Radio compliance to which apparently these documents apply.
]http://www.acma.gov.au/Industry/Suppliers/Equipment-regulation/EMC-Electromagnetic-compatibility/emc-standards-list] (http://www.acma.gov.au/Industry/Suppliers/Equipment-regulation/EMC-Electromagnetic-compatibility/emc-standards-list)
You can email ACMA if you can wait for the turn around they can actually be quite helpful.
I just got something through radio compliance it is not that hard, but it does cost if it needs testing, and some things do. If it will qualify for FCC rules you are in with a good chance as we seem to lift most of our standards from them. The big exception being some of the frequencies.
BTW there is a new unified compliance mark which is a CTick inside a triangle.
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Thanks for the information. i will consider the self certification, but as some may have heard already 2 people are dead due to failed compliance chargers from China, so the idea of compliance is still fresh in my mind, but the cost of actual compliance is still an issue.
Quite a few years ago i want to build a product for the deaf but after checking the compliance cost I had to abandon it. Cost projection placed it was out of market potential.
I have quite a few ideas but if full compliance is sought by the the government then there is no way i could afford it.
ACCC may be more supportive of communication as the past I have had a terrible experience. Basically no self compliance was on the cards, i suppose it depend on the person you speak to initally.
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self compliance?
Are you talking about Ctick yourself?
isn't that punishable by death?
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Anyone can design main powered devices, however:
You should exercise due diligence in your designs.
Read and know safety standards, like UL-60950.
Perform risk analysis and an FMEA on your device and document all of this.
Consider public liability insurance, although it has become a ripoff in Australia. Nothing beats due diligence.
The most important benefit of being an EE is helps you get a job and teaches you about control theory (the "key" to good design), but you won't become a chick magnet with an EE degree.
This is total nonsense. I think you should do your reasearch before you make a comment like that and make a fool of yourself on the public forum. Everybody here knows and it totally goes without saying that all the hottest chicks go for electrical engineers ;)
sorry bad joke. As for the Ctick issue, Ive seen products on the market simillar to the type of work I do - niche and small market - with Cticks on them. This confuses me because the cost I presumed would ouweigh any profits made. Are people faking these Cticks?
I would imagine commercialising a product without compliance may bare a heafty penalty, but faking a Ctick would be outright criminal. Yet unless I have misunderstood the costs involved I cannot see how it would be economical for said products.
OK, on your comment on engineers attracting hot chicks... :bullshit:, but it depends on what a hot chick is. How often do you hear in the media the likes of, "Kylie Minogue snapped by the paparazzi, leaving her local electronics store arm in arm with her new FPGA designer beau." or "Kim Kardashian with a new life as a PCB layout designer, dumps her boyfriend for an ace debug technician".
The government has lost control on C-Tick enforcement and the RCM mark. I can buy stuff in the local cheap imports shop that does not have C-tick compliance. I can import crap on eBay that does not have compliance.
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Anyone can design main powered devices, however:
You should exercise due diligence in your designs.
Read and know safety standards, like UL-60950.
Perform risk analysis and an FMEA on your device and document all of this.
Consider public liability insurance, although it has become a ripoff in Australia. Nothing beats due diligence.
The most important benefit of being an EE is helps you get a job and teaches you about control theory (the "key" to good design), but you won't become a chick magnet with an EE degree.
This is total nonsense. I think you should do your reasearch before you make a comment like that and make a fool of yourself on the public forum. Everybody here knows and it totally goes without saying that all the hottest chicks go for electrical engineers ;)
sorry bad joke. As for the Ctick issue, Ive seen products on the market simillar to the type of work I do - niche and small market - with Cticks on them. This confuses me because the cost I presumed would ouweigh any profits made. Are people faking these Cticks?
I would imagine commercialising a product without compliance may bare a heafty penalty, but faking a Ctick would be outright criminal. Yet unless I have misunderstood the costs involved I cannot see how it would be economical for said products.
OK, on your comment on engineers attracting hot chicks... :bullshit:, but it depends on what a hot chick is. How often do you hear in the media the likes of, "Kylie Minogue snapped by the paparazzi, leaving her local electronics store arm in arm with her new FPGA designer beau." or "Kim Kardashian with a new life as a PCB layout designer, dumps her boyfriend for an ace debug technician".
The government has lost control on C-Tick enforcement and the RCM mark. I can buy stuff in the local cheap imports shop that does not have C-tick compliance. I can import crap on eBay that does not have compliance.
Lots of beautiful engineering women, havent you ever seen star trek ?
true. But I still want to be above board so long as its possible.
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Lots of beautiful engineering women, havent you ever seen star trek ?
true. But I still want to be above board so long as its possible.
OK, princess Leia from Star Wars. She fell in love with me and my 10X oscilloscope probe. And I fell in love with her 8-ohm impedance headphone hairstyle. And then I woke up.