Regulatory requirements for medium-scale manufacturing

[SpatialEffects]

Hello beautiful people!

I'm making PCBs for "physical games" -> escape rooms etc. Simple "shields" that click on to an existing dev board with an ESP32 on it, or onto a raspberry pi.

On these PCBs there's stuff like I/O expanders, ADCs, optocouplers, LED drivers, MOSFETs, level shifters to use addressable LED. All PCBs use a voltage up to max 24VDC. No CPU or power supply components are present on the boards.

I found the following resource:
https://predictabledesigns.com/understanding-certifications-for-electronic-hardware-products/

From this info, I deduce:

• My devices are classified under "Unintentional radiators" to the FCC (some components, like the IO expanders oscillate at higher freq than 9khz)
• Every separate device that I sell as a finished product has to be tested, but not submitted to the FCC (Supplier's Declaration of Conformity)
• UL can be complied with by using UL rated power supplies and wiring (no mains voltage would be going directly into my devices)
• CE rating seems kind of a self-certification?

What's still confusing to me:

• Can I avoid EM emission testing (costly) by selling the products as a kit or subassembly? (“subassembly” as defined by 15.101e of Title 47)
• Can I avoid EM emission testing because my devices are exempt under the following rule? (Title 47 → Chapter I → Subchapter A → Part 15 → Subpart B → §15.103) https://www.ecfr.gov/cgi-bin/text-idx?SID=e061b383491ff11ba22a84d29be96b73&mc=true&node=se47.1.15_1103&rgn=div8
• Can I avoid EM emission testing because there's no CPU or power supply components on my boards?
• Do my products have to be installed by licensed electricians? Or can anyone do it?

Input appreciated!

[Just_another_Dave]

• CE rating seems kind of a self-certification?

Yes, in most cases CE marking is a self-certification, being just necessary to add some required measurements in the user manual, as well as a conformity declaration in it and the CE logo on your product. The required tests can be found in the European directives that apply to your product

However, if your product needs to be tested by an external laboratory (I’m not familiar with FCC regulations), there are companies that prepare all the required documentation for selling your product in most companies

[AndyC_772]

The need for CE marking applies when you place a product onto the European market.

You may be able to make quite a strong case that your products are each individual, bespoke items, none of which are ever actually "on the market" unless you make and sell the same complete assembly to multiple customers. Even then, you may find that there's no test standard that actually applies to theatrical props.

Your products must nevertheless be safe, and that definitely requires care and attention given that they'll be in the hands of the general public.

[SpatialEffects]

I'm mostly interested in North American and European markets. I'd make around 15 different boards, all specialized for different sensors / buttons.

None of the boards are really a "one off" or a prop, it's more like a modular system: combine the boards you need for the game you have in mind. So I guess it would be "on the market".

It's just that... if I need FCC testing for all of them, it's going to cost at least $15000 already.

If I sell them as a kit, I think the customer has the end responsibility towards the FCC - But they might not want that.

[jonpaul]

Bonjour: If all the PCB are low voltage then safety compliance is minimal.

Compliance is Depending on the country they will be sold, type of  shielding, filters, and EMI sources,

You have both conducted and radiated.

You must weight the cost of compliance and testing with the total engineering and setup eg will you build 100 pcs or 100K pcs?

I would say the majority of such small boards are NOT built to comply even if the (Chinese) mfg put the CE mark.

Survey the market for similar devices and see what the other competitors are doing.

Rather than rely  on second/third hand info like the website link, I would do research especially from the compliance standards applicable to the product.


Bon Chance


Jon