General > General Technical Chat
The path to commercial product
AndyC_772:
The problem is the risk that competitors will lodge a complaint and trigger a costly investigation. For most of us, the cost/benefit of buying a competitor's product and having it EMC tested with a view to complaining if it fails wouldn't be worth it - but for very high volume products in a competitive market, nobody can afford to be caught with their pants down.
I heard a cautionary tale from an EMC lab some years ago about a photocopier manufacturer, who performed routine testing on products coming off their production line for the sole purpose of ensuring they'd spot a compliance problem before any competitors did. They spent a fortune on testing, but it was still a very small sum compared to the total sales for that product - and one day they did actually find a problem: a brand new machine was broadcasting noise at a particular frequency. Turned out that one IC manufacturer had performed a die shrink and hadn't told anyone; the outputs of the new device had faster edges than the old one, resulting in more radiated noise.
calumk:
I am resurrecting this very old thread, to ask a follow up question, as i stumbled upon this thread from google, so i suspect others may do the same.
I am UK/EU Based, I have a degree in Mechatronics, and In my current role, I maintain & service & commission mainly 24v electropnuematic systems, conveyer belts, sensors, actuators, on educational equipment.... But I have no Legal 'Electrician' qualification - Similar I believe to how AndyC_772 described himself above.
It seems clear to me that for domestic or industrial installation, an electrical qualification is required, but I cant seem to find good information regarding the need for a qualification when designing a product for sale, and was wondering if anyone could provide any advice, or point me in the direction of further reading.
-
So, theoretically, if I am looking at designing a new 'product' from scratch, in which (for arguments sake) I would like to include an internal, DIN mounted, 240v power supply, or some other 240v components.
My question is not regarding how to do this safely, but is regarding the legal standpoint, without being a Qualified Electrician - Is this allowed?
Again, for arguments sake, assuming that I comply with the Machine and LVD Directives, use harmonised standards, test (or self test) the product, provide the documentation, and CE mark it, does the fact that I don't have an "electrician" Qualification, stop me from being the person who "designs" a product that uses 240v?
Presumably, there is a difference in whether a qualification is required, for a product that falls below the LDV 50v threshold.
My best guess, is that I assume that I could design and manufacture it myself, but that a Qualified Electrician would be required for the "test" aspect of the CE process?
As a further thought:
I assume the person actually assembling the product, does not require any specific qualification? As that would require all factory line employees in appliance factories to have a form of electrical qualification, which I feel is unlikely.
Cheers
tom66:
--- Quote from: funkimunky on November 01, 2012, 12:18:22 pm ---Kudos to you Thomas that must have taken a lot of bottle to make the jump. Its funny because I am also in software of sorts (web developer).
Say I wanted to handle all the power myself without using off the shelf power pack how does the testing process for (lets say uk) work. Is this done through via an official testing company or is it my neck on the line to assure that nothing is wrong with the product (I would hate for any products I make to hurt or endanger anybody).
I know that you can get public liability insurance for certain types of companies but I am guessing that this would only be possible if there was certain standards adhered to and certificates attained?
I'm not planning to do anything soon but I am just thinking of where I'd like to be. I am just starting out learning electronics (self taught using internet resources and Foundations of Analog and Digital Electronic Circuits by anant agarwal). I'm also a little worried that because I'm not going to get an electronics engineers degree and hence not be certified that this is going to cause real problems for me.
--- End quote ---
In the EU, which the UK is still involved in from a regulatory point of view, your neck is on the line, because you are the one that makes the certification that the device is compliant. UKCA, post Brexit :palm:, is likely to be similar ... although there has been little clarity on this from the government. You back up that assertion with testing or a desktop study. For instance a low power microcontroller product without a radio is likely to pass because comparable products pass. That is accepted under CE (but not under FCC if I recall correctly). A high power mains device will require testing as it is novel (excepting some common devices like luminaires which generally need to be made of fire retardant materials etc but otherwise don't require testing).
For the insurance it is likely that the insurer will want to know the product has been tested. Insurance companies make money by not paying out claims so make sure you get the full policy wording and give it a good read to see that it covers your circumstances. Declare everything relevant to the insurance company (and -DOCUMENT- that declaration; don't just phone it in and tell them, get it in an email).
EEVblog:
--- Quote from: calumk on June 09, 2020, 06:49:49 am ---It seems clear to me that for domestic or industrial installation, an electrical qualification is required, but I cant seem to find good information regarding the need for a qualification when designing a product for sale
--- End quote ---
There isn't.
But the product may have to comply with any regulations such as FCC (or UK equivalent) or electrical safety standards if it's mains powered.
--- Quote ---So, theoretically, if I am looking at designing a new 'product' from scratch, in which (for arguments sake) I would like to include an internal, DIN mounted, 240v power supply, or some other 240v components.
--- End quote ---
If you use and existing compliant mains rates supply then the safety regulations should be covered already. Provided no mains wiring of course, in which case you'd try and use an existing supply with integrated mains input IEC connector for example.
--- Quote ---Again, for arguments sake, assuming that I comply with the Machine and LVD Directives, use harmonised standards, test (or self test) the product, provide the documentation, and CE mark it, does the fact that I don't have an "electrician" Qualification, stop me from being the person who "designs" a product that uses 240v?
--- End quote ---
I'm 99.99% sure the answer is no.
Of course you'd want to have business product liability insurance.
nctnico:
--- Quote from: EEVblog on June 09, 2020, 11:10:58 am ---Of course you'd want to have business product liability insurance.
--- End quote ---
Which will be insanely expensive. A better (usual) approach is to create a limited liability company and make sure to certify the product to adhere to all the rules and regulations. Worst case the limited liability company goes belly up. As long as if there is no neglect and/or criminal intend your personal finances will be isolated from the company. In many cases companies which develop products are split into several entities. 1) holding(s) for primary share holders / owners, 2) holding for R&D where all the IP resides, 3) holding for selling products. Several of the companies I have worked for are structured this way.
See here for a more thourough explaination:
https://alainromanlaw.com/holding-company-structure/
Navigation
[0] Message Index
[#] Next page
[*] Previous page
Go to full version