Author Topic: Design to market  (Read 7234 times)

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Offline Macka

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Design to market
« on: April 06, 2012, 10:21:40 am »
Hi,

Something I've always wondered about (and has never come up at uni) is how does a design get to market.

Say I design some device/appliance and I want to sell it (in Australia or overseas), what needs to be done?
I'd assume it would have to meet EMC standards such as CISPR 14, but is there some other sort of certification required?

What if I wanted to design something to be hard wired into my own home such as an intercom, a light dimmer or home automation?
 

Offline Rerouter

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Re: Design to market
« Reply #1 on: April 06, 2012, 10:38:13 am »
this has actually been asked before without much clarification, but i shall clear atleast some points,

if you wanted to sell something, have a look through here http://www.productsafety.gov.au/content/index.phtml/itemId/970225

i havent actually read through it yet, but incase its just buerocratic circles, if it connects to the grid in some way, e.g. hard wiring, it will as a basic start have to comply by the australian wiring rules, the latest copy can be downloaded, but i will warn you, its large, and long, and covers just shy of everything to make a sparky not even give it a second thought.

 

Offline Macka

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Re: Design to market
« Reply #2 on: April 06, 2012, 11:57:46 am »
Information on this topic seems hard to find.

The product safety website lead me to this website: http://www.erac.gov.au/ (Electrical Regulatory Authorities Council) which seems to have some good info.

I may just have to tackle the Australian wiring rules someday anyway, so I suppose now is as good a time as any to at least start glancing over them.
 

Offline GeoffS

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Re: Design to market
« Reply #3 on: April 06, 2012, 12:03:51 pm »
You'll find that the Australian wiring standards (AS3000:2007) apply mainly to premises wiring i.e. fixed wiring, rather than to a plug in appliances.
 

Offline Rerouter

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Re: Design to market
« Reply #4 on: April 06, 2012, 12:57:39 pm »
yes but hard wiring, light dimmers and home automation are kinda entirely premisis wiring  :-\

also as a tip of the trade, if you design something to wire permenantly into mains around the the initial installation, try and build its input to handle a surge of 600V, meggers can be a PITA for home automation gear :D
 

Offline Bored@Work

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Re: Design to market
« Reply #5 on: April 06, 2012, 01:57:51 pm »
The sad answer is, if all else fails, contract a lawyer specialized in the field.
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Offline EEVblog

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Re: Design to market
« Reply #6 on: April 06, 2012, 10:59:02 pm »
What if I wanted to design something to be hard wired into my own home such as an intercom, a light dimmer or home automation?

In Australia, it took this guy several years to get his product manufactured and approved to market, with much $$$$$ and dicking around.
http://www.ecoswitch.com.au
And it's just an extension cord with a mains switch...

Dave.
 

Offline ejeffrey

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Re: Design to market
« Reply #7 on: April 06, 2012, 11:23:30 pm »
The sad answer is, if all else fails, contract a lawyer specialized in the field.

Contacting a lawyer is necessary at some point, and possibly even helpful, but definitely don't automatically trust your lawyer.  Do as much research as you can both before and after talking to a lawyer.  Try to figure out the answer both in theory (what do the rules actually say) and in practice (what do other manufacturers actually do, and how to the regulatory agencies interpret the rules).  This is really the only way to figure out if your lawyer is actually full of shit.  Lawyers who do tech are extremely specialized, and the ones who are really good charge enough to give you an aneurysm.  You will also find lawyers who do basic contract law and one helped the son of a friend submit a patent application for self defrosting eyeglasses, and is in over his head.  Unless you have a pretty good idea of what he is supposed to be saying, it is too easy to fall for a load of bull and not realize it until you get screwed at the 11th hour.
 

Offline Macka

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Re: Design to market
« Reply #8 on: April 14, 2012, 10:49:29 am »
In Australia, it took this guy several years to get his product manufactured and approved to market, with much $$$$$ and dicking around.
http://www.ecoswitch.com.au
And it's just an extension cord with a mains switch...

Dave.

That's really sad. From what I've read, he was/is an architect; do you think it would have been easier for him had he been an electrical engineer?

I am a bit surprised at the need for a lawyer, especially if no patent is required.
 

Online Psi

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Re: Design to market
« Reply #9 on: April 14, 2012, 10:58:59 am »
You can reduce your risks a bit if you use a pre-made and certified power supply.
That way nothing in your design deals with 230V mains.
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Offline steve_w

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Re: Design to market
« Reply #10 on: April 14, 2012, 12:01:54 pm »
Macka,

This is the applicable standard for NSW.  Firstly if its a declared article then there will be a specific  construction standard (safety) the declared articles are mainly for consumer stuff and dangerous stuff.  If its not a declared item and its electric then is must conform to AS3028 (??) or similar.  This standard is very lax and basically says the item must be electrically safe.   see here http://www.fairtrading.nsw.gov.au/Businesses/Product_safety/Electrical_articles/Approval_of_electrical_articles.html

Then there is the ACMA c tick / r tick.  If its considered a medium risk device then you have to get it tested.  This standard is mirrored in each state in Australia.   

AS3000 is not for manufactured goods its for wiring houses and the like so don't fall into the trap of trying to apply that.

The national standard for plant is the australian code of practice for safety in engineering it basically says that you must  identify hazards and control them in your design.  There is also a regulation in the WHS act to back that up.

hope this helps (I have copies of all these standards if you need a copy)

steve w
« Last Edit: April 14, 2012, 12:11:26 pm by steve_w »
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Offline bfritz

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Re: Design to market
« Reply #11 on: April 14, 2012, 04:33:48 pm »
This is a great question.  I don't know the market in Australia, but I do understand how this is done in the US and europe.  I would not be surprised to find that Australia is similar.  There is a good reason you don't find the information on the internet...

In the US, there are multiple requirments.

FCC will be the first we discuss.  The FCC has requirments for conducted and radiated emmissions.  Conducted emmissions are the RF energy transmitted via a line cord, back into the AC power system.  There is a testing method called out by the FCC.  The testing must be performed by an entity, that goes through a qualification process.  There are many vendors that can do this testing for you.  Google "Conducted Emissions Testing", and you will find many.  The big names that do this are UL and ETL (Intertek).  Radiated emissions testing is required if a device has certain components that may produce RF emmissions.  The FCC site gives rules on what devices must be tested.  Again there are qualified vendors who do the testing.  Google for them, but UL and ETL do this work.

Next is safety.  There are not necessarily requirments for safety for all devices.  But, if you produce an unsafe device, and someone decides to sue, you can be held liable.  Most companies get around this by complying to industry standards.  Also, certain devices, like those connected to the AC power distribution system, are often required to meet certain standards.  The US "incorporates by reference" these standards into the rules (laws).  Right now there are some people that are challenging this "incorporation by reference".  The issue is that standards bodies have used their manpower and experience to develop the standards, so to get access, you must pay.  The contention is that this produces "secret laws" where you must pay to find out what the laws are!  I expect that we are going to see some changes in the standards area in the years to come, as this has some basic problems.  The standards bodies need to get paid for their work, but the people need to have access to the rules / laws.  This makes meeting the rules rather difficult.

In a more practical sense, the best way to approach this, is to work with a company like UL or Intertek and have them review your design and give you a quote on what standards you would need to meet, and their fee for testing your design to those standards.  Their quote will then give you the list of standards you will need to buy, and understand for your device.  The good news, is that by going this route, when your design gets a safety mark, this ensures your design has met certain industry standard practices, and typically the safety agency will represent in court that your design meets those standards, which should go very far toward reducing any liability you may have.

As you can see, there are a number of hurdles.  By getting rid of designing the AC power supply, and choosing a device that meets conducted and radiated emissions, and carries such approval, you get rid of those testing requirments.

Then your device may need FCC testing.  You can determine if this is needed by looking at the requirments for your country, for radiated emissions, and RF transmitters / receivers.  These rules in the US are open, and for some devices no testing is required.  For many devices, testing is not that expensive, and may be a couple thousand dollars.

Safety is a bit more problematic.  If your device requires approval, as some building codes or laws reference standards, then you either buy the standards, and hope you don't misunderstand or misapply them, or you get someone else to certify your design.  If not stadards are required by law, you may still want the protection of the standards, in which case you buy them or work with a testing house, or you decide to incorporate so that your personal assets are protected, and only the corporate assets are at state, should a lawsuit occur.

Anyway, this is only part of getting a product to market.  Don't forget paying for material, shipping, tariffs, production, legal matters with who owns what at different points in the process, so that if something is damaged or lost, who is liable?

The good news is that if you have an idea, and can get some products to work, there are contract manufacturers that can either do or help with all this.

 

Offline Neilm

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Re: Design to market
« Reply #12 on: April 14, 2012, 07:38:24 pm »
If you want to export a product from Aus to the EU you will have to ensure it complies to the relevant EU directive. However, the good news is that the company that imports the product is the one responsible for getting the CE mark on the product.

This mark covers a multitude of different regulations depending on what product you produce - for instance if your product is test equipment it would not have to meet CISPR but IEC61326 which specifies not only the emissions but how much deviation from actual the product is allowed to have in immunity situations. (for instance radiated interference means the instrument should not go out of specification)

If you let the importer apply the CE mark then it may cause problems if your product has missed some small part of the appropriate standard. I was once given an instrument to test that claimed it was rated to 600V CATIV but it did not have sufficient clearance around the terminals. Indeed, one of the screws that held the PCB in place was between the legs of the surge arrestor and had less than a third of the required distance. This was such a fundamental flaw it could not be fixed and the product could not be placed on the market.

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Offline steve_w

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Re: Design to market
« Reply #13 on: April 15, 2012, 12:04:49 am »
Neilm

What you say is true, but in practice that is not how it works, we are trying to sell a product into Europe and the distributor says he can't sell it unless it has the CE mark.  The distributor says well when you have the CE mark give me a call.

A distributor cant get the CE mark without the "technical data file" which is the complete design, failure to have the complete design package in  Europe available for inspection by the govt authorities will get the distributor a nice big fine.  This has massive interlectual property  implications.

regards

SW

So long and thanks for all the fish
 

Offline EEVblog

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Re: Design to market
« Reply #14 on: April 15, 2012, 01:12:44 am »
That's really sad. From what I've read, he was/is an architect; do you think it would have been easier for him had he been an electrical engineer?

It may have prevented him being taken for a ride.
He told the story once, I'll have to dig it out, but from memory, he used some "invention" company that takes your idea to market and handle all that stuff, but he was screwed over and lost his money.

Dave.
« Last Edit: April 15, 2012, 01:14:40 am by EEVblog »
 

Offline EEVblog

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Re: Design to market
« Reply #15 on: April 15, 2012, 01:18:17 am »
Ah, found it. This is a quote from the EcoSwitch "inventor", from a post on Aus.Electronics in Sept 08:

Quote
Greetings all. I am the inventor of the eco-switch and thus take
responsibility for it taking so long to get to market.
Almost 2 years ago I engaged the services of a particularly well
connected agent to procure manufacturing on my behalf in China. Some 8
months later no tooling, no manufacturing and $25kUSD out of pocket
due to his unscrupulous business practices.
Subsequently I sought the services of another agent who's now taken
another 8 months to do not much more than repeatedly fail safety
testing and generally mismanage the entire project.
This has been the most risky and financially testing business I have
ever been involved with, and I caution all you inventive types out
there.
Anyway, your interests are fair and clear...when can we buy an eco-
switch?
The answer is...I hope early in the new year.
Sorry for the interminable delays, please trust me that I'm doing my
very very best. Beyond the eco-switch are other exciting inexpensive
energy abatement devices in development once this flagship product
gets up and out to you good patient people.
Please keep faith.
 

Offline Bored@Work

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Re: Design to market
« Reply #16 on: April 15, 2012, 09:12:07 am »
I am not a lawyer, but ...
distributor says he can't sell it unless it has the CE mark. 

That part is probably right, depending on the product, but ...

Quote
A distributor cant get the CE mark without the "technical data file"

No one gets a CE mark, as in applying for on and getting it granted. Instead the manufacturer or his authorized representative affixes the CE mark to a product when he is sure he has met all obligations regarding the usage of the mark. One such obligation, depending on the applicable directives, is the technical file.

But, the file is for the authorities on request. Not for the distributor. If you don't trust your distributor being your authorized representative, then use a trusted third party, for example a lawyer, as point of reference for the authorities.

Quote
which is the complete design,

No, only information required to demonstrate conformity, not more.
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Offline mikeselectricstuff

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Re: Design to market
« Reply #17 on: April 15, 2012, 01:06:40 pm »
Quote
But, the file is for the authorities on request. Not for the distributor. If you don't trust your distributor being your authorized representative, then use a trusted third party, for example a lawyer, as point of reference for the authorities.
But the distributor may require more info to make sure your CE mark is genuine, or at least that they can cover their arses that they took resonable steps to ensure it was[/quote]
 
Quote
Quote
    which is the complete design,

No, only information required to demonstrate conformity, not more.
This could be as little as a test house report and need not contain much valuable info
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Offline Bored@Work

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Re: Design to market
« Reply #18 on: April 15, 2012, 02:41:09 pm »
But the distributor may require more info to make sure your CE mark is genuine, or at least that they can cover their arses that they took resonable steps to ensure it was

Maybe, but I thought the formal declaration of conformity from the manufacturer or authorized representative, signed and all that, is supposed to serve that purpose. And if they pick a local, licensed lawyer as authorized representative and let him sign it ...

But of course, the distributor can ask for whatever they want. It is just strange that the distributer uses the CE marking as an excuse for their broad request.
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Offline Neilm

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Re: Design to market
« Reply #19 on: April 15, 2012, 05:47:36 pm »
But the distributor may require more info to make sure your CE mark is genuine, or at least that they can cover their arses that they took resonable steps to ensure it was

I can understand an importer pushing the CE marking requirement onto the manufacturer, but there is nothing to stop them from faking a test report or just sticking the CE mark on without producing any file. Then if there is a problem with the product and the lawyers get involved the importer will still be the ones responsible.

I worked for a company that re-badged and sold equipment as part of the business. When importing items from outside the EU we didn't care if the manufacturer had stuck a CE mark on it - we assessed each product. A good and comprehensive file with the required test reports was simply used as a good indication that the company we were dealing with was a competent and professional one. It was frightening how many were not.

Neil
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Offline gregariz

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Re: Design to market
« Reply #20 on: April 16, 2012, 06:49:03 pm »
Quote
But, the file is for the authorities on request. Not for the distributor. If you don't trust your distributor being your authorized representative, then use a trusted third party, for example a lawyer, as point of reference for the authorities.
But the distributor may require more info to make sure your CE mark is genuine, or at least that they can cover their arses that they took resonable steps to ensure it was
Quote
Quote
    which is the complete design,

No, only information required to demonstrate conformity, not more.
This could be as little as a test house report and need not contain much valuable info
[/quote]

My understanding is that distributors and individuals can assume responsibility for the CE mark if they want to sell in the EU - but many don't due to obvious reasons that they will be left having to represent the product if they are audited.

As of early next year ROHS will also be in effect part of the CE mark. Therefore you'll need some kind of documentation to prove there are no nasties in each component. but maybe a statement from the mfr would be enough to place in the file.

Here is the US interpretation of what you need now to market in the EU;

http://www.techhelp.org/upload/pdf/CE%20Mark.pdf


BTW if anyone knows of a decent reasonably cheap testlab in the far east that will test to FCC/EU/Aus standards I'd love the link.
 


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