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When is product certification required (or not!)

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steaky1212:
Hi,

I have been having a discussion with a colleague regarding the testing and certification requirements of a particular product.

Assume the product is battery powered, voltage under LVD, no pressure requirements, no ATEX requirements, intentional radiator (2.4GHz). Crucially, the device is not to be sold. Instead, it is to be issued to specific customers. This may be for a fixed term, or indefinitely.

His argument is that as the device is not sold, that it isn't subject to any specific certification. My argument is that it is put into service, at least outside of our premises, so the requirements apply.

Obviously different regions have different rules, so any experience/advice on UK, EU, and USA would be appreciated.

Many thanks,

steaky

Benta:
i can only speak for the EU. The term used is "putting on the market", which says nothing about selling, lending, leasing, for free etc.
It's out of your hands and it needs to be certified. If someone gets killed or injured because of a bad design, the designer/producer is responsible, free or not.
I've no idea what BoJo plans on this point, but AFAIK CE rules still apply in the UK.

jonpaul:
Any electronic devices shipped internationally may be inspected by import or export authorities.

Lack of compliance with emissions and safety can result in stopping the freight shipping, return to sender or seizures.

The intention to sell, give away or donation has no impact.

Jon

floobydust:
Is this safety or RF/EMC/communications certifications you wish to dodge?

A customer's insurance policy is invalidated if they use/install a product not conforming to safety standards.
You think your product is harmless but the battery can still be a source of fire/ignition. Is there a fuse, thick enough wiring, non-flammable plastics etc. these common-sense things are looked at during an evaluation/certification, which is one reason they are done.
It's too bad certification agencies are outrageously expensive and formal, as well as the access to safety standards-preventing entrepreneurs from making products, yet the chinese can export unsafe garbage to our countries unimpeded.

I would do the basic assessment of the product's possible hazards and if there are some... certification or at least special inspection would be needed.

janoc:

--- Quote from: floobydust on June 08, 2022, 07:57:40 pm ---Is this safety or RF/EMC/communications certifications you wish to dodge?

A customer's insurance policy is invalidated if they use/install a product not conforming to safety standards.
You think your product is harmless but the battery can still be a source of fire/ignition. Is there a fuse, thick enough wiring, non-flammable plastics etc. these common-sense things are looked at during an evaluation/certification, which is one reason they are done.
It's too bad certification agencies are outrageously expensive and formal, as well as the access to safety standards-preventing entrepreneurs from making products, yet the chinese can export unsafe garbage to our countries unimpeded.

I would do the basic assessment of the product's possible hazards and if there are some... certification or at least special inspection would be needed.

--- End quote ---

For the EU CE you can self-certify, no formal lab visit is required. Now whether that's a good idea depends ...

A battery powered flashlight is likely safe to self-certify, something that could cause interference, major fire or was dealing with mains - there it would be another story. One could still self-certify but should anything go wrong, you better have the paperwork ready showing your device isn't exceeding the applicable standards because if it does, false conformity declaration would bring you a lot of pain.

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