CE and FCC compliance - Who the hell needs it, how much it costs, etc?

[mondalaci]

Hey Dave,

My friend and I are about to start a business - creating some pretty high-end consumer products for a niche market, more specifically for techies.  We have a lot to learn in every aspect but the topic I found the least information about is CE and FCC compliance.  I've found some information on the net but nothing too specific regarding the requirements, costs and such.

I wonder if you could take the time to create a kickass episode on this topic.

Cheers and keep it up!

Laci

[JohnS_AZ]

Don't forget UL certification.

[mondalaci]

Don't forget UL certification.

UL certification?  Some of my products (my Logitech mouse) has the UL logo but others don't.  What it is?  Is it required?

[JohnS_AZ]

UL (Underwriters Labs) is a product safety testing organization formed by US insurance companies a VERY long time ago. My understanding is that anything that plugs into a wall in the US needs to be UL certified, but I really don't know that for certain.

[jahonen]

Note that unlike UL etc. there is no such thing as CE certificate, you just have to have so called "technical file" and declaration of conformity about your product available on request and ensure that your product fulfills all relevant EMC, LVD and other applicable directives. In practice, you will want to do some EMC testing to ensure that your product will meet all the requirements.

Regards,
Janne

[Neilm]

Note that unlike UL etc. there is no such thing as CE certificate, you just have to have so called "technical file" and declaration of conformity about your product available on request and ensure that your product fulfills all relevant EMC, LVD and other applicable directives. In practice, you will want to do some EMC testing to ensure that your product will meet all the requirements.

Regards,
Janne

The technical file has to contain sufficient evidence of conformity to show in court that you have taken all relevant steps to comply with the directives. Some of the standards will define what is required, for example IEC61010-1 (the standard for test and measurement)says that a company has to produce a check-list to all the points in the standard. The new version that came out last year also requires a safety hazards analysis to try to predict misuse.

EMC tests are also covered by the CE mark. Personally, I would only not test if the Unit Under Test could be proven to be no problem - which for anything more complex than a resistor in a box could be quite difficult.  FCC compliance is the US body that is responsible for EMC compliance - although I believe they only regulate the emissions from your product.

As for who needs CE marking - the answer is simple. If you don't statements of conformity for your product you can't place it on the market within the European Union. If your product is found not to comply then the results could be anything from a fine to a mandatory product recall to jail time for the company directors responsible depending on the circumstances around the failure. The FCC are noted for monitoring the airwaves and have been known to issue mandatory recalls or prohibiting use of equipment in the event that it does not comply.

Your profile does not say where in the world you are so I can't be very specific, but in the UK there are recognised test houses that will do some / all the tests for you. The costs will depend on how much testing you have to do to meet the relevant standards. A day at an EMC test house in the UK costs about £1,000 depending on what equipment you are using and whether you need technician support. If you have no experience of EMC then a good technician is a MUST. 

For tips and advice on EMC compliance I would suggest going to http://www.compliance-club.com/ and checking out the articles on designing and laying out PCBs for EMC compliance.

Good luck on your new adventure.

Neil

[saturation]

IIRC one way around compliance requirements is to sell initially a product as a kit.  Full products to consumers requires a lot of hoops to jump through.

[Alex]

If you are selling as a kit, you dont need your regular commercial product certifications?

In that case where is the line drawn between kit and product?

[Chasm]

If you can get around rules by selling Kits depends very much on both your local laws and those were you are selling your product.
The first because they will get you sooner or later, the second because they will determine if you can sell your product legally.

Germany has very tight laws when it comes to electronics and for all practical value it is pretty much impossible to sell them without going the full way to create a company.

One of the biggest problem is the product liability. 10 years, AFAIK no matter if you sell a full product or just the PCB.

[mondalaci]

@JohnS_AZ:

UL seems to be a non-issue for us as we only plan to create USB driven hardware.

@Neilm, @jahonen:

Thanks for elaborating on the technical file, guys.  I'm from Hungary and I think I have some contacts who can let me know about such test houses and competent engineers.  Thanks for the link to http://www.compliance-club.com/ - I'll study that site for a while for sure.

@saturation, @Alex, @Chasm:

Yeah, I've heard about this "kits and development boards" category.  It's pretty interesting.  Take for example the Arduino.  They've distributed it without the CE and FCC mark but eventually managed to get those mark for the Uno.  I don't know why they needed the marks.

[qno]

It comes down to; Your product shall not disturb any other product and it should withstand disturbance transmitted by any other product.


There is a part that describes the radiation your product may transmit and a part that describes the susceptibility to electromagnetic fields your product must withstand without changing function.

Then there is safety, the user shall not be electrocuted while operating your product.
Then there is the manual that says what the product is intended for and how the user should use it and especially what NOT to do with the product.

That's about it.

[Neilm]

Then there is safety, the user shall not be electrocuted while operating your product.

Safety will also include not catching fire, not just electrocution.

If you want to use the USB logo you will have to comply with the USB standard. Also if you want a computer to recognise it you will have to get a VID and PID. There are separate threads on the options you have there. For more information see www.usb.org

Yours

Neil

[mondalaci]

Nelim:

A VID is surely gonna cost $2000.  Seems like it's not possible to avoid paying this fee.  Even if the MCU manufacturer provided a block under certain conditions it would be unprofessional and unpractical to use such a range for any final product as our VID-PID combo could clash with another product.

USB compliance is another question.  We don't insist having the USB logo immediately, but I wonder if it's required to USB certificate our products if we wanna distribute them.

[NiHaoMike]

Is there a legal problem with making up your own USB VID?

[mondalaci]

Is there a legal problem with making up your own USB VID?

I can imagine this being problematic when a company buys the VID in question and starts to use it.

[Neilm]

There are USB interface chip manufacturers that have bought a VID. They will then then assign PID to a company that buys their chip. I believe that FTDI do this but I'm sure others do as well. FTDI also supply the driver for the device so you will not have to worry about writing drivers for different operating systems.

If you don't want to do that you can use an interface chip and leave the VID and PID as the identifier for that interface chip. The worst affect of this would be your product identifying it with the name of another company when you plugged it in. It can also mean that the user has to install 2 drivers - one for the chip and one for the product.

You don't need to have the USB compliant logo in order to sell the product - the logo is simply there to say that if a product carries the logo it will always work. Products that do not carry the logo may not be compliant and might have problems working. The specification details even include which way up the logo faces when plugged in.

The best way of avoiding problems with USB is keeping the traces as short as possible between the connector and the interface chip or keeping it to the correct impedance if you can't.  The easiest method is keeping traces short.

Neil

[mikeselectricstuff]

Nelim:

A VID is surely gonna cost $2000.  Seems like it's not possible to avoid paying this fee.  Even if the MCU manufacturer provided a block under certain conditions it would be unprofessional and unpractical to use such a range for any final product as our VID-PID combo could clash with another product.

USB compliance is another question.  We don't insist having the USB logo immediately, but I wonder if it's required to USB certificate our products if we wanna distribute them.

Nobody is going to not buy a USB product because it doesn't have a logo. so the only issue in making one up is collision avoidance. The only USB compliance issue is customer hassle if it doesn't work, and even then there's a good chance it would be because of a crappy Chinese hub or out-of-spec cable - I've stripped USB cables and found ridiculously thin power conductors.
I'm not sure what arrangements other MCU makers have, but FTDI will allocate you a block of 8 PIDs for use with their products.
There is also someone selling individual PIDs. Someone else was doing this and got told off by the USB people & caved, however these people claim that they started before there was any restriction on reselling, and although the USB cartel have revoked the VID< there's no way they could reuse it.

I can imagine this being problematic when a company buys the VID in question and starts to use it.

That would be an issue between them and the people they bought it from. I doubt anyone could assert copyright over a 16 bit number...