Author Topic: CE Marking Directives and standards.  (Read 3519 times)

0 Members and 1 Guest are viewing this topic.

Offline Siwastaja

  • Super Contributor
  • ***
  • Posts: 8110
  • Country: fi
Re: CE Marking Directives and standards.
« Reply #25 on: March 24, 2023, 03:57:42 pm »
Unfortunately not the case, you have to do both EMC and RED for a product with radio functionality.

Again in tldr: EMC as generic term is always needed. As a directive name, if RED applies then the RED contains the EMC stuff.
 
The following users thanked this post: bookaboo

Online SiliconWizard

  • Super Contributor
  • ***
  • Posts: 14309
  • Country: fr
Re: CE Marking Directives and standards.
« Reply #26 on: March 24, 2023, 09:58:56 pm »
Yes. If there is any radio in your product, you must comply with the RED directive.
Even if you use a ready-made radio module that claims to be "compliant". A very common source of misconception.

A module once integrated in a device can't be compliant by itself or make the whole device compliant. Unfortunately. (But that's relatively easy to understand if you know something about EMC.)

There's an exception to that, if said module can be installed or uninstalled as an addition by the end-user, in which case showing compliance is much easier.
But if the module is permanently attached to the device, you'll pretty much have to do all the testing. In short.
 

Offline Siwastaja

  • Super Contributor
  • ***
  • Posts: 8110
  • Country: fi
Re: CE Marking Directives and standards.
« Reply #27 on: March 25, 2023, 09:47:33 am »
Yes. If there is any radio in your product, you must comply with the RED directive.
Even if you use a ready-made radio module that claims to be "compliant". A very common source of misconception.

Yeah. It's grey area if you could skip some of the radio measurement parts of RED, if you can get testing reports from the module manufacturers. But definitely you need to still comply and test for everything else in the RED. Savings from skipping a few radio measurements are not that significant anyway.
 

Online popeTopic starter

  • Frequent Contributor
  • **
  • Posts: 275
  • Country: pl
Re: CE Marking Directives and standards.
« Reply #28 on: March 25, 2023, 09:35:51 pm »
So unless you go through thousands of pages or paying a little fortune there's no way to know what directives and standards should be applied right? I mean some kind of an EU online tool or free EU service that can give you a responsible answer. Lobbying at its best...

Figuring out the directives is usually not that hard, as was stated earlier, this page lists all CE directives (product groups): https://single-market-economy.ec.europa.eu/single-market/ce-marking/manufacturers_en
(and just to be clear, the small fortune you pay mostly for the actual testing and there is really no way around that)

I am assuming the electronic device you are building is not:
- a medical device
- part of a machine (moving parts)
- a toy
- used in explosive atmospheres
- a regulated measuring device (like an electricity meter)

Then you are left with:
- either EMCD and LVD or
 RED (if it has a radio transmitter/receiver)
- RoHS
- potentially Ecodesign (certain consumer/household equipment, list is here (Annex I) https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32008R1275)

From what you told us, you will probably end up with EMCD, LVD and RoHS. Now for the standards.
- Here is the list of all EMCD harmonised standards: https://ec.europa.eu/docsroom/documents/51314
The rule is to pick the most specific standard that applies to your product. There probably isn't one specifically for your niche product, so the most likely case is that you use one of the product family standards, like:
EN 55022/55024 Information technology equipment
EN 55032/55035 Multimedia equipment
EN 55103 Audio, video, audio-visual and entertainment lighting control apparatus for professional use
EN 61326 Electrical equipment for measurement, control and laboratory use
If none of the family standards apply, you would fall back to the generic EN 61000 standards. Note that the more specific standards refer to those in any case, they usually just contain additional information on how to apply them (test setups, what limits to test to and so on).
- Now for LVD: https://ec.europa.eu/docsroom/documents/53895
This list is annoyingly long, fortunately most of it is cables, electrical installation material and houeshold appliances. Again, a lot of products will use product family standards, in particular:
EN 60950 Information technology equipment
EN 61010 Electrical equipment for measurement, control, and laboratory use
EN 62368 Audio/video, information and communication technology equipment
- RoHS is essentially about collecting the right paperwork on your suppliers and components. There is currently only one harmonised standard, EN IEC 63000:2018.

Unfortunately not the case, you have to do both EMC and RED for a product with radio functionality.

You are both right (kind of). The EMC and LV directives do not apply to radio products but the RED includes most of the requirements from both. So only RED appears on the declaration of conformity, however you still need to do all the tests.

On the topic of "creative loopholes" I will just say that EU regulators are not stupid. Case in point, this is the actual wording in the LVD on the declaration of confirmity:
"The EU declaration of conformity shall state that the fulfilment of the safety objectives referred to in Article 3 and set out in Annex I has been demonstrated." (emphasis mine) You are also required to create and keep technical documentation on this and may be asked to produce it later on (though usually only if something goes wrong). The LVD also does not mention the word "prototype", the question is rather whether the product has been "placed on the market" (which is usually not the case for a genuine prototype). So in any case, take legal advice from random guys on the internet with just a tiny grain of salt...

Thank you. Very informative post.

Do you whether different EU countries require different standards or variations of the same standard?
 

Offline Benta

  • Super Contributor
  • ***
  • Posts: 5840
  • Country: de
Re: CE Marking Directives and standards.
« Reply #29 on: March 25, 2023, 11:51:32 pm »
Do you whether different EU countries require different standards or variations of the same standard?
All EU countries (and associated trade zone countries like CH, N, etc.) adher to the same standards. If your product is OK in one member state, it's certified for all others.
That's the beauty of standardisation.
 

Online popeTopic starter

  • Frequent Contributor
  • **
  • Posts: 275
  • Country: pl
Re: CE Marking Directives and standards.
« Reply #30 on: March 26, 2023, 10:47:09 am »
Do you whether different EU countries require different standards or variations of the same standard?
All EU countries (and associated trade zone countries like CH, N, etc.) adher to the same standards. If your product is OK in one member state, it's certified for all others.
That's the beauty of standardisation.

Thank you. I'm asking because I have the impression that I read somewhere that there can be some slight differences on the standards between EU countries. Or perhaps, that there are specific versions of each standard? Can't remember exactly.

On a similar note, from what I understand you don't have to follow the whole standard's procedure but parts of it depending on your product. Is this correct? 

Again, I realise that I would get the best answers from a consulting company but I would like to have a good idea before going down this road.

Thank you all for the replies!  :-+
 

Offline Neilm

  • Super Contributor
  • ***
  • Posts: 1545
  • Country: gb
Re: CE Marking Directives and standards.
« Reply #31 on: March 27, 2023, 06:39:53 pm »

Thank you. I'm asking because I have the impression that I read somewhere that there can be some slight differences on the standards between EU countries. Or perhaps, that there are specific versions of each standard? Can't remember exactly.

On a similar note, from what I understand you don't have to follow the whole standard's procedure but parts of it depending on your product. Is this correct? 

In answer to the first part - each country will have "local" version, which generally means that it is translated into the local language. The important part is there will be a statement at the very front of the standard that will say it is identical to the IEC version. If there are any variations they are not usually significant (for instance allowing a second colour for earth wiring as well as the green & yellow)

If you have a standard that is applicable then you have to meet all relevent sections of it. For instance, test and measurement equipment has to meet IEC61010-1. If it measures mains, it has to meet IEC61010-2-030. If it does not, then this part is irrelevnet and can be ignored (and does not have to be tested).

Also, when you go to a test house go with a list of standards you think are applicable. I have had some places (even a notified body) tell me that a standard didn't apply when I know it did (which the NB admitted when I challenged)
Two things are infinite: the universe and human stupidity; and I'm not sure about the the universe. - Albert Einstein
Tesla referral code https://ts.la/neil53539
 

Online tszaboo

  • Super Contributor
  • ***
  • Posts: 7309
  • Country: nl
  • Current job: ATEX product design
Re: CE Marking Directives and standards.
« Reply #32 on: March 28, 2023, 09:55:57 am »
Unfortunately not the case, you have to do both EMC and RED for a product with radio functionality.

Again in tldr: EMC as generic term is always needed. As a directive name, if RED applies then the RED contains the EMC stuff.
Yes, to add to this: that's why I wrote that the EMC directive is not applicable. You would fail the EMC directive as you have a radio.

Yes. If there is any radio in your product, you must comply with the RED directive.
Even if you use a ready-made radio module that claims to be "compliant". A very common source of misconception.

Yeah. It's grey area if you could skip some of the radio measurement parts of RED, if you can get testing reports from the module manufacturers. But definitely you need to still comply and test for everything else in the RED. Savings from skipping a few radio measurements are not that significant anyway.
For some parts of CE, you only need technical documentation that you are compliant with the standards, and the documentation is only internal.
This is to make access to the market easy, and cheap. So that's why the documentation can be a single page, derived from other companies. Saying like "The radio module is certified, I'm using 9dBm for the TX power, and the PCB is good" in theory is an acceptable documentation for RED. You don't necessarily need measurements, and for a product sold in small quantities by a startup for a non-critical application it might be enough.
If the product is actually proven to be non-compliant, thats a whole other story.
 

Offline metebalci

  • Frequent Contributor
  • **
  • Posts: 451
  • Country: ch
Re: CE Marking Directives and standards.
« Reply #33 on: March 28, 2023, 10:45:00 am »
You definitely can sell a bare PCB and a bag of components without requirement for CE marking, that's for certain.

Now some are pushing their luck by selling basically consumer products like single board computers that only need a case or one simple connector added. That is pushing your luck and probably beyond gray area. Many do that, too, and I'm personally satisfied they do, but this might indeed be illegal.

Does anyone know whether any well-known vendor selling breakout boards (for smd IC etc.) or something a bit more complicated than that (arduino/rpi shields/HATs) does any such certifications ?
 

Offline Siwastaja

  • Super Contributor
  • ***
  • Posts: 8110
  • Country: fi
Re: CE Marking Directives and standards.
« Reply #34 on: March 28, 2023, 12:56:04 pm »
Does anyone know whether any well-known vendor selling breakout boards (for smd IC etc.) or something a bit more complicated than that (arduino/rpi shields/HATs) does any such certifications ?

There is a trivial way to know: look for a CE mark.

As you can easily find out, breakout boards, development boards etc.often do not have CE marking and have not gone through such certification.

Raspberry Pi, for example, does have a CE marking, and so do Arduino boards (at least recently).
 
The following users thanked this post: metebalci

Offline Siwastaja

  • Super Contributor
  • ***
  • Posts: 8110
  • Country: fi
Re: CE Marking Directives and standards.
« Reply #35 on: March 28, 2023, 01:01:46 pm »
For some parts of CE, you only need technical documentation that you are compliant with the standards, and the documentation is only internal.
This is to make access to the market easy, and cheap. So that's why the documentation can be a single page, derived from other companies. Saying like "The radio module is certified, I'm using 9dBm for the TX power, and the PCB is good" in theory is an acceptable documentation for RED. You don't necessarily need measurements, and for a product sold in small quantities by a startup for a non-critical application it might be enough.
If the product is actually proven to be non-compliant, thats a whole other story.

That's the myth, but I truly fail to see in which case this would apply.

In real projects you would have power supplies, switches, LEDs, possibly other microcontrollers, maybe a crystal external to the module - anything like that. This all requires conforming to the EMC and ESD requirements in RED - nothing to do with the radio. The tests done for the radio module obviously can only cater that module, the EMC pass doesn't stick to your own circuits. Even if you have a bare module directly wired to a battery cell and nothing else, ESD is still a big question. This is all required for a final product.

Of course, just deciding not to do all of it because you are small and the risk of getting into trouble is small - I totally agree with that. But it's still a different thing.
 


Share me

Digg  Facebook  SlashDot  Delicious  Technorati  Twitter  Google  Yahoo
Smf