EMC precomplience

[R_G_B_]

I have some questions regarding precomplience testing. EMC testing.
Meeting the standards that have been set by the directives for a electronic product.

I called a precomplience test centre. I was advised that you can do this your self by creating a file/report showing that your product meets the standards set out by the directive you are following. That's all that is required. I asked the question to try and open up a bit more of a discussion to understand the general practices. I mentioned that I had seen products developed in certain high street stores and supermarkets and questioned how it was possible for such products to get into the sores some of them such as lamps, solar power devices, electronic toys etc that did not look like they have attention to detail that would fit with meeting the standards but they have the CE marking. Some improrted from China loop hole ..?. The general concesus from the test lab was that it's a bit of a grey area and it's not as difficult as I anticipate. They mentioned that there are certain areas with-in engineering where  it is very rigourers. But if your designing an electronic product and you shown you have done everything as a safety measure and on top of this you can demonstrate you have met the required standards. Then that's perfectly acceptable.

Would be interesting to open up this discussion a bit more. To hear how other people have got on with this process. The ins and outs the traps and pitfalls

Thank you for reading my post.

[TimNJ]

IIRC, the CE mark is self-prescribed, so a manufacturer may (in good faith) state that the product is compliant with the applicable European requirements, and that's that. 3rd party sign-off not required.

[R_G_B_]

With-out trying to go off topic.

I am aware and seen in other professions such as building proffession. Such as tradesman. That have no qualification Or certificate to carry out a particular job. An example here in the UK. IEEE wiring regulations. Or refrigeration engineers with out F gas certificate working as refrigeration engineers and electricians without qualification.  There's no strict rules as such but if you take short cuts and the crap hits the fan. I take it that's where the onus is on you if you want to take that risk. So It boils down to professional values and practice and so it's down to the individual to insure they have followed the guidelines and implemented the requirements as specified. Use your own judgment and willingness to do the job properly.

[Neilm]

The CE mark says you comply with all relevent directives, safety, EMC etc.

I have to say, I can probably count on one hand the number of products I have EMC certified without testing, but most of my work has been in test and measurement. If there is any switching components you could see some unwelcome harmonics - especially if there are wires coming out.

[SiliconWizard]

IIRC, the CE mark is self-prescribed, so a manufacturer may (in good faith) state that the product is compliant with the applicable European requirements, and that's that. 3rd party sign-off not required.

Only if the product fits in a category that doesn't require going through a notified body, such as medical devices. And a lot of others. So you need to check that first.

Now if your product can indeed be self-marked, it is true that the only required *paperwork*, strictly speaking, is the declaration of conformity that the company will write. Someone is going to sign it. Usually, it's either the quality director if you have one, or the CEO themselves. This is not just a piece of paper though. Signing it means you take full responsibility, and as Neilm said, you claim that your product complies with all applicable directives.

No one is going to force you to *prove* compliance at this point. Until something goes wrong in the field. If there's significant damage and someone sues the company, then one of the first things will be to check what the company did to ensure compliance. If the damage done is related, even remotely, to a suspected non-compliance to one point of a relevant directive/standard, and you happen not to have done enough to ensure compliance in the first place, and have not even tested it, then you're in trouble. The person(s) responsible (again CEO+quality director if any) may face penal charges.

Now the amount of work to do for any given product to reasonably ensure compliance is entirely up to you. It requires experience and knowledge, and a great chunk of compromise. And testing is not the only thing to ensure compliance. You need to have a minimal technical file describing the design of the product, part selection and manufacturing, and this cannot be done by an external lab.

[penfold]

Testing is just one of many different means of supporting your declaration of compliance (only talking about CE marking here for general products (not medical or functionally safe)).

It is officially the responsibility of the seller of the product to ensure that an appropriate declaration is made relating to the intended/marketed use of the product, but in reality, the buck is passed up the chain to the design authority. It's also really only enforceable by Trading Standards, so in the event of a problem, the reseller would be the first person summoned to the bench in court, they would likely pay for the consequences themselves (unless death or something truly catastrophic happened). Whether the reseller is happy taking such a risk with a product is down to them. The reseller could mitigate that risk by requesting CE declaration of conformity from the manufacturer with any amount of supporting information they desire from design file assessment to third party certified-test documents or even quality and manufacturing audits to ensure there are sufficient measures to ensure consistent manufacturing.

In reality with small volume products, EMC/safety failure is not much different to not meeting any other specification, except the consequences can unexpected and it's down to you what you consider to be appropriate risk mitigation.

But of course, some products have requirements beyond safety and EMC which is covered by their CE declaration... beware.

[gnuarm]

If a country is going to have a self certification for something like EMC which is not easy to determine if a product is in compliance, it seems like there should be some means of encouraging third parties to get into the act of identifying the non-compliant products.  A bounty system could be used where a lab can test products, report non-compliant products and receive a portion of the punitive fine levied. 

I'm in the US where testing is required prior to putting a product on the market and we still have cheap junk products that radiate.  They way they get away with non-compliance is by manufacturers being fly-by-night so there is no one to go after.  So the retailer should also be held responsible.  Then they have pressure to buy from reliable sources that don't lie about the testing.

[bjbb]

"Now if your product can indeed be self-marked, it is true that the only required *paperwork*, strictly speaking, is the declaration of conformity that the company will write."

No, In addition to the Declaration of Conformity, there are requirements per the 'basis for presumption of conformity. That is, the Technical File. There is other technical and clerical stuff for both importers and EU members for placing a product on the market.
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"It is officially the responsibility of the seller of the product"

No. Responsibilities for placing on the market varies per the scoped directives and how the product is placed into the supply chain.
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"No one is going to force you to *prove* compliance at this point."

No. For stuff scoped by the LVD, import officials, and any designated authority of a member state may request the DoC and Technical File at any time for any reason.
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"I'm in the US where testing is required prior to putting a product"

No. There is no blanket requirement for product safety testing or for emissions testing. CFRs 47 and 29 provide explicit requirements for products scoped by emissions limits  and/or are subject to testing by an NRTL.
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" some products have requirements beyond safety and EMC which is covered by their CE declaration."

Non sequitur. The D of C has no "requirements". The format of the D of C is specified by the ISO17050-x series.

[R_G_B_]

Volkswagen is an example of what can happen if you exploit the rules. But that's a very big fish to go after and they became the example which shows that even the big fish bend the rules. As long as you follow  what has been set out. And you can demonstrate that you implemented all and met the required standards, you have documentation as proof.

[tszaboo]

If you are an engineer at a company, you should just take the easy way out.
For about 2KEUR, send the part with a HW or FW engineer to a test lab to do EMC precompliance testing or RED test. Properly in anechoic chamber with documentation written by someone who wrote another 50 this year only.