Selling products that run of mains voltage vs run off AC->DC adapter?

[Corporate666]

For the past decade, we have been doing automotive stuff where UL/CSA/CE is a non issue.

However I want to manufacture some home LED lighting products that I would like to sell worldwide, so now it is an issue.

I have heard (and may be true or not), that using an external power supply, such as a 12VDC mains adapter exempts the product which runs on 12V from having to bear CE/UL labeling, and that as long as you use a UL/CE/CSA approved AC->DC adapter, you are OK.  From a cursory reading of CE directives, this appears to be true, since the CE has a "voltage directive" which covers devices running on 50-1000VAC or 75-1500VDC. 

However, I know there are other aspects like electromagnetic interference... but if one designs a product that runs on 12VDC and runs from a AC->DC adapter which is already FCC/CE/UL/CSA approved, does there need to be additional testing done?  (the devices in question would not use wifi/bluetooth just LED lighting)?  What if the device contained a switching regulator inside - does it then need some form of testing that it would not without one?

Would be nice if there was some sort of "idiots guide to certification" somewhere

[minime72706]

I don't know the answer here, but I would say if you intend to sell LED FIXTURES (not retrofits or bulbs), you ought to use an off-the-shelf power supply. I began retrofitting my under-cabinet kitchen lights with LED and I basically just replaced the ballast with a CC LED driver.

[Neilm]

To properly certify to for the CE mark you have to produce a technical file to prove that you meet the CE directive. The CE mark covers not only safety, but also EMC and several other areas - possibly stand by power consumption as well. I don't know the regulations in that area. There are several different directives, and you have to meet all the applicable ones to meet the CE requirement. Unfortunately, CE mark + CE mark does not equal CE mark. With a switching regulator inside, you will still need to test for emissions. If you are supplying the external supply I would recommend testing them as a system. I have seen several supplies that passed comfortably with the 75% load resistor they test with, and fail horribly (>10dB) when connected with the end system. The only time I have not tested a product it was (quite literally) 5 resistors in a box.

The one good bit of news is that you are not responsible for the CE mark, who ever is "placing <the device> on the market" is responsible. They may very well pass that requirement on to you but I believe that they are the ones who will have to produce the deceleration of conformity. This lists the standards that the product meets and is a quick way for a regulatory authority to see if you have correctly identified all of them.

I seem to recall a guide to CE marking on the EU website, but I can't find it at the moment. I would recommend talking to a test house to see what they think and also talking to who ever will be importing the lights. Also, check the DOCs of competitor products. They will list the standards they comply to and will give you a good idea of what you will have to meet. They should be freely available.

[daedalus]

neilm: maybe talk to trading standards, they enforce CE in UK, and have rather varying views as to what makes up adequate testing, depending on the size of the company and number of products produced.

[vk6zgo]

For the past decade, we have been doing automotive stuff where UL/CSA/CE is a non issue.

However I want to manufacture some home LED lighting products that I would like to sell worldwide, so now it is an issue.

I have heard (and may be true or not), that using an external power supply, such as a 12VDC mains adapter exempts the product which runs on 12V from having to bear CE/UL labeling, and that as long as you use a UL/CE/CSA approved AC->DC adapter, you are OK.  From a cursory reading of CE directives, this appears to be true, since the CE has a "voltage directive" which covers devices running on 50-1000VAC or 75-1500VDC. 

However, I know there are other aspects like electromagnetic interference... but if one designs a product that runs on 12VDC and runs from a AC->DC adapter which is already FCC/CE/UL/CSA approved, does there need to be additional testing done?  (the devices in question would not use wifi/bluetooth just LED lighting)?  What if the device contained a switching regulator inside - does it then need some form of testing that it would not without one?

Would be nice if there was some sort of "idiots guide to certification" somewhere

Well,certainly in your own country,the product would have to pass FCC "Part 15" requirements,which is to do with incidental RF radiation.
From comments I've heard,the FCC apparently make the required information available on the Internet.

For a similar requirement in my own country,ACMA would be the people to check.

[AndyC_772]

Some good advice here 

Running your product off an approved (CE marked) AC/DC adapter is a good start, it will save you some of the testing which would otherwise have to be done when you submit your product for safety testing under the LVD - but you still need to declare compliance in respect of high temperatures (burn risk), fire, sharp edges and so on.

EMC is a separate issue and you definitely need to test this. Your product + a CE marked mains adapter does not equal a CE marked combination, and low cost mains adapters are some of the noisiest products I've ever come across when EMC testing.