CE testing

I did not say you should not do any testing yourself, but it would not have to be tested by an external testing bureau. It depends on your own knowledge, experience and available equipment and on the nature of the device in question whether you can test that yourself.

Reply to
Rob
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Right, CE is a *declaration* of conformity (to the relevant EU regulations, e.g. the curvature of a banana), not a result of any tests. It's your competitor's task to pay for the testing. :-)

And if they are right, you'll pay a fine and the products will be withdrawn from the market. So it is actually cheaper to pay for it yourself and let a certified lab issue the necessary papers, taking responsibility for that. One sleeps better then.

Best regards, Piotr

Reply to
Piotr Wyderski

Basically, yes. And they will get medieval on you if they prove you lied. Engagement in the proving procedure may be the result of a random sample market test (done routinely with the China Export branded products) or your competitor's denunciation. Not that stupid, everyone is watching over everyone else.

Best regards, Piotr

Reply to
Piotr Wyderski

Am 14.06.2018 um 06:18 schrieb John Larkin:

Well, you can buy the stickers at Conrad's, which is our local equivalent to Radio Shack.

In the last years, I did mostly design for space applications. We export to the orbit :-) No CE stickers. Probably the glue would not be certified for outgassing.

Our design reviews are much harder. You have to justify every resistor, in writing. Even transient power in a 2R2 damper in series to a 100n on a power supply line.

That is in contrast to CE testing, where a manufacturer may insist that a camera is still functional even when it delivers no picture when bombarded by RF in the test chamber. Happened to a friend of mine who ran a test lab near Berlin. Customers flock to where it is easiest to get the signature. He has since given up and instead audits labs :-)

Cheers, Gerhard

Reply to
Gerhard Hoffmann

Sell a dozen as engineering samples... Plenty of small compaies in the UK that don't bother with CE...

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Reply to
TTman

I've done the CE process for non-electronic products. The best answer reall y is to read the paperwork. I'm not clear which regs you as a foreigner wou ld need to conform to, you're not subject to EU law but your customers are, so would want a product that complies with everything. These include CE, R oHS, Electrical Equipment (Safety) Regulations, Electromagnetic Compatibili ty (EMC) Directive, Plugs and Sockets etc. (Safety) Regulations, WEEE, and LVDS. Some may not apply and there may be others. I did non-electrical.

CE consists of risk assessment, safety testing where any questions exist, w hich we did ourselves, and a declaration form, then product markings. There 's also a requirement for various warnings if your product isn't suitable f or neonates, people falling asleep in a bath, etc.

Once you understand what's required it's not so bad. The annoying part abou t EU rules is the EU directives, which are too vague to be followable. Coun tries have made their own Acts that embody what EU rules require, see those & expect to read around a bit.

Yes, there are companies that do none of this & slap a sticker on, but do y ou really want to be wiped out by a resulting scandal?

NT

Reply to
tabbypurr

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ratory imposes a non-tariff barrier to trade.

ot usually a big deal. It's a minor aspect of the design process, and certa inly doesn't "quadruple" design costs - but then again John Larkin has clai med that his total design times are typically about two weeks, which doesn' t leave time for much actual design.

If you are changing an existing product to do a slightly different job - an d John Larkin doesn't seem to design his products to be flexible, which tak es time - you can make the necessary change very quickly.

Whether this counts as "design" is a question. If the product has a differe nt inventory stock number from it's precursor, it's a new product, but the re-design content isn't high.

Actually, it's more like cooking. Change one item in a successful recipe an d you have a new dish. John Larkin certainly sounds and acts more like a ce lebrity chef than a design engineer.

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Bill Sloman, Sydney
Reply to
bill.sloman

Correct. Of course I've done some measurements to gain that confidence.

Usually in some smaller cheap lab for which I know how much I need safety margin to know that I'd also pass the accredited measurements.

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mikko
Reply to
Mikko OH2HVJ

It seems you are exempt:

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page 17

"exemption for the custom built evaluation kits destined for professionals to be used solely at research and development facilities for such purposes (Article 2.2.e of the EMCD). "

in adition to the use of a wall-wart, that clears you from the Low Voltage Directive.

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Best Regards Steve Sousa

Reply to
etsteve1

Really? I'm a one man band, don't have ISO-9000, and have had dozens of products certified (both via the self certification route or external testing).

Reply to
JM

If you think it will meet all the required standards, write down why, create a product file with that information, and self certify based on that file.

Then buy a roll of stickers and ship it.

Reply to
JM

If a box is exempt according to the CE standards, is it reasonable for us to put a CE sticker on it?

Our box will be used in a fixed industrial installation, which makes it exempt from the EMI directives, and will be powered by a CE-marked

24 volt wart, which might exempt us from the LV directive. I think we could self-certify for the safety stuff, if we can be exempt from EMI.
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John Larkin         Highland Technology, Inc 
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Reply to
John Larkin

That does sound like the way it's done. As I noted, it's apparently exempt form the EMI directive, which would be the hard one to hand-wave.

I don't want to cheat, but neither do I want to do what most other people agree is enough.

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John Larkin         Highland Technology, Inc 
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Reply to
John Larkin

Hi John

That does not sound correct, do you have a reference? E.g.

============ Electromagnetic Compatibility (EMC) Directive Scope

The Directive is one of the widest in its application and all electrical products must comply whether they are mains or battery powered. The only exceptions are for components or sub assemblies with no intrinsic function (i.e. their use cannot be defined unless they are combined with other components) and certain electrical products and systems which are already covered by other directives. Examples of components which do not need to comply are plugs and sockets, capacitors, resistors and integrated circuits. More complex sub-assemblies such as power supplies, micro-controllers and cards for PC?s do have to comply. As a rule of thumb, if it possible to make meaningful EMC tests on a product then it needs to comply and be CE marked accordingly, unless it is covered by one of the specific exclusions. =============

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John Devereux
Reply to
John Devereux

Presumably your box has already passed some form of FCC emissions testing? My understanding was that is mandatory before selling the product in the US if it contains any circuit that runs at (IIRC) 10 kHz or higher.

The FCC and IEC class B emissions limits are nearly identical, so that should give enough confidence of a pass without re-testing, especially if the lab gave you a copy of the emissions plots.

FCC does not impose any requirements for immunity for regular commercial-grade electronics AIUI. For CE there are a set of immunity requirements to EMI, plus ESD, mains borne transients etc. But for this class of product it's up to you to define your own pass/fail criteria for each immunity test, which makes a bit of a mockery of the whole process. The rules for the products we do, life-critical medical gear, are a lot stricter, as you'd expect.

TL;DR : Put the sticker on and ship it. But keep any supporting evidence you may have, just in case.

Reply to
RBlack

That would be a very rare occasion. Industrial is often relaxed in the standards but so far I never had a case (on terra firma) where there wasn't at least a class A requirement for EMC. Residential and med was always class B, at least over the last 30 years.

That would almost be the perfect loophole. However, in general the whole installation would then have to pass at least class A for industrial and class B for most other environments. In order for that to happen John's device would need to behave well from an EMC point of view but since they are good engineers I assume that would be the case.

That part looks a bit like a gray zone. Maybe a box with electronics that gets integrated could be called an "integrated circuit" 8-)

Or let it run through a short 4h sanity check at BACL or some other lab close by. That should be under $2k. Then you'd get a report with plots et cetera and could tack that on. It's not a full EMC cert but if everything is well below the margins you could claim to strongly believe that EMC will be fine.

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Regards, Joerg 

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Reply to
Joerg

Also called Chinese Engineering.

I was called to a client when their equipment just could not pass radiated. Turned out a bar code reader from China was a gross polluter. Needless to say it had all the usual conformance stickers and declarations including CE mark.

Once I depleted the snap-on ferrite stock of all Radio Shack stores in

20mi radius around a client. Now that Radio Shack is gone we'd be up the creek because the unit had to ship next day on a 6am flight. I hit the pillows at the hotel around 2:30am. The engineer accompanying the unit on the flight slept in the hallway of their home in order not to wake up his family.
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Regards, Joerg 

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Reply to
Joerg

What nonsense. UL has made huge strides in harmonizing with other countries. For example, UL60601 is now almost the same as EN60601 in Europe. Meaning you can go to a lab, have them do a "lowest common denominator" run and get both certs in one swoop. There is plenty of cross accreditation in labs between countries.

[...]
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Regards, Joerg 

http://www.analogconsultants.com/
Reply to
Joerg

Someone else here led me to this document:

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I don't know if other CE requirements, like low voltage and such, are also exempt. Got to do more research.

My problem is that the ultimate customer wants a CE sticker on our gear, even though it's probably exempt. It will go into a jet engine test cell, which is a seriously fixed application.

If it's exempt, I should think we can put a sticker on it, with a suitable explanation in the manual.

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John Larkin         Highland Technology, Inc 

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Reply to
John Larkin

No. Our sort of test equipment is exempt. As it is apparently exempt under the CE rules.

Mockery is good.

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John Larkin         Highland Technology, Inc 

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Reply to
John Larkin

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