CE testing

You need ISO-9000 for a start ;) Actually you must have some type of Quality management system in place. 9000 is a standard QM system, so might as well give in.

Cheers

Oh, once that's in place the you'll need to figure out what Directives to apply. And there's always Lab time for EMI testing. And don't forget Rohs and REACH.

I'm not sure if the Conflict Materials assesment is required, but that too.

Cheers

OK, it's not worth it to sell a dozen boxes.

How do small european electronics companies survive? The cost to design a product could quadruple with all that nonsense.

A French company bought one of our gadgets and then introduced a clone. I bought one to see what they did inside. It does NOT have a CE mark.

Perhaps they don't sell it in the EU, just for export. I have never come across anything that states that an EU company needs a CE mark to put something on a boat for export. But i've heard EU customs looks at imports for CE markings. No CE marking and it gets stuck in customs.

Cheers

As far as I know, none of the relevant Directives require anything like ISO9000 unless he's making power supplies, medical products, etc.

RoHS2 is purely paperwork -- go down your BOM, get a supplier RoHS cert for each part, put them all in your Technical File.

Realistically I think John's looking at 2 rounds of EMC testing at about $3k each (many products fail on the first iteration), plus his own labor costs. There is potentially a lot of labor in research and preparation.

If the customer is a reseller in the EU, they can sign the Declaration of Conformity. Otherwise you need an Authorized Representative in the EU...

Conflict Minerals is required -- if he's buying raw tantalum or tungsten metal. But I think most manufacturers of laboratory instruments prefer to purchase their capacitors ready-made.

-- Adam

They not only survive but export to the US where the Underwriters Laborator y imposes a non-tariff barrier to trade.

Most components have UL approvals where ever they come from, so it's not us ually a big deal. It's a minor aspect of the design process, and certainly doesn't "quadruple" design costs - but then again John Larkin has claimed t hat his total design times are typically about two weeks, which doesn't lea ve time for much actual design.

You wouldn't need it if the gadget was being sold to somebody in the US.

How much had they improved the design? "Clone" implies that it did the same job, but doesn't necessarily mean that they did it the same way.

I suspect there are thousands of european companies that never do the CE testing. As some English colleagues told me, CE means Can't Enforce.

I think CE is mostly a way to keep out imports. Or to try.

Am 14.06.2018 um 05:13 schrieb John Larkin:

Actually, it is exactly the opposite. When you are attaching a CE sticker to your products you promise to the European Union that you have checked the applicable laws and that you can prove it. That is usually not challenged unless sth. bad happens or you have a competitor who provides clear evidence that you do not comply. That is essentially the same as starting a law suit.

The CE mark is recognized by all EU countries, you may import to any of them without considering local regulations individually. That is actually a relaxation. There are products that are not covered by this. It may even be illegal to attach a CE label to certain goods, like safety critical parts of elevators where they might not simply take your word for it.

I would not rely on what English colleagues tell about the EU. They do not even have an idea on how to handle the borders in their own islands after next year.

Cheers, Gerhard

Do small european electronic instrument companies do all the testing, or do they just "Attach a sticker" ?

Do they even attach the sticker?

The Chinese companies do!

As noted, the thing I bought from France had no indication of CE compliance. Maybe they *remove* the sticker for exports outside the EU. Or just never did it.

What do you design? Do you always do the CE testing?

Like Underwriters Laboratories certification in the US.

It's mostly about having designed it right in the first place.

If you really know your way around electromagnetic compatibility, you can u sually design stuff that you can be confident will meet the requirements.

The one time I had to get a product EMI certified, it was a product where s omebody else had done the electronic design before getting a lectureship in another city and dropping out of the design team, leaving a few problems t hat I fixed by modifying the original design, rather than starting over.

The fact that some of his logic (in a 22V10 part) didn't meet worst case ti ming requirements wasn't the only problem that I had to deal with.

That's done in production.

They would do it for European products that happened to be made in China. Q uite a bit of European manufacturing is sub-contracted to China (as is Amer ican and Canadian manufacturing - if it happens in Australia, I haven't hea rd about it).

Why go to the trouble of adding the sticker to a device that's intended to be exported? A paranoid producer might see it a way of making it a bit more difficult for somebody to clone their product and export it back into Euro pe.

The Chinese interpret it as China Export. The local EMI testing lab had here plenty of Chinese 'CE' things that did not, for sure, pass any of the limits.

CE does not necessarily mean testing, but you take your risk that the product is not completely compliant if you just slap the sticker on.

I was in the team producing an industrial measurng instrument and getting the test results. It took about a week at the testing lab and plenty of the samples Wurth provided to pass the limits.

Short design times are a commercial reality. If you don't do it someone else will.

I think we self certified some products for the EU. (I don't really know the details, someone else did the leg work, and my boss stuck his name on it.) We did a few simple things to make it harder to kill yourself with our products, but no EMI testing... not much fast stuff, and we use someone else's SMPS.

I don't think we put CE marks or stickers on the products... but I could be wrong.

George H.

It depends on the type of equipment if you need to do any testing. A simple electronic instrument not related to medical or other safety critical use probly does not require any testing by a certified body to have the CE sticker.

ngs

atory imposes a non-tariff barrier to trade.

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

But you run the risk of getting knocked out of the market by somebody who s pent the slightly longer design time required to get it right.

The temptation to rush into production as soon as you have something that i s more or less saleable is remarkably strong, and the same sales people who want a barely good enough product right now, also want you to get started on the next product immediately.

There's always a tension between engineering and sales about this, and ther e is a lot of shoddy hardware around where the sales force had its way.

I saw a classic example of the process in the Lintech Electron Beam Tester, which was the first one on the market, sold and developed by the guy who i nvented voltage contrast electron microscopy.

One of the engineers who worked the original machine got cross about gettin g pressured into doing stuff too fast, and got hired away by Fairchild, lat er Schlumberger, who used him to design a competitive machine, which was ju st enough better than the original that when it hit the market Lintech neve r sold another machine.

Mike Engelhart, now with Linear Technology, was on the Schlumberger develop ment team.

If you really want to know, don't ask here. Ask these guys:

So you apply the sticker out of personal confidence that the box would pass all the radiated and suceptability EMI limits?

Cool, just buy a box of stickers.

What risk?

Sometimes two days. One of our more successful products was done in a weekend, PCB layout included.

It's like programming: a really good programmer is 20x as productive as the average programmer. And the bigger the team, the slower the work. So design cost goes as the square of team size.