Declarations of conformity-real problem - Page 1
Forum section: electronics / general

author: MikeEagle95
author_rank: Newbie
timestamp: March 05, 2018, 02:19:22 pm
content: HelloA few months ago I've started thinking of putting one of my electronics design into the market.I read a whole bunch of useful documents, tutorials, etc. and frankly spealing I had been overwhelmed for a while.There is so much stuff to do (besides designing, prototyping, making PCBs,putting the whole thing into an enclouser, testing) and what is the worst for me is: DECLARATIONS OF CONFORMITY.Please let me know if I'm correct.Let's say that I want to sell my electronics product(for example: power supply).Because I wouldn't like to go to the prison, if one of my customer died using this product, I should get somesort of conformity: CE for EU, FCC for USA, ROHS. And the major problem is that it cost at least several hundreds of dollars.So my question is:How such a person or start-up company can be able to put a product to the market if the price for tests for these conformitiesis really huge?

author: dmills
author_rank: Super Contributor
timestamp: March 05, 2018, 02:53:59 pm
content: You have picked about the nastiest possible product to do this for (A power supply).Firstly you need to decide what standard(s) you are declaring conformity to, and what its requirements are, the elephant in the room being the LVD for a power supply product in Europe.FCC is required for the US if you product has digital doings at above a 9kHz clock frequency, or is any kind of intentional emitter, read their rules, they sometimes actually get serious about this stuff and levy fines, the EUs EMC directive has truly pathetic enforcement.An NRTL mark (UL, VDE, CSA, Intertek, MET..., whoever) may be required by some of your customers, and even by some cities, but that is largely a US perversion.ROHS can usually be dealt with fairly easily, almost any components you can buy will comply if obtained from a proper distributor, keep copies of the datasheets and use lead free solders, but good odds nobody will check.The other one that can be a bit of a pain is the WEEE Directive in the EU.Incidentally, your cost estimates are a couple of orders of magnitude too low, £10-20k is more like it if going for the CB scheme route to gain access to a substantial part of the worldwide markets (And doing it properly).Regards, Dan.

author: metrologist
author_rank: Super Contributor
timestamp: March 05, 2018, 03:39:33 pm
content: Even big companies avoid that mess by buying OTS or to spec power supplies. Using an external brick is so much easier as the MFG will take care of all the requirements, testing, and labeling.It's getting so complicated (especially if you are looking at a global market) that companies are turning to consultants to help them keep up-to-date with the regs. There are more coming.

author: Mr. Scram
author_rank: Super Contributor
timestamp: March 05, 2018, 03:45:12 pm
content: Quote from: metrologist on March 05, 2018, 03:39:33 pmIt's a mess, but unfortunately there are no incentives to make things better.

author: dmills
author_rank: Super Contributor
timestamp: March 05, 2018, 03:45:56 pm
content: Indeed, I would not design a mains power supply unless I was anticipating volumes of at least 10,000+ units, far better to buy them in as a pre certified unit, still got to do the business but it makes everything very much simpler.Regards, Dan.

author: Jolle
author_rank: Contributor
timestamp: March 05, 2018, 04:04:23 pm
content: As I work with legislation and standards in EU I would like to add the following regarding EU, directives and harmonised standards:To show conformance with the essential requirements in a EU directive you could use the associated harmonised standards (HS) - they are not mandatory* so you could in principle make your own standard and save a lot of money. The benefit of using a HS is in the case where your product is involved in some kind of problems (it could be someone was hurt by your product), you can then point at the HS and say that you have done what it demanded and therefore you were in good faith when you brought the product to the market (the catch here is that if your product has a dangerous property which is clearly not taken care of in the standard, then you should have known better as a manufacturer and can be made liable for the damage anyway).But even though HS is not a bulletproof solution they are a good starting point if you want to be on the right side of the law.*Sometimes the conformity can only be fulfilled by using a HS or going through a notified body, and in that case you cannot create your own requirements (and example of this is the radio properties in a radio product).

author: MikeEagle95
author_rank: Newbie
timestamp: March 05, 2018, 04:45:43 pm
content: Well, power supply was only an example of a product.The question applies to test equipment, development boards, etc.I'm just wondering, how can there be so many of various types of boards i.e. GPS,WIFI,xxduino-s (which are really cheap), if costs of conformity are so huge?

author: T3sl4co1l
author_rank: Super Contributor
timestamp: March 05, 2018, 04:48:40 pm
content: Read the relevant laws regarding test equipment, and items that are not end products but components of a possible end product.Tim

author: T3sl4co1l
author_rank: Super Contributor
timestamp: March 05, 2018, 06:34:19 pm
content: Quote from: DiligentMinds.com on March 05, 2018, 05:47:19 pmQuoteTIL "large companies" have "$1000"s.Well, avatar checks out, I guess.QuoteYes, let's go back to the good old days of knob-and-tube wiring*, uninsulated prongs and electrocuted hotdogs**.*Which really wasn't so bad; back then, they were afraid of it, and used the best insulators available at the time.**My grandpa had one of these, always entertaining...and a bit scary.Hyperbole aside, show that the regulations have not worked. Show that per capita injuries due to unsafe electrical appliances have increased after the adoption of more strict electrical safety laws.You cannot. They work.Now, there are plenty of laws where the intended effect is not that of its title. Americans seem particularly skilled at this, but as an American, I'm most familiar with our examples. I imagine it generalizes to every country that needs to misdirect its population to pass such laws. (Countries without relatively powerful citizens need not do such things; these are not necessarily dictatorships, but certainly countries with very great inequality.) But, we need not get into politics here.BTW, EMC regulations are a poor example. Safety is a better example, as UL approval typically starts at $10k. Still not a big deal for a product you're going to sell $1M of, and that's still a very small company indeed.There are plenty of violators as well. The responsibility is always on the buyer. Caveat emptor. You can buy any piece of shit from China, today. If you're too hypnotized by the low price, to recognize that, say, a charger will garble your smartphone's capacitive touch screen; or potentially deliver unsafe electrical shock, especially if you happen to bathe with it; or knock out nearby radio stations, or emergency radio services, impacting the safety of others; that is literally your problem, as the importer of those direct-to-consumer products. Or that this one unregistered device plugged in means you aren't going to get any insurance payout whatsoever when your house burns down, regardless of cause.Tim

author: Kalvin
author_rank: Super Contributor
timestamp: March 05, 2018, 07:07:14 pm
content: Manufacture it in China and just print the required certification markings on the package, documentation and the enclosure.

author: MikeEagle95
author_rank: Newbie
timestamp: March 06, 2018, 02:36:01 pm
content: I'm curious of one thing also:Is there any way that a manufacturer could place a note like this and be free not to put any conformity on his product:"The manufacturer is not responsible for any damages resulting from the direct or indirect use or malfunction of the product"

author: dmills
author_rank: Super Contributor
timestamp: March 06, 2018, 02:39:53 pm
content: Nope, one cannot disclaim statutory liability (For all that the software industry likes to try!).Regards, Dan.

author: nctnico
author_rank: Super Contributor
timestamp: March 06, 2018, 10:30:15 pm
content: Quote from: DiligentMinds.com on March 05, 2018, 07:01:42 pmThat is a pretty dumb statement so I hope you are sarcastic. Regulations are required to make products safe because you don't have the time, skills and knowledge to do product safety testing yourself. Take leaded paint, leaded gasoline, fruit with pesticides, milk with melamine, risky financial products, etc as examples of products you come across daily. Without regulations you'd need a huge lab in your home and several PhDs to test anything you buy properly.