The path to commercial product - Page 1
Forum section: electronics / general

author: funkimunky
author_rank: Contributor
timestamp: November 01, 2012, 11:20:09 am
content: I've been thinking recently of working for myself making something electronic (not sure what yet). I have been wondering what kind of testing and safety certs are needed to release a commercial product? Does a qualified electrical engineer have to sign of these products. How do you go about getting insurance etc?

author: EEVblog
author_rank: Unknown
timestamp: November 01, 2012, 11:43:07 am
content: Quote from: funkimunky on November 01, 2012, 11:20:09 amThat's usually a problem!QuoteDepends entirely on the product, the end user, the country it sells into, and the country you live in.QuoteNo.QuoteInsurance for what exactly?Dave.

author: Psi
author_rank: Super Contributor
timestamp: November 01, 2012, 11:58:36 am
content: In general (things vary between countries) you can side step the mains safety issues by using an off-the-shelf power pack to run your product.That way, if anyone gets electrocuted, the fault is with the power pack which was made by someone else.However!! there's a catch.Most countries have standards for mains goods. If you import a power pack from china and supply it with your product and it turns out non-complaint you're at fault for importing a dangerous product.So, to be safe, you should buy the power packs locally. That way it's the local company that gets in trouble for importing it instead of you.(or, another way to be safe is to run your product on batteries)Note: If you take low voltage from a powerpack or batteries and step the voltage up to something dangerous inside your product then your back to needing to get your product certified

author: Otatiaro
author_rank: Regular Contributor
timestamp: November 01, 2012, 12:09:49 pm
content: Hello,Quote from: funkimunky on November 01, 2012, 11:20:09 amI did it this year ... don't do it unless you have at least one real project and some backup money.I had to work a full year on nights and week-ends on a real project with partners (MS Heli) before quitting my regular job (software developer).But if you can make it ... it's awesome ...Thomas.

author: funkimunky
author_rank: Contributor
timestamp: November 01, 2012, 12:18:22 pm
content: Kudos to you Thomas that must have taken a lot of bottle to make the jump. Its funny because I am also in software of sorts (web developer).Say I wanted to handle all the power myself without using off the shelf power pack how does the testing process for (lets say uk) work. Is this done through via an official testing company or is it my neck on the line to assure that nothing is wrong with the product (I would hate for any products I make to hurt or endanger anybody).I know that you can get public liability insurance for certain types of companies but I am guessing that this would only be possible if there was certain standards adhered to and certificates attained?I'm not planning to do anything soon but I am just thinking of where I'd like to be. I am just starting out learning electronics (self taught using internet resources and Foundations of Analog and Digital Electronic Circuits by anant agarwal). I'm also a little worried that because I'm not going to get an electronics engineers degree and hence not be certified that this is going to cause real problems for me.

author: AndyC_772
author_rank: Super Contributor
timestamp: November 02, 2012, 08:11:26 am
content: Here in the UK there's no legal benefit to having an electronics degree. I'm a professional, degree qualified design engineer, but I'm not "certified" to sign off any product as "safe" in any legal sense. I am, however, arguably better qualified than the average joe to actually identify features in a product which might give rise to a hazard - but that's more about me protecting my own neck than any legal sign-off.When you place a product on the market in the EU, you're responsible for ensuring it has a CE mark. The CE mark is a legal document which means that you are declaring the product to be compliant to all applicable EU directives.The applicable directives are usually those concerned with EMC (radio interference) and safety. There are many standards which apply to different types of equipment. Other standards may also apply depending on the type of equipment and its target market. Most of the equipment I design is industrial and telecommunications equipment, so it is tested to EN:60950 and EN:55022.You don't strictly have to have your product independently tested - but you do need to maintain what's called a "technical file" which includes details of how your product is built, what the key components are in it which could affect EMC and safety, and the evidence you have to back up your assertion that the product is compliant.The best evidence you can have is generally a test report from an accredited test laboratory. If your product does ever get investigated by Trading Standards for any reason - they're the ones responsible for enforcing CE marking here in the UK - then having a test report should get you out of trouble. You might still have to withdraw and/or modify your product, but you're unlikely to actually get in trouble if you have this sound basis for claiming compliance.If you don't have a full test report, then you must accept that you're taking on some more responsibility. If, for example, your product is mains powered but you buy in a 3rd party CE marked PSU and install and use it correctly, then you may decide you're confident enough that your product overall is "safe". This is your decision, nobody can make it for you. Note that there are many other factors which you'll need to take into account in the design of your product beyond just worrying about electric shock from the mains - you must also consider things like hot surfaces, fans, moving parts and so on. There are documentation issues to consider too: you must have a label by the power inlet stating the product's supply voltage and power consumption, for example.EMC is more difficult in this respect. It's very hard to be able to claim that your product cannot generate excessive radio interference, or stop working in the presence of external interference, unless you've actually had it tested by a lab. There's a whole suite of radiated and conducted emissions and immunity tests which are performed on the product and its power supply, and products which aren't designed from the ground up with this in mind do tend to fail.You can certainly get product liability insurance. Again, it's your call as to whether you believe it's necessary given the nature and quantity of products you're planning to sell. Product liability cover should protect you in the event that failure of your product causes someone to lose money as well as if it actually causes injury or death. But it's expensive, of course.

author: funkimunky
author_rank: Contributor
timestamp: November 02, 2012, 09:45:22 am
content: Thanks AndyC_772 That answers everything in detail. A really informative and concise answer.

author: jeroen74
author_rank: Frequent Contributor
timestamp: November 02, 2012, 02:02:05 pm
content: And EMC standards can be quite difficult to understand.One anecdote from an EMC course I attended recently:I assume most know those Philips LCD TVs with the Ambilight LED bars on the back. Interesting is that one feature they had to withdraw or choose not to implement, namely only turning on those lights but no TV functionality, suddenly classifies the device as lighting equipment. For which other, more stringent standards apply. It did not meet those.Another problem area is when some EMC standard does not seem to (sufficiently) cover a particular situation, like electronic control equipment inside lantern poles.Ergo, if you're inexperienced with EMC standards, I guess it a wise move to ask an expert

author: Neilm
author_rank: Super Contributor
timestamp: November 02, 2012, 04:08:29 pm
content: With all the different functions built into equipment nowadays you can find that they fall into all sorts of competing standards. For instance, it a television that is connect to a network and showing a TV show across the internet a bit of computer equipment or a bit of of audio / visual equipment?I can hear everyone saying it is a bit of AV equipment. OK, well how would you classify a computer that is showing the same TV show?Neil

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: November 02, 2012, 04:44:03 pm
content: Quote from: Neilm on November 02, 2012, 04:08:29 pmFiguring ot which standards are applicable can be the hardest part, however where there is ambiguity, you generally pick whichever is easiest/cheapest - the chances of any decision being challenged are pretty negligible. Lighting standards last time I looked were a bit out of date as they were orientedt to wards things like magnetic fluorescent ballasts etc and not entirely appropriate for more modern systems.It's only mega-corps like Philips that would care about the minor silliness of a TV also being a light. Everyone else just gets on with doing what makes sense.

author: AndyC_772
author_rank: Super Contributor
timestamp: November 02, 2012, 06:58:30 pm
content: The problem is the risk that competitors will lodge a complaint and trigger a costly investigation. For most of us, the cost/benefit of buying a competitor's product and having it EMC tested with a view to complaining if it fails wouldn't be worth it - but for very high volume products in a competitive market, nobody can afford to be caught with their pants down.I heard a cautionary tale from an EMC lab some years ago about a photocopier manufacturer, who performed routine testing on products coming off their production line for the sole purpose of ensuring they'd spot a compliance problem before any competitors did. They spent a fortune on testing, but it was still a very small sum compared to the total sales for that product - and one day they did actually find a problem: a brand new machine was broadcasting noise at a particular frequency. Turned out that one IC manufacturer had performed a die shrink and hadn't told anyone; the outputs of the new device had faster edges than the old one, resulting in more radiated noise.

author: calumk
author_rank: Newbie
timestamp: June 09, 2020, 06:49:49 am
content: I am resurrecting this very old thread, to ask a follow up question, as i stumbled upon this thread from google, so i suspect others may do the same.I am UK/EU Based, I have a degree in Mechatronics, and In my current role, I maintain & service & commission mainly 24v electropnuematic systems, conveyer belts, sensors, actuators, on educational equipment.... But I have no Legal 'Electrician' qualification - Similar I believe to how AndyC_772 described himself above.It seems clear to me that for domestic or industrial installation, an electrical qualification is required, but I cant seem to find good information regarding the need for a qualification when designing a product for sale, and was wondering if anyone could provide any advice, or point me in the direction of further reading.-So, theoretically, if I am looking at designing a new 'product' from scratch, in which (for arguments sake) I would like to include an internal, DIN mounted, 240v power supply, or some other 240v components.My question is not regarding how to do this safely, but is regarding the legal standpoint, without being a Qualified Electrician - Is this allowed?Again, for arguments sake, assuming that I comply with the Machine and LVD Directives, use harmonised standards, test (or self test) the product, provide the documentation, and CE mark it, does the fact that I don't have an "electrician" Qualification, stop me from being the person who "designs" a product that uses 240v?Presumably, there is a difference in whether a qualification is required, for a product that falls below the LDV 50v threshold.My best guess, is that I assume that I could design and manufacture it myself, but that a Qualified Electrician would be required for the "test" aspect of the CE process?As a further thought:I assume the person actually assembling the product, does not require any specific qualification? As that would require all factory line employees in appliance factories to have a form of electrical qualification, which I feel is unlikely.Cheers

author: tom66
author_rank: Super Contributor
timestamp: June 09, 2020, 07:46:39 am
content: Quote from: funkimunky on November 01, 2012, 12:18:22 pmIn the EU, which the UK is still involved in from a regulatory point of view, your neck is on the line, because you are the one that makes the certification that the device is compliant. UKCA, post Brexit, is likely to be similar ... although there has been little clarity on this from the government. You back up that assertion with testing or a desktop study. For instance a low power microcontroller product without a radio is likely to pass because comparable products pass. That is accepted under CE (but not under FCC if I recall correctly). A high power mains device will require testing as it is novel (excepting some common devices like luminaires which generally need to be made of fire retardant materials etc but otherwise don't require testing).For the insurance it is likely that the insurer will want to know the product has been tested. Insurance companies make money by not paying out claims so make sure you get the full policy wording and give it a good read to see that it covers your circumstances. Declare everything relevant to the insurance company (and -DOCUMENT- that declaration; don't just phone it in and tell them, get it in an email).

author: EEVblog
author_rank: Unknown
timestamp: June 09, 2020, 11:10:58 am
content: Quote from: calumk on June 09, 2020, 06:49:49 amThere isn't.But the product may have to comply with any regulations such as FCC (or UK equivalent) or electrical safety standards if it's mains powered.QuoteIf you use and existing compliant mains rates supply then the safety regulations should be covered already. Provided no mains wiring of course, in which case you'd try and use an existing supply with integrated mains input IEC connector for example.QuoteI'm 99.99% sure the answer is no.Of course you'd want to have business product liability insurance.

author: nctnico
author_rank: Super Contributor
timestamp: June 09, 2020, 12:56:50 pm
content: Quote from: EEVblog on June 09, 2020, 11:10:58 amWhich will be insanely expensive. A better (usual) approach is to create a limited liability company and make sure to certify the product to adhere to all the rules and regulations. Worst case the limited liability company goes belly up. As long as if there is no neglect and/or criminal intend your personal finances will be isolated from the company. In many cases companies which develop products are split into several entities. 1) holding(s) for primary share holders / owners, 2) holding for R&D where all the IP resides, 3) holding for selling products. Several of the companies I have worked for are structured this way.See here for a more thourough explaination:https://alainromanlaw.com/holding-company-structure/

author: SiliconWizard
author_rank: Super Contributor
timestamp: June 09, 2020, 03:58:50 pm
content: It probably depends on the country, but in many countries that I know, you don't need to be a "certified" engineer to do an engineering job and design products. Only in a very restricted number of engineering fields is that true - like civil engineering, usually. But EE? Not that I know of.As far as CE marking goes (for instance), the company takes responsibility - not any individual engineer.Checking that employees (including engineers) are qualified for the position they are employed for is the company's responsibility as well. Again unless it's in some specific regulated fields, this usually doesn't imply anything specific - not even a degree. It's really up to the employer to define (and take responsibility) if someone is qualified or not. Additionally, if some product a company sells required compliance to any specific standard that you're not ultra familiar with (especially for the testing part), it's more than recommended to have the product tested for compliance in a specialized, external lab. Then this lab will share some of the responsibility as well - but ultimately, this is the company's responsibility (usually through the CEO, sometimes through both the CEO and the quality director in some regulated domains) and not any of its other employees.Now if YOU are the CEO - well, this becomes YOUR responsibility, the fact you designed the product yourself being a secondary consideration.

author: bdunham7
author_rank: Super Contributor
timestamp: June 09, 2020, 04:08:25 pm
content: Quote from: nctnico on June 09, 2020, 12:56:50 pmI don't mean to be offensive, but this is the most insanely bad legal advice you could possibly give a new business owner, for many reasons, at least here in the US where my expertise is valid. There are several reasons, and while I don't want to get into giving specific legal advice, I would caution any new business owner not to confuse what large organizations with huge legal budgets can get way with what you, the single-member LLC owner, can expect.

author: bdunham7
author_rank: Super Contributor
timestamp: June 09, 2020, 04:22:51 pm
content: Quote from: calumk on June 09, 2020, 06:49:49 amYou need an answer from a UK-based person, or at least one familiar with UK law in this regard. I'll just say that I would guess that your "Qualified Electrician" is equivalent to what we call a Licensed Electrician here, although the licenses are all state or local, not federal. In our case, being a licensed electrician has nothing whatsoever to do with your products or testing or manufacturing. The Licensed Electrician and the National Electrical Code (again, as modified and adopted locally) have a specific domain that generally starts on the customer side of the service meter or service entrance and ends at the wall socket. Anything outside that domain, again with a few exceptions due to local law, is just not their area. I suspect something similar is in place in the UK.

author: AndyC_772
author_rank: Super Contributor
timestamp: June 09, 2020, 08:23:31 pm
content: Quote from: calumk on June 09, 2020, 06:49:49 amYou're quite right that it's an oddly inconsistent area.In most instances, work onfixedelectrical installations must be done by a "competent person" - though the definition of that particular term isn't nearly as clear as you might hope. Let's assume for the sake of argument that it means a qualified electrician.If, on the other hand, you're building something that people can buy, as a complete, preassembled unit, which willpluginto the mains, then you don't need any particular qualifications at all. (Think about it for a moment... the army of people working in factories churning out TVs and washing machines by the million aren't all qualified electricians).Someone does, however, have to sign the CE declaration of conformity document, and that person takes responsibility for all those products being safe and compliant. Looks like that person might be you.QuoteNo, it doesn't stop you. If you're ever called upon by Trading Standards to demonstrate that your product is compliant, you'll send them a copy of your technical file which will - if you have any sense - include a test report from an accredited safety lab which shows that your design complies.Nobody cares whether you "are an electrician" or not; they care whether the design of your product actually is safe. That's a good thing, IMHO.

author: EEVblog
author_rank: Unknown
timestamp: June 10, 2020, 01:34:31 am
content: Quote from: AndyC_772 on November 02, 2012, 08:11:26 amFor insurance purposes, and being sued etc, it all comes down to "best practices". If you have followed best practices, and haven't done anything deliberately negligent unless then you are fine, regular product liability insurance should handle any issues.It's a bonus when you an show independent testing, or using already certified products like mains power supplies.For a mains product you'd be crazy to design your own own mains switching supply for example unless you had no other choice.

author: nctnico
author_rank: Super Contributor
timestamp: June 10, 2020, 10:25:55 am
content: Quote from: bdunham7 on June 09, 2020, 04:08:25 pmOfcourse it depends on what kind of money you can spend and the local rules & regulations so my advise could be unsuitable in some cases. However the companies I worked for which are structured this way employed 20 to 40 people with a turnover of several million euro annually. Either way going for an limited liability company requires to get legal advise which will be tailored to local rules and regulations. The bottom line is that when you put products on the market on a large scale you will need to put some isolation between product liability, IP ownership and your personal finances.To get back to liability insurance: I have looked into that as well (several times) but besides the huge premiums the fine print excluded the risks I wanted to insure. They don't make it easy to understand these insurance policies and the people selling them seem to have very little knowledge on what the insurances actually cover.

author: calumk
author_rank: Newbie
timestamp: June 12, 2020, 09:40:35 am
content: Many thanks to all of you for your helpful feedback.It has certainly cleared a few things up, and as is I suppose inevitable, generated more questions.I think ill hunt around for some more specific legal advice from other small UK startups.Cheers,Calum

author: EEVblog
author_rank: Unknown
timestamp: June 13, 2020, 02:47:39 am
content: Quote from: nctnico on June 09, 2020, 12:56:50 pmReally?I have $20M product liability coverage + $20M Public Liability for AU$1280 a year. And this includes covering all my onsite location filming etc.It was under $1k a year when I only had one lab and just me as the employee.

author: Mr. Scram
author_rank: Super Contributor
timestamp: June 13, 2020, 03:34:05 am
content: Quote from: EEVblog on June 13, 2020, 02:47:39 amDoes that include any physical products?

author: EEVblog
author_rank: Unknown
timestamp: June 13, 2020, 07:32:19 am
content: Quote from: Mr. Scram on June 13, 2020, 03:34:05 amYes, of course, that's the point of it.If my uCurrent or a multimeter somehow does harm to anyone or anything, then I'm covered.

author: Psi
author_rank: Super Contributor
timestamp: June 17, 2020, 08:32:30 am
content: Quote from: EEVblog on June 13, 2020, 07:32:19 amUnless they can find some obscure regulatory certification the product should have had but didn't and weasel out of paying. Like insurance companies love to do.

author: nctnico
author_rank: Super Contributor
timestamp: June 17, 2020, 01:26:03 pm
content: Quote from: EEVblog on June 13, 2020, 02:47:39 amThat seems quite cheap for product reliability; I'd be interested in the terms of it. Can those be found online somewhere? I know it will be tailored to Australian law so it is useless to me but nevertheless I'm curious.I've been looking for product liability coverage myself but either insurance companies would hang up on me saying they don't insure industrial products OR I got a quotation for an insurance policy which excluded the risks I wanted to insure. In the end I just limited the risk for me in my terms & conditions.

author: EEVblog
author_rank: Unknown
timestamp: June 22, 2020, 05:41:29 am
content: Quote from: nctnico on June 17, 2020, 01:26:03 pmSome pertinent details in the attached, but it doesn't specifically state the kind of stuff that is covered, it's more general.https://www.vero.com.au/content/dam/suncorp/insurance/vero/documents/policy-documents/vero-business-insurance-pds.pdfI just told my insurance guy "I want cover that takes care of product liability in terms of it causing harm to person or property or business etc" and he assured me that it does. And I trust him, he's a friend of mine.If you want something specific added to a policy then I'd guess that's going to cost you.I found that when contacted direct most companies wouldn't touch me, or they'd give some absurd quote, as they had no idea what I was doing and didn't want the hassle. This is what insurance brokers are for.

author: Mr. Scram
author_rank: Super Contributor
timestamp: June 26, 2020, 09:24:52 pm
content: Having an insurer you can trust is an untold luxury. Most would prefer slow torture of their mother over having to pay out. Though usually it's just you who ends up being tortured.

author: Bud
author_rank: Super Contributor
timestamp: June 26, 2020, 09:33:43 pm
content: I get a picture of a multimeter when i click the link

author: tom66
author_rank: Super Contributor
timestamp: June 26, 2020, 09:48:47 pm
content: Same. Dave sponsoring Uni-T?

author: Bud
author_rank: Super Contributor
timestamp: June 26, 2020, 10:33:48 pm
content: Perhaps it may have to do with the recent problem with the server.

author: nctnico
author_rank: Super Contributor
timestamp: June 26, 2020, 10:37:13 pm
content: Quote from: Bud on June 26, 2020, 10:33:48 pmThat could be. Today I've seen wrong attachements pop up in other posts too. The attachement above from Dave has worked correctly.

author: Bud
author_rank: Super Contributor
timestamp: June 26, 2020, 10:57:08 pm
content: Weird..I downloaded the attachment and it was the same multimeter picture

author: EEVblog
author_rank: Unknown
timestamp: June 27, 2020, 02:24:45 am
content: Wow, yeah, that's weird.