Bring a product to market without certification? - Page 1
Forum section: electronics / projects

author: JamesG-J
author_rank: Contributor
timestamp: March 05, 2020, 02:33:16 am
content: Hello!I'm ready to bring my project to market and am trying to navigate the certification process. I'm in Canada, though looking to sell globally, and am aware of the standard approach to certification - I just don't have money and time.My product is essentially just a low voltage power controller running custom software (raspberry pi controlling mosfets to 12V solenoids), and has already been tested on-site by my business partner / pseudo-first-customer. The only custom electronics I built were the power controller boards, using I2C GPIO expanders and mosfets, and a sensor board with more GPIO expanders and some pull-down resistors to measure simple open-close switch sensors.In order to avoid having to certify this product I thought I could just swap out my custom boards for some off-the-shelf boards from a reputable source (like sparkfun), but in looking around I noticed that those boards don't seem to have any certifications either...So now I'm wondering whether it is at all possible to avoid borrowing a few grand and getting the paperwork, and also how sparkfun and other kit builders are allowed to sell, perhaps because their products are 'educational'?If anyone has any thoughts or has been in a similar situation before, any advice or ideas would be much appreciated!Also wondering if I can at least delay the process by selling 'engineering samples' or 'prototypes' while I get the certifications, then have my customers switch out the hardware once I have the paperwork in order...I'm selling to a pretty niche market so the volume should be pretty small at first - though, of course, this is not ideal for a lot of reasons including safety and hassle...Maybe I can make the hardware open source and sell 'the assembled kit' until I have the money to certify...?

author: ataradov
author_rank: Super Contributor
timestamp: March 05, 2020, 04:20:15 am
content: What specific certifications you are looking for? If your product does not connect to mains and does not have any intentional radiators, you should be fine in most cases.Also, worry about it when you get enough sales to justify it. Unless your product is actually dangerous enough that you are personally worried.

author: JamesG-J
author_rank: Contributor
timestamp: March 05, 2020, 05:02:22 am
content: Thanks for the quick reply, ataradov!My main concern was with the CSA certification (general safety from electrical shock and fire), I thought that selling any electronics in Canada without that mandatory certification would be a bad idea.The other one would be UL / testing by a NRTL for sales in the states...would I not be taking a big risk if I was exporting a product to the U.S. without that certification since it has to pass through customs?The product will be installed in commercial facilities, so harder to pass through than a person product.The only intentional radiator would be the raspberry pi, which is already certified.The product does connect to mains but I'm using a certified power supply to convert to DC.

author: ataradov
author_rank: Super Contributor
timestamp: March 05, 2020, 05:20:49 am
content: Customs should not be a problem. But "commercial facilities" is key point here. For them to even consider your products, you would need certifications in place.

author: JamesG-J
author_rank: Contributor
timestamp: March 05, 2020, 05:45:37 am
content: Very interesting idea, blueskull!The goal was to make the entire system very modular so the end user can buy different expansion 'cards' to control any number of inputs/outputs. So there was already a plan to have 'some assembly required'.And the idea was to make most of the profit on the software as well, so this seems like a good way to go, at least until I can afford to certify everything properly.Thank you both very much for your insights!

author: penfold
author_rank: Frequent Contributor
timestamp: March 05, 2020, 12:39:46 pm
content: Hi,Unfortunately in these situations, there is no get-out legally. The wording is very specific in its ambiguity for most "certification" routes, it is the end product in its intended application which you must certify.I would urge you to avoid take any advice offered by anyone who doesn't know the exact nature of the product. There are no get-outs even for modularity, the certification of the RPi will be invalid when installed. If your product requires a RPi or a certain configuration of modules to be installed to work, that configuration must be certified.Just what you're classifying as "commercial facilities" is most important, the rules are different for offices or factories, and if its permanently "installed" in the building you've got more considerations to add. UL testing isn't just one thing, there is a lot that goes into it and it is only valid for a limited number of use-cases and monumentally expensive if you want a "catch-all". It's worth getting some advice under non-disclosure agreement with an experienced engineer. Even speak to target customers and see what they're looking for in certifications, it'll have to get signed off at some point, if they have to do it, it might turn them off your product.Max

author: frozenfrogz
author_rank: Frequent Contributor
timestamp: March 05, 2020, 01:41:03 pm
content: Legally you are required to comply with RoHS / REACH / electro-magnetic testing standards / and various other things depending on the class of product - at least here in Europe. There is no exemption any longer for kits / modules /...For Europe, you must include a certificate stating you are compliant with EU regulations. This includes a written statement of you, having taken into account all legal standards regarding the product class your product falls into (CE). Also, user manual, datasheet and the likes would most likely be mandatory.You could go ahead, skip all the testing, simply assume your product is meeting all the requirements and "provide" the necessary paperwork that has to be present for the product. However, if for some reason your product actually is not meeting the required standards and someone will point that out, you might be in for quite some legal trouble.My guess is, that similar laws apply to U.S., Canada, Japan, ...For a very small run of products you might be good flying under the radar. I would not recommend that though.

author: angrybird
author_rank: Regular Contributor
timestamp: March 05, 2020, 02:45:38 pm
content: There is a lot of paperwork no matter what certification you are going for, and if you need EMI, ESD, etc this also means some costly days in an approved lab. IMO, for some certifications, you are just paying the "compliance mafia", but that's just the way it is.Products made in china and sold online seem to be exempt from all of these requirements, there are so many hazardous electrical devices still sold on Amazon even today, as an example. There is still hope, however - In the USA, they have been agressively working to level this playing field and the American people area also making their own little war against all the chinese products sold online, so just push foward with this project and don't try to do something dishonest like the chinese guys, it always burns you in the end.There is possibly an easy and honest way to avoid needing some certifications - Contracting directly for your customer. In some countries, if you contract for the customer as a "consultant" or the like, and the customer has final sign-off on the product (i.e. you work with them to build their own specifications, and you build it to these specifications), you may be able to make the product on a per-customer basis and be excempt from some requirements, but this will vary with industry, country, and application. There are and always will be numerous applications exempt from RoHS, EMI/EMC and safety certs, but it's up to you and your customer to determine what apply and be able to defend this decision if the braindead bureaucrats come sniffing around

author: SiliconWizard
author_rank: Super Contributor
timestamp: March 05, 2020, 03:06:35 pm
content: Quote from: JamesG-J on March 05, 2020, 05:02:22 amFrom your short description above, I unfortunately doubt you can sell that without proper certification. You should probably start with contacting them:https://www.csagroup.org/and see what they say. You will need to describe your product way more accurately than this before even getting a proper answer IMO.As someone else said, the fact it contains parts that are "already certified" doesn't make your product, which is an assembly of all this that you will be held liable for, itself "certified". It may just help with the certification/testing process (sometimes only marginally!)Regarding the process for CE mark, the same ideas prevail, but unless your product lies in a specific category that requires going through a notified body (such as medical devices), you can self-mark your product. Be aware that you are considered fully responsible for this: you can perfectly self-mark (with the appropriate declaration) a given product without any testing (so at very low cost), but in case something goes wrong in the field, you can get in a lot of trouble - because basically, a CE declaration of conformity implies that your product is compliant with the corresponding directives. If you haven't tested that it is, you'll have no way of proving it: which means you effectively signed a false declaration. The risk management is up to you, as so far, you will never get controlled randomly (for products that are not regulated), so the risk is there only if something goes wrong in the field. That may change in the future, although I doubt that as it would require way too much resource to be enforced.One way to possibly circumvent this, as angrybird suggested, would be to put the burden of the certification/CE mark on the shoulders of your customer(s), in which case you would essentially be selling "spare parts". I doubt any customer would accept that though. Besides, some regulations may still apply, such as RoHS and the like (but this is relatively easy to document.)

author: angrybird
author_rank: Regular Contributor
timestamp: March 05, 2020, 03:16:44 pm
content: Generally speaking you can also protect yourself in the "self marking" case IF you can demonstrate beyond a reasonable doubt (by documentation, reports, and at least a little bit of external certification assistance) that you have done your due diligence in conforming to the spec. This does mean a lot of documentation but this combined with good business setup (in the states, you can start with a Limited Liability Company, for example) gives you a decent firewall against trouble. I've never had any problems past EMC due to deviation from original/design setup or parameters, and this is solved easily enough.In regards to UL certification, in many ways, these guys are the "certification mafia"... You are paying to play, all of the work is up to you even when they "perform" the testing with one of their techs. I am not at all discounting the value of an entity like UL, it's just that sometimes I think they have gone too far in the "profit" direction

author: SiliconWizard
author_rank: Super Contributor
timestamp: March 05, 2020, 03:30:47 pm
content: Quote from: angrybird on March 05, 2020, 03:16:44 pmCertainly, in case of trouble, anything you have done to document your product and assess its compliance will certainly be better than having done nothing. Just know that it may not be enough.When you're only selling low-voltage devices, the risks are way lower usually, and as you mentioned, apart from possible EMC issues (which are rarely deadly), you take limited risks even if you haven't tested it thoroughly. But as soon as it's connected to mains, safety issues could obviously potentially lead to death, so that's a lot more risks.Quote from: angrybird on March 05, 2020, 03:16:44 pmWell, all those certification bodies and testing labs cost an arm and a leg, especially for small companies.... that said, I have known a notified body and two big testing labs from relatively up close, and their operating expenses are way higher than you may think. But yeah, you will spend way more time on a given certification for your product than they will ever do - usually a few hours for them, sometimes months for you.

author: JamesG-J
author_rank: Contributor
timestamp: March 05, 2020, 06:40:42 pm
content: Thanks for all the input everyone!!I definitely do NOT want to try my luck flying under the radar, I'm trying to start a legitimate company here and have dealt with improper import/export paperwork at my old job (after a few times through secondary screening at customs they stop giving warnings and things start getting scary) - and I can only imagine that illegally selling uncertified electronics would be just as bad if not worse. There's also the morality of selling something to people that could potentially harm them - I don't sleep enough as is, don't need to be losing sleep over that too...Was hoping to hear that I could use other peoples' modules to piggyback off their certifications but seems that's not the case (and does make sense, you can wire up other peoples' good designs incorrectly and still risk harming someone).Even though it sucks to have to pay that much to play, seems like I'm going to have to do a round of fundraising to get this product certified (luckily I have a few people lined up to get in on the first round)...let's just hope I make it modular enough that this design can last a while!I'm going to call CSA today and will post here if I get anything more than "you must certify with us" as a response.Thanks again everyone for helping me out! First post on the EEVBlog forum and the community here is amazing!

author: Ground_Loop
author_rank: Frequent Contributor
timestamp: March 06, 2020, 03:30:55 pm
content: Quote from: JamesG-J on March 05, 2020, 05:02:22 amI deal with import and export of electrical equipment in and out of US fairly often. CBP couldn't care less about certification. They just want the taxes and to ensure its not a bomb or drugs. My inbound equipment is UL certified at final point of use by either UL directly or NRTL (TUV), if the customer requires it. End user and local jurisdictions specify the required certifications. I have never had emissions questioned.I've dealt with CSA and it's a royal pain. Fortunately, I've had competent consultants to get me through the process.

author: splin
author_rank: Frequent Contributor
timestamp: March 07, 2020, 01:32:22 am
content: Quote from: angrybird on March 05, 2020, 02:45:38 pmCracking down on the really dangerous stuff would be good ... butQuoteI would hate that we reverted back to the bad old days pre-cheap Chinese goods. All those dirt cheap electronic modules including Arduino (clones!), sensor modules, relay boards, motor controllers, DC-DC convertors etc. ad infinitum have massively fuelled the 'maker' movement if not actaully created it. Without them we would be back to the position where you either made everything youself from scratch, or paid $50+ for the simplest module, assuming it was even available.A significant part of that cost would be needed to cover certification and compliance given the resulting limited size of the market. $5 to $10 costs/item could easily multiply to $20 to $30 or more by the time distributer and retailer markups and sales tax/VAT are included.Yes its totally unfair and it sucks that local manufacturers are put at such a massive competitive disadvantage to Chinese suppliers who have additional tax (typically no VAT) and shipping cost advantages. But the real problem is the excessive regulatory burden imposed on small businesses. Of course safety is important but the emission requirements in particular are, in my opinion, almost totally pointless.Yes there were cases of equipment being sold which caused severe interference to radio reception so regulation is good. But for a great deal of equipment and electronic modules almost nobody cares. It hardly matters if a set of electronic scales is 'noisy' given they are typically ony used for a few minutes at a time, but they can be fantastically useful on odd occasions. When they cost < $10 they are an easy purchase but if you had to pay $50+ for a fully compliant approved variety you likely wouldn't bother.Same applies to an awful lot of stuff. Ultimately, cracking down on enforcing the regulations probably won't help small to medium local manfacurers much anyway. If forced, the Chinese suppliers will find ways to get very low cost domestic certification testing. I believe EMI certification is much cheaper in China anyway, but for low cost and/or lower volume products I expect they would respond with very low cost certification facilities providing as much 'certification' as justified for the type of product and its value, whilst being sufficient to cover regulatory controls in most export markets.At the same time it would be just robust enough to cover any legal challenge that might be expected. Eg. smartphones etc. would get top of the line testing and certification. An automatic pet feeder would get the 'ecomomy' certification given that any domestic competition is likely to come from relatively small competitors with limited funding for legal action to prove that the Chinese certification was not up to standard.To summarise, regulation is good up to a point but as always it seems to get ever more onerous over time as largebodies of regulators have to continue to justify their salaries by perpetually changing and 'improving' the regulations. Cost benefit analyses be damned!

author: Mr. Scram
author_rank: Super Contributor
timestamp: March 07, 2020, 01:46:29 am
content: I'm under the impression a lot of products are sold without any real certification or with certifications borrowed from other products.

author: ataradov
author_rank: Super Contributor
timestamp: March 07, 2020, 01:51:07 am
content: Yes, I (and probably others) would be more inclined to actually advocate certifications if it was not a pure hell at a very high cost.Most of the certifications are nothing but a way to extort money.It would be nice if Chinese managed to organize something like PcbWay, but for certifications - cheap, heavily automated service. And put all those greedy certification places out of business.

author: floobydust
author_rank: Super Contributor
timestamp: March 07, 2020, 02:27:49 am
content: Approvals and certification are a huge, fat industry, at least in North America. Because they have intimate knowledge of the standards and the expensive test equipment, and purport to have a government mandate.Formal approvals are $10,000-$50,000 for testing to one safety standard. A Dilbert kind of company can spend over $100,000 if they can't get the it right and mess around.Afterwards, it's $5,000 to re-open the file and make a small (component etc.) change, if you are lucky. $350/hr to talk to a certifier.You get charged lab tech time, any estimates or quotations are meaningless because any findings mean extra time and charges beyond the quotation. Certifiers have $cash$ revenue targets to achieve, to make month-end. The projects that get closed, money brought in, it's all part of their scorecard as a revenue-driven industry under the guise of 'safety'.It too bad approvals are so outrageously expensive- it kills any entrepreneurs/inventors from making and selling anything. Yet china sells unsafe products with no approvals, no liability, no morals.I think the largest mistake is thinking certification is doneafterthe product design, as a last step. This is totally incorrect. It's common for certification to have findings about a product, so you have to make changes to the pc board, components, firmware etc. which takes many weeks or months before you can re-submit for certification.

author: angrybird
author_rank: Regular Contributor
timestamp: March 07, 2020, 04:04:49 am
content: Quote from: splin on March 07, 2020, 01:32:22 amI understand what you are saying, and I totally agree that regulations cripple an industry, but I don't think I was clear enough on my point. My point was that the playing field is not level. People making the same products in the chinese are subject to massive restrictions and regulations while the chinese generally avoid them. IMHO imported products should always be subject tomore, not less regulations than domestically produced product in the same class. This is how you keep your economy strong and keep money from flowing out of the borders.This is what I meant when I said that America is doing something about it. I believe that consumers are more conscious about this than they were even a few years ago, and this means the government is becoming more aware of it as well. There is also a hilarious aspect to it - People taking matters into their own hands, buying chinese knockoff products they know are junk on amazon, opening them, observing them immedaitely malfunction break (as they were obviously going to do), then sending them back just so that they can leave a 1-star review with "verified purchase" next to it. I had never even heard of this concept, and I can't believe how many people I've talked to in the past couple years who are doing some variant of this. I would feel ashamed for this next one, but lots of people doing this too - Buying the cheap chinese knockoff tool online for a quick job on the house, using it and returning it when they are done with a 1 star review. I don't know how common it is but I've seen quite a few people mention this tactic on other forums as well. The bottom line is that everyone is becoming wise to the unlevel playing field and hopefully over the next couple years we see it leveled... finally!

author: duak
author_rank: Super Contributor
timestamp: March 07, 2020, 04:49:40 am
content: The playing field is also tipped in favor of corporations to keep competition out. For the past 30 odd years, who do you suppose participated in writing & OK'ing many of the regulations?When I designed for production I worked with our in-house safety approval people - one was ex-CSA. It was easier to have something passed if the components used eg., relays, switches, fuses, etc. indiviually had agency approvals. If the voltage was less than 42 VDC, it was far less exacting than above it. If the product can be operated from a wall wart that contains all the hazardous voltages, you can really simplify things.As far as EMI is concerned, you design something using certain rules and then you have it tested at a facility where it passes or fails. It's important to decide where the product is intended to be used. Home and medical are the tightest and industrial is less so.Having looked at some CNC machines imported from China, the better vendors use European modules like Siemens or Telemechanique rather than from their indigenous suppliers. Design, on the other hand violates many UL/CSA requirements such as adequate wire gauges and fusing of branch circuits. eg., one machine has a 40 A, 3 pole breaker on the input power, and that's it. The 18 ga branches are tapped off the mains bus without any current limiting devices whatsoever. This thing would never pass inspection, and so it never was. The same place has a 9000 CFM dust collector. The local fire department inspected the facility and wrote them up because you cannot have a dust collector larger than 5000 CFM inside a building. Here's why:https://www.cbc.ca/news/canada/british-columbia/abbotsford-fire-dust-explosion-1.3759400The video is quite interesting.Best o' luck,

author: angrybird
author_rank: Regular Contributor
timestamp: March 07, 2020, 05:21:10 am
content: I have never had trouble passing any certification or compliance test. I have to pay for it, just like the corporations do, and quite frankly for EMI and various compliance testing it takes me a lot less work and money to pass than a larger corporation. The larger the company, the less "nimble and quick" they tend to be.On the other hand, the china region products simply have no certification and this must change. They must pay for the same certifications in the country they sell into that a person like you or I (or that corporation) would have to pay to.It's funny, because not only do you get an uncertified product when you buy chinese, you also get junk. Not to sound offensive to any chinese people on here but it just blows my mind again and again how warped their view of "good quality" is. It's almost as if they have never seen a quality product before, but that can't be true, they copy quality products and turn them into disposable rubbish! It defies all logic. I honestly don't care as long as we start making them pay for the certs.

author: ataradov
author_rank: Super Contributor
timestamp: March 07, 2020, 05:27:57 am
content: Many American and European corporations actually get their FCC certification in India, where it is faster and cheaper. And if there was a team in India that actually worked on the product (as often the case), it is actually more convenient. So that theory does not work that well.Also, I do get a lot of great stuff from China at the price point I like. American corporations all decided that things either need to last for 100 years and cost a lot, or don't exist. I don't care for my thing lasting long, but I want the price I like. And China delivers here. And that's why they successful.

author: angrybird
author_rank: Regular Contributor
timestamp: March 07, 2020, 05:31:49 am
content: If you live a disposable life, I agree, china stuff works. Personally, I like to ponder my purchases well and only buy something that will serve me for a very long time if I care for it. This disqualifies 100% of items designed in china, and disqualifies many items manufactured in china. Everyone has different needs. I like to grow roots in places, care for the belongings that I am fortunate enough to have, and make them last as long as possible. Some people like to live in tents! That's cool too!

author: ataradov
author_rank: Super Contributor
timestamp: March 07, 2020, 05:35:59 am
content: It is not a "disposable life". Things improve over time and I more likely than not will want improved things. The most up to date oscilloscope from 15 years ago is trash now compared to a cheap Rigol of today.I'm selective with what I buy, but on average I'm very happy with the stuff I get from China. And I'm tankful that China exists and that they manage to make stuff affordable.Also, quality of western stuff steadily goes down. And the "brand" itself will only get you that far.

author: angrybird
author_rank: Regular Contributor
timestamp: March 07, 2020, 05:47:00 am
content: Quote from: ataradov on March 07, 2020, 05:35:59 am"The most up to date oscilloscope from 15 years ago is trash now compared to a cheap Rigol of today." -> This is absolutely incorrect. A better statement would be "A high end Rigol outperforms a high end oscilloscope from 15 years ago".That is great that the china stuff is affordable, but if you're like me and want something to serve you well for many years, it just isn't a workable solution. I speak from experience as I do have the unfortunate experience of buying chinese tools when in a rush and the fastest option is Amazon prime. I'm amazed at how quickly even a "high end"chinese tool can fail.I agree that western quality is going down, because they are forced to compete with chinese products being sold on an unlevel playing field to uninformed consumers. A majority (or all?) of those western brands whose quality is going down are manufacturing in places like china.

author: radioactive
author_rank: Regular Contributor
timestamp: March 07, 2020, 06:29:54 am
content: QuoteIf western quality is diminishing, it isn't because of China. If anything, it is because investors have determined that they can get better short term gains by forcing MBA types to make decisions by proxy that should be made by the engineers doing the work. Chinese quality has been going up for many years now and has become very good for many areas related to manufacturing/engineering/design. Short term strategies for profit only work for so long.

author: angrybird
author_rank: Regular Contributor
timestamp: March 07, 2020, 07:13:55 am
content: Quote from: radioactive on March 07, 2020, 06:29:54 amI think you are spot on with the MBA statement! Disagree on the china manufacturing quality, though. My experience with chinese quality is that it has become more consistent, but not better. I am excluding Taiwan from this because Taiwan is not china; Taiwan quality has been decent for some time and has definitely gotten better over time. I have quite a bit of experience trying to teach chinese engineers and my impression is that there is no actual design that takes place in mainland china

author: ataradov
author_rank: Super Contributor
timestamp: March 07, 2020, 07:16:31 am
content: You clearly have a china-basing agenda, that's fine.But whatradioactiveis talking about not the crap you buy on eBay. But actual manufacturing equipment. And it is quite good, since they have a lot of demand for it inside the country, given that they still manufacture stuff.

author: Mr. Scram
author_rank: Super Contributor
timestamp: March 07, 2020, 01:47:05 pm
content: Can we please make this thread about certifications, something practical many people have to deal with? We really don't need another thread full of protectionist fence building and patriotic flag waving, no matter the colours of that flag.

author: angrybird
author_rank: Regular Contributor
timestamp: March 07, 2020, 03:00:57 pm
content: I think I deflected the thread a little bit and I didn't realize I would attract a communist to it... Sorry about that

author: OwO
author_rank: Super Contributor
timestamp: March 07, 2020, 03:09:08 pm
content: If it doesn't touch mains and isn't an intentional radiator, I wouldn't worry about it. Do some basic testing with a spectrum analyzer and near field probes, get rid of high peaks if any (by e.g. enabling spread spectrum clocking), and then slap on the CE logo. FCC is easy to get around with the subassembly thing, and there are plenty of exemptions (for example test equipment is exempt).Quote from: angrybird on March 07, 2020, 07:13:55 amTeach who? I work for a tiny R&D contractor and we put out designs that are disruptive in terms of performance per cost, and I'm sure there are thousands if not more similar outfits here. How else do you explain that the mainland is the biggest market for test equipment?

author: angrybird
author_rank: Regular Contributor
timestamp: March 07, 2020, 03:17:28 pm
content: Quote from: OwO on March 07, 2020, 03:09:08 pmI think any cable that handles a reasonable amount of power should also be closely looked at. I've had two micro USB cables from amazon suffer red-hot fire-starting heat on the end when the power pin broke through the plastic insulating layer and touched the shield... The cables were advertised as being good for 2.4A, but were plugged into a samsung 2.0A charger and that was all it took to make them glow red. I shut the light off in my office one night and saw this glowing thing on top of a stack of papers, it was the end of the cable. Confusing at first, then very scary!I am not sure what safety standard would even apply to a bare USB cable being sold? If any?

author: Cerebus
author_rank: Super Contributor
timestamp: March 07, 2020, 03:24:28 pm
content: Quote from: blueskull on March 07, 2020, 07:56:49 amBe aware that the poster in question had two sock puppet accounts banned yesterday. As it happened publicly I don't think I'm out of place mentioning this out in the open. For various reasons I think that this is just an attempt to bait you, not least the recent creation of the account, the speed with which a new account moved to an average 12 posts a day and the association with two recently created sock-puppet accounts.Be the bigger man and ignore the little tit.And with that, I too am going to shut up and ask that we keep the nationalism out of it and stick to the question in hand.

author: coppice
author_rank: Super Contributor
timestamp: March 07, 2020, 04:20:34 pm
content: Quote from: angrybird on March 07, 2020, 07:13:55 amI have quite a bit of experience teaching Mainland Chinese engineers, and they have exclusively been people doing actual design, and quite often very innovative design, in Mainland China.Many you just move in the wrong circles.

author: NiHaoMike
author_rank: Super Contributor
timestamp: March 07, 2020, 04:21:22 pm
content: In the US, UL/ETL listing is not required if the device does not work with high voltages or other hazardous items like lithium batteries.

author: Bark
author_rank: Newbie
timestamp: March 07, 2020, 04:59:46 pm
content: In most developed countries you must be a certified electricion to do any electronics for a building - Some countries are so strict on this that it can take 10 years to get the license to do this type of work independently! I would bet that they keep the liability insurance companies in business

author: Cerebus
author_rank: Super Contributor
timestamp: March 07, 2020, 05:11:32 pm
content: Quote from: Bark on March 07, 2020, 04:59:46 pmC'mon children, less of the playground games:

author: OwO
author_rank: Super Contributor
timestamp: March 07, 2020, 05:12:06 pm
content: I personally don't like the "certification and limited liability" way of governance and much prefer the "do whatever you want, but go to jail if your product kills people" model. Corporations seem to always find ways to design shit products that kill people, certification or no certification. It would be much better if the executives in charge would go to jail and be held personally liable for the corporation's actions.

author: coppice
author_rank: Super Contributor
timestamp: March 07, 2020, 05:16:08 pm
content: Quote from: Bark on March 07, 2020, 04:59:46 pmYou are right that many countries require certification to install and maintain eelctronics in a building, but anyone can design the stuff. Weird, huh?

author: Bark
author_rank: Newbie
timestamp: March 07, 2020, 05:18:32 pm
content: Even more ironic, the guys doing the end install in the building (the certified electricians) generally have no idea how much of it works (nor do they care to!)

author: frozenfrogz
author_rank: Frequent Contributor
timestamp: March 07, 2020, 06:19:36 pm
content: Quote from: OwO on March 07, 2020, 05:12:06 pmI hear what you are saying and agree, that personal responsibility and common sense should be a basic requirement. However, I also think that standardization has its merits in terms of: This is a proper way to implement things. There is no need in reinventing the wheel. The only thing I absolutely hate about standards, is the monetization side, i.e. "pay to play".In my mind, standards should be freely accessible to anyone and everyone free of charge. But in the real world, companies are pushing their means of doing things through a committee to make it a standard for everyone else. And if you have to implement said standard, you have to pay for getting access to the specifications. That is simply malicious.

author: fcb
author_rank: Super Contributor
timestamp: March 07, 2020, 06:52:53 pm
content: A good first step is to talk to your product liability insurer (you do have product liability??? right?), they usually ask pertinent questions.Unfortuatley if you want to sell worldwide then it is helpful to understand the legislation in each market - many markets have rules that follow closely with the US/EU. Less of a headache if your product doesn't transmit RF or is connected to mains. If you have competition, download their manuals/user guides and see what standards/certifications they are meeting.If you need to test, China have some amazing labs and weirdly Japan do as well (each prefecture has at least one lab, and the testing is pretty cheap if you can get it through a 'friend'). We buy standards through the Estonian Standards chaps (www.evs.ee), all done online and around 10x cheaper than through BSI etc..As others have said - test as part of your design process, not just at the end!Anyway, probably worth making sure your product is legal in your home market first.

author: worsthorse
author_rank: Super Contributor
timestamp: March 07, 2020, 08:45:28 pm
content: Quote from: OwO on March 07, 2020, 05:12:06 pm[\begin rant]That's an awesome idea until the product in question harms hundreds or thousands of people before the producer stands trial and goes to jail. Unforunately, given the world's current economic structure, government regulation is the only thing that levels the playing field between giant, wealthy corporations (which by the way are generally created in order to shield individual owners from liability for their actions) and individuals who don't have the resources to bring such corporations to account for destroying their lives.[\end rant]

author: ataradov
author_rank: Super Contributor
timestamp: March 07, 2020, 08:48:06 pm
content: Quote from: worsthorse on March 07, 2020, 08:45:28 pmBut in reality we already have a ton of stuff without certification. And thousands are no harmed.I doubt corporations with good brand recognition will intentionally make a really unsafe product.

author: Cerebus
author_rank: Super Contributor
timestamp: March 07, 2020, 09:09:54 pm
content: Quote from: ataradov on March 07, 2020, 08:48:06 pmSadly quite a few manage to make dangerous products despite the safeguards. The recent record of fires in the UK thanks to intrinsically flawed clothes dryers testifies to this.We need standards to create a minimum "level playing field", so that people who would design a product down to a pricewithout regard to the consequencescan't out-compete people who will be conscientious with product safety and thus have to spend more making a product while selling it into a market with a price established by those with no conscience over the harms their products may cause.What we have to guard against are standards that set an unnecessarily high standard that acts as a barrier to market entry which favours the big companies (who second people to standards bodies) or which acts as a unfair barrier to trade (thus skirting international legal protections against unfair trade barriers - as proposed by grumpy pigeon or whatever he's calling himself this hour).Looking at existing emissions standards and, to some extent, safety standards in terms of the compliance testing models and costs that have built up around them, I think we have failed at guarding against the barriers to market entry.

author: Mr. Scram
author_rank: Super Contributor
timestamp: March 07, 2020, 09:38:51 pm
content: Quote from: worsthorse on March 07, 2020, 08:45:28 pmThe huge prices and expensive specialists involved unfortunately also mean a divide is created between wealthy corporations and anyone else. Certification is nothing for major players but effectively bars small outfits from entering the market or at great risk.

author: coppice
author_rank: Super Contributor
timestamp: March 07, 2020, 09:39:04 pm
content: Quote from: ataradov on March 07, 2020, 08:48:06 pmPINTO!

author: Mr. Scram
author_rank: Super Contributor
timestamp: March 07, 2020, 09:41:58 pm
content: Quote from: fcb on March 07, 2020, 06:52:53 pmProduct liability insurers are likely to exploit any and all omissions or mistakes for the sake of dropping you as a customer when claims are being made. Doing your best to do everything right is no guarantee. If you're doing a custom or prototype device I don't see how any insurer would pick up the tab unless you've guilded the lily and jumped through all the hoops.

author: worsthorse
author_rank: Super Contributor
timestamp: March 07, 2020, 10:00:20 pm
content: Quote from: RiffRaff on March 07, 2020, 09:36:22 pmI had to do the interweb thing to figure out what you were talking about... it would, wouldn't it? That said, I am referring less to cornballer level problems and more to stuff like thalidomide or the fiasco with automobile air bags.

author: floobydust
author_rank: Super Contributor
timestamp: March 07, 2020, 10:07:41 pm
content: The MBA management school way is to put pressure on to get the product to market ASAP. Profit is king, shareholder return, quarterly numbers - all that matters.Because safety certifications add a delay to immediate profit, moreso if there are findings and the product needs design changes- it is best to sneak around and circumvent certification.How I have seen it rationalized:"It doesn't need to be certified, it can't hurt anyone. It's safe""Certify to the oldest, lax standard we can find""Chose a crappy agency with idiot certifiers who let anything pass""Lie about how the product is actually used, so no testing is really needed""Give it no name brand. That way, it's untraceable to us for liability"Generally, I see Engineering is starved for support and pushed hard to finish the product. You can't actually make something safe in some corporate environments.Boeing has reached the pinnacle for making unsafe products, after killing hundreds of people. I think something has to change with corporate governance and liability.

author: fcb
author_rank: Super Contributor
timestamp: March 08, 2020, 12:17:00 am
content: Quote from: Mr. Scram on March 07, 2020, 09:41:58 pmPrototypes and custom units might be covered, although depending on the scenario might also be covered by “professional indemnity” insurance.Of course doing your best is no guarantee - but I don’t consider doing mandated testing/certification as ‘gilding the lily’, and it’s probably a good idea to get a second opinion on anything that might sail close to the wind.

author: Mr. Scram
author_rank: Super Contributor
timestamp: March 08, 2020, 01:43:46 am
content: Quote from: fcb on March 08, 2020, 12:17:00 amCertifying one offs or prototypes seems to qualify as gilding the lily. There's a whole class of aircraft who get a lot of leeway due to being experimental or one offs. Something similar seems absent when it comes to electronics. I don't see how prototypes and custom units would be covered if the law doesn't provide exceptions for them.

author: fcb
author_rank: Super Contributor
timestamp: March 08, 2020, 09:56:39 am
content: Quote from: Mr. Scram on March 08, 2020, 01:43:46 amI was referring to the liability element, not the certification of prototypes.If I make a prototype for a client, and it burns down their facility - it would likely be covered by “product liability” - in that case I would have to show that the unit was in-compliance with any rules/regulations just as much as any series produced unit. You get round this to some extent on prototypes by making them sign a waiver.If you crash your experimental aircraft into someone’s property you’d assume that your insurance would cover it - that’s why they have low weight limit.Technically if I build a prototype device and it starts emitting RF out of ISM band limits - I am immediately in breach of the Wireless Telegraphy Act 1949. No ifs - no buts.EDIT: Or it’s covered by my radio amateur license..

author: skyjumper
author_rank: Regular Contributor
timestamp: March 11, 2020, 06:47:09 pm
content: This is a great thread, I'm in the same position as OP, getting ready to launch a small run niche product and trying to understand the certification requirements. From reading, am I to understand that there are not in fact criminal penalties, at least in the US, for selling a device that lacks FCC certification? Or in Canada?I got a quote for a certification service, it was relatively low at about $10,000 US. IIRC, it was $1,800 for FCC, $600 for whatever Canada calls it and a whopping $7,500 for two different CE type certifications for Europe. I can swing North America, but wow, CE, wow! Not only is it a lot of money out of pocket for a label, These costs really add to the final price of the product.

author: fcb
author_rank: Super Contributor
timestamp: March 12, 2020, 11:35:36 am
content: With some exceptions (radio).CE is just a declaration that your product meets the applicable standards.You can ask (&pay!) for the 'opinion' of testing lab, include their report (more$$) in your TCF (technical construction file - might be called something else these days, but we still call it that). But it is just that, it is their opinion (based on tests), that the one sample of your device has been tested to a certain standard and found to be in compliance.So if your device was a battery flashlight for adults (as in bulb and alkaline cell) - you could easily skip EMC tests and argue (if it ever came to it) that it was incapable of generating EMI outside the limits. You could even wave a near field RF probe over it and capture screen grab the spectrum analyser for your TCF.But what happens if..So lets say your competetior gets pissy with you and your flashlight, they can PAY for an EMC lab to test your product and write a report. Then submit that report to who-knows as a reason to get your product banned from sale, repeat x26 countries and your flashlight might just end up on a list for customs to seize.As far as I know this only used to happen between laptop maufacturers.Customs are far more bothered about imported toys without secure battery compartments, or leaded paint, or toxic sofas.https://www.poison.org/articles/button-batterieshttps://www.cdc.gov/features/leadintoys/index.htmlhttps://www.theguardian.com/commentisfree/2020/feb/26/toxic-sofa-eu-red-tape-flame-retardantsIt's not unreasonable to use your FCC testing (with some maths) as evidence for your TCF.

author: EEEnthusiast
author_rank: Frequent Contributor
timestamp: March 12, 2020, 12:03:12 pm
content: Many products without an intentional radiator (non wireless devices) can be released to the market using a SDoC (Supplier's Declaration of Conformance). This process does not require the product to be certified in a lab or by a 3rd party. It requires the manufacturers to ensure that the product meets the requirement by means of measurement. If the manufacturer can ensure that the product is safe for EMC and other specifications, they may release the product to the market using the SDoC. The SDoC is valid for FCC, CE. I am not sure for other markets.Some good sourceshttps://www.tele.soumu.go.jp/resource/j/equ/mra/pdf/30/e/03.pdf

author: splin
author_rank: Frequent Contributor
timestamp: March 14, 2020, 01:04:40 am
content: One aspect that I've never seen discussed is the impact of software/firmware on EMI emissions from a product. Specifically the need to revalidate emissions with any firmware updates. How often do you suppose that ever happens, even for the big players?A firmware change could have a big, easily predictable impact if it added or modified a feature such as changing a USB I/F from lo-speed to full-speed, or slightly less obviously to increase GPIO port drive strength to improve reliability of a signal. In the first case you would almost certainly have to repeat the EMC testing; in the latter it would be a matter of judgement/risk tradeoffs.But what about a 'minor' change such as a security or bug fix? A debugging/hacking technique that was ocaisionally used in the past was to place an AM radio close to the device. You could deduce certain patterns of behaviour from the interference caused - eg. a busy wait loop would be very different from complex code execution (so you could tell, for example, when a program was running out of control).In most cases varying code execution patterns wouldn't be an issue (unless the original certified product had very trivial code). But emissions can be particularly sensitive to peripheral usage on microcontrollers, especially clock related. Doubling an ADC clock rate for example, to improve analog resolution or for higher bandwidth could cause emission limits to be breached.Problem is the programmer may have little understanding off these consequences so it would require a suitably skilled engineer to review the code changes to make the decision to re-test or take the risk of not doing so.Another example; a purely software implementation of some security code is updated to something more secure using the microcontroller's inbuilt encryption unit. The engineer responsible for certification might not even be aware that the implementation had changed substantially, perhaps assuming that the hardware encryption peripheral had always been used.Be honest - how often have you gone through an expensive EMC re-test following a firmware update?

author: coppice
author_rank: Super Contributor
timestamp: March 14, 2020, 01:11:19 am
content: Quote from: splin on March 14, 2020, 01:04:40 amSome firmware updates are specifically dishonest. Run firmware that turns on spectral spreading. Test. Change firmware to turn off spectral spreading. Ship.

author: fcb
author_rank: Super Contributor
timestamp: March 14, 2020, 01:18:54 am
content: Sometimes (the opposite of cheating) you have to run special FW for EMC testing.Had to do this in the past for things like full 150KHz-30MHz sweep on a product (takes over 30 mins per line/neutral, conducted emissions with quasi-peak) - product shut off way before sweeps ended.

author: NiHaoMike
author_rank: Super Contributor
timestamp: March 14, 2020, 01:22:38 am
content: Quote from: splin on March 14, 2020, 01:04:40 amWhat about if the product is designed to run software or firmware developed by a third party or end user and the manufacturer has little or no control over it? For example, the Raspberry Pi is FCC approved, but it's pretty easy for the end user to program it to be a FM jammer.

author: splin
author_rank: Frequent Contributor
timestamp: March 14, 2020, 01:52:50 am
content: Quote from: coppice on March 14, 2020, 01:11:19 amOf course that's possible, but why what would be the motivation? I guess it would apply to applications requiring as jitter free clocks as possible including ADCs, but will only pass testing with spread spectrum clocking enabled.The only reason I could think of for what you suggest is because you need a certificate to sell your product into a particular market but believe the probability of being challenged for non-compliance subsequently is slim.So do you require EMC certfication (for non-intentional radiators) for the US, Australian, Chinese etc. markets?If not, why bother with testing? CE compliance doesn't, AFAIK, require certified EMC testing (for non RF devices at least) but you might want it for protection in the event of a complaint about your products emisions.

author: wizard69
author_rank: Super Contributor
timestamp: March 14, 2020, 03:40:48 am
content: If you are connecting to mains and switching or otherwise interacting with the mains, I wouldn't ship until you have certification, insurance and some sort of corporate protection. Certification isn't enough. The plant I work in requires UL certification on all (ALL AS IN EVERY THING) equipment connected to the mains. That means every thing including a desk lamp As for insurance & corporate identity, that is to protect you some bozzzo that kills himself doing something he shouldn't have done.It is a good idea before going into "business" to realize what your exposures are. Here in the USA we have the SBA offering up courses for people that want to go not business for themselves. I actually took one of these seminars and frankly it turned me off to the idea of going into business for myself. the legal landscape is that bad and you really need a product that can sustain a business out of the box or have a deep bank account.

author: Psi
author_rank: Super Contributor
timestamp: March 14, 2020, 03:44:31 am
content: Yes, if you are making/selling your own gear as a hobby business always buy and then resell a pre-certified DC power brick to your customers to power your low voltage product.Never try to roll your own mains voltage PSU as part of your product.And make sure the power brick is from a known good brand.Go to their website and download/save all of the PSU's certification docs before you sell it. Have the docs on file in case you need them.You don't want to use a certified power brick and then not be able to provide the documentation to prove it later on.

author: skyjumper
author_rank: Regular Contributor
timestamp: March 14, 2020, 07:25:40 pm
content: My product is an "intentional radiator" because it has WiFi and BT/BLE, all from a certified ESP32-WROOM module. I understand that using a certified component does not make my product certified, but I was thinking that it would make designing a product that will meet certification easier. Given it is an intentional radiator is there a mandatory testing requirement?

author: ataradov
author_rank: Super Contributor
timestamp: March 14, 2020, 07:28:03 pm
content: You can transfer module certification to the product certification. But this works if you only have one intentional radiator. And I'm not sure what happens if the module itself contains two radiators. You may want to research that.

author: skyjumper
author_rank: Regular Contributor
timestamp: March 14, 2020, 07:30:32 pm
content: Quote from: ataradov on March 14, 2020, 07:28:03 pmInteresting... Well the ESP32-WROOM-32U uses a single hardware radio for both WiFi and BT, so I think it's fair to say thats only one radiator, unless there is law or regulation that says otherwise.But what does that mean exactly, transfer certification?

author: ataradov
author_rank: Super Contributor
timestamp: March 14, 2020, 07:35:09 pm
content: I'm not sure about the details. The concern there is that combined power may exceed limits even if single radios pass. So if ESP32 uses the same antenna and by design only one radio can operate at a time, it might be fine. But I would definitely do more research.Yes, and the key point is that module must actually have modular certification. It is different from a final product certification.

author: skyjumper
author_rank: Regular Contributor
timestamp: March 14, 2020, 07:37:56 pm
content: Quote from: ataradov on March 14, 2020, 07:35:09 pmYes just one antenna and, I think, either WiFi or BT at any given time. Thanks very much I'll investigate.

author: palindrome
author_rank: Contributor
timestamp: April 22, 2022, 02:18:02 pm
content: Quote from: ataradov on March 05, 2020, 04:20:15 amThis is an excellent thread. I have been working on a product for a couple of years and I think I am at a stage where I could manufacture a small run.My device does not have any intentional radiators. The problem I am facing is that my device is using an internal power supply - it is a certified PSU with a metal chassis.I see that other niche products from the same segment use exactly the same power supply and I am fairly certain they did self certify their products (small volume and full certification costs wouldn't make it viable).Is having such power supply going to get me in trouble (I am also using IEC inlet filter and I think all the wiring from inlet to PSU is properly done) or is it better to use an external power adapter?I am planning to order a first batch of enclosures and it would be a pain if it turns out I should have used an external power adapter (patching IEC inlet cutout to fit XLR connector would look awful).I am probably not going to sell more than 50-100 units.What I have against external power adapter is cosmetic and customers would prefer to connect to mains and that I would have to buy a large volume of these power adapters (likely more than I would make my devices with) and they are more expensive than internal PSU (it is a renowned brand and has all certification).

author: ataradov
author_rank: Super Contributor
timestamp: April 22, 2022, 04:17:01 pm
content: Quote from: palindrome on April 22, 2022, 02:18:02 pmOnly lawyers in your jurisdiction would be able to tell for sure.Anything having to do with mains is better safe than sorry, IMO.

author: floobydust
author_rank: Super Contributor
timestamp: April 22, 2022, 04:49:13 pm
content: Just because a power supply module is "certified" doesn't mean the implementation ended up safe. Tell me about your AC mains fuse.The power cord, strain relief, terminal blocks, fuse, grounding etc. - all must be approved components and used properly.Are you using child labour for the soldering, an example of why an approved manufacturing facility is also something agencies require to guarantee the assembly is professionally done.A common mistake is thinking a PSU module is certified, when cheap manufacturers will stretch it, i.e. in the little datasheet schematic it shows you must add EMI filtering and a fuse+MOV, and a certification agency will treat it just as a component that gets to go along with the formal product testing.Even a wall adapter/brick a few don't actually have proper approvals, it passes one subset or EMC partially and that is all over the datasheet to mislead people. Always get a copy of their safety certificates and go over with a fine-toothed comb, to know if any loopholes were used.It's unfair and terrible for the small guy that chinese products enter the country by the zillion having no approvals whatsoever, and we allow it to happen.For small batches sold locally, I've used special inspection services where an inspector looks at each device and issues a sticker if it passes hi-pot and other requirements.

author: nctnico
author_rank: Super Contributor
timestamp: April 22, 2022, 04:58:28 pm
content: Quote from: palindrome on April 22, 2022, 02:18:02 pmGo for the external power adapter otherwise your device is connected to mains with all the safety requirements that come with it. I 100% agree with what floobydust wrote. 'Certified module' is an empty phrase.

author: palindrome
author_rank: Contributor
timestamp: April 22, 2022, 06:36:05 pm
content: Thank you so much for help! I am going to use an external power adapter then.QuoteFortunately they sent me "paperwork" with the samples, so I will review it.

author: Kerlin
author_rank: Regular Contributor
timestamp: April 23, 2022, 03:55:00 am
content: As some one who has spent the last eight years in international Avionics, believe me you don't want to ignore the RF interference requirements.It HAS happened.All aircraft instruments communicate and take many types of sensitive and exacting navigation measurements by using RF.On frequencies from H.F. to Microwave.They will fly over your equipment.I will give this yet advice again, it was taught to me by a former employer and has worked for me, hundreds of times.How they "over there" get their products approved and still manage to flood markets with rubbish is that they have their own world wide certified test houses. I know I worked "over there" for years as an E.E., and sometimes still do projects there.If you go about it the right way they can be very "co-operative" and don't charge any where near as much.USE them or definitely risk sending yourself broke one way or another.

author: penfold
author_rank: Frequent Contributor
timestamp: April 23, 2022, 07:43:29 am
content: Quote from: palindrome on April 22, 2022, 06:36:05 pmAlternatively, there are some PSU product families (at least from TDK Lambda... depends on your price point though) that, whilst intended for "internal" installation, have an integrated IEC socket intended to be butted up against the side of the enclosure quite similar to how a classic ATX PSU is installed. I only mention because an external PSU can be a bit of a minefield unto itself, though applicability may vary, just some things to think about: firstly (as with any solution) it must be appropriately rated for the useage environment (i.e. overvoltage category and industrial/commercial EMC) which may not necesarily be an easy find for industrial environments; secondly you typically lose the mains earth connection, given that most external units are isolated, and that may be useful in a broader systems EMC; and whilst you have still guarded yourself against the noisyness of the switcher, there is still possibility of radiation from common- and differential-mode noises, from your system on tthe DC side that will (with an external power adapter) be allowed outside the enclosure. Again, any of those points may or may not be applicable to you, mileage may vary... just something to think about.

author: fcb
author_rank: Super Contributor
timestamp: April 24, 2022, 02:30:27 pm
content: Palindrome.If you take your product to a testing lab and spend (£3-4K) on testing it and get a nice report (usually another £1K) all you really have is their OPINION that this unit, on this date, under these conditions met this standard, etc..You can put this report in your TCF (technical construction file) or whatever they call it these days, and this will help you if you ever get hauled-over-the-coals.The reality is that almost no one in the last 25years has been prosecuted. There have been odd cases of laptop maker A paying for latop maker B's product to be tested and then whining to some authority to block their import, but nothing I have seen for many years. Authorities spend their time focused on firey escooter battery chargers, toys with accessable batteries, lead paint, choking hazards, etc..If you fit a nice TDK PSU you are just as liable if it squirts all over the spectrum as if you fit a NONAME unit - however the reality is no one will really care and you are fairly safe. YMMV.My main recommendation would be setup an LTD company (£13+ongoing accountacy!), get your company some product liability insurance - Hiscox for about £2-300/yr. depending on product. Remember that regardless of paying an EMC lab or not - you are always self-certifing the product.

author: Kerlin
author_rank: Regular Contributor
timestamp: April 25, 2022, 06:16:39 am
content: For sure some of what fcb says above is true.If there was a prosecution it would be against a local company.I have been told the rules are mostly only enforced on local companies.I know in many countries "they over there have" an official Favored Trading Nation status. Why?I have always had a feeling feel there is some thing very sus about the whole compliance thing, remember I have worked over there and seen what goes on.In fact when I worked there I was trained in how to go about it.

author: penfold
author_rank: Frequent Contributor
timestamp: April 25, 2022, 07:58:13 am
content: Quote from: Kerlin on April 25, 2022, 06:16:39 amI was under the impression (at least from a UK perspective, generally, though some more special arrangements exist) that it is the responsibility of the retailer, the entity that puts the device in th market place, that assumes responsibiliy for the certification of a product, though could just as eaasily be the importer, talking mostly about small producers and resellers since larger corporate entities can have slightly more negotiated and delegated responsibilities - also ignoring medical and functional safety related products. If a product produced by company "X" is purchased by company "Y" and resold to company "Z" before being "marketed" to consumer "U" - the responsibility of ensuriing compliance lies with the reseller "Z": which formally is because the certification relates to the advertised useage of a product rather than its original designed function. In real-life, reseller Z may (informally) delegate the respopnsibility of compliance Y, who delegates to X - if a legal dispute arrises the first priority of conviction would be anybody making an unsubsantiated claim about the product.The word "practicable" could very easily feature as can "risk"; a low-volume and low-price product doesn't necesarily warrant a full testing and certification process, but the manufacturer/designer would be well advised to document all the reasons and motivations for not formally-testing along with all the mittigations and design choices. What fcb said is still perfectly valid, but even an insurer would want to see that one wasn't being reckless or negligant.

author: fcb
author_rank: Super Contributor
timestamp: April 25, 2022, 03:55:09 pm
content: Quote from: penfold on April 25, 2022, 07:58:13 amEMC/CE/etc.. It's all a bit like the parking at my business unit:In theory we have clearly defined (in the lease) parking spaces. The reality is that everyone parks in the most convienent space and we all just get along nicely & quietly - someone once suggested marking out the spaces, that idea was very quickly gelded - things just seem to work well as they are.I think a good part of the reason things aren't enforced is that no one really complains about EMC. FHSS, digital TV, DAB and streaming radio all seem to still work well enough so people don't correlate low-bit rate events with RF noise anymore - I certainly remember the days when next door vacuuming would show on the TV as black speckles, or you could hear a motorbikes ignition on the radio - these things may well be generating the same RF crud as before, you just wouldn't notice it now.And since the legislation was introduced in Jan 1996 I have NEVER been asked for a copy of a products TCF.

author: penfold
author_rank: Frequent Contributor
timestamp: April 25, 2022, 06:12:42 pm
content: Quote from: fcb on April 25, 2022, 03:55:09 pmI like that analogy, but I wonder what lengths people would go to if, in the unlikely event of some upset, the penalty for having caused the upset was getting their car crushed - though I'd also suspect that one of the reasons to not mark parking spaces would be that it increases council tax rates. From my perception of it, EMC is just one of those nightmare issues thats invisible, often counter intuitive, potentially high penaltied, expensive and time consuming to measure and correct, and very difficult to portray a pragmatic approach to without sounding slap-dashed. Something I forgot from my previous post was that the user manual and any exclusions to the devices useage are also quite important, i.e. making clear whether it is commercial or industrial, for integration within a larger system or not, listing suitable external power sources etc

author: Psi
author_rank: Super Contributor
timestamp: April 26, 2022, 12:30:11 pm
content: Quote from: fcb on April 24, 2022, 02:30:27 pmTrue, but the TDK PSU is MUCH less likely to squirt all over the spectrum than the $1 aliexpress PSU.Quote from: fcb on April 24, 2022, 02:30:27 pmPretty sure in the event of an issue, the liability insurer would refuse cover you if you didn't have all the certs with all the I's dotted correctly. It's insurance, they are always looking for a way to avoid having to pay out.

author: fcb
author_rank: Super Contributor
timestamp: April 26, 2022, 03:43:02 pm
content: Quote from: Psi on April 26, 2022, 12:30:11 pmTDK vs NONAME - You pays your money and makes your choice - ultimately the only way to prove this is to test it. I'd sure trust TDK's documented test results more than a NONAME unit.As for the insurer covering you - they are covering the liability the product goes wrong and injuries people or property, not that it fails EMC. Unlikely they are protecting you if by some weird turn of events you get sued for emmisions (unless of-course they are the reason people/persons/property get injured). Also, it's important to keep pointing out - the EMC lab report is not a certificate - it's an opinion, there is no such thing w.r.t. EMC in the UK/EU as certification, there is in the US (FCC), but not in the UK - you are always self-certifying.Also, I'm not actually suggesting that manufacturers don't test, but that they understand the role it plays in self-certification.

author: fcb
author_rank: Super Contributor
timestamp: April 26, 2022, 03:52:09 pm
content: Quote from: penfold on April 25, 2022, 06:12:42 pmAgree, difficult to not sound slap-dashed. Probably also worth pointing out that I do test products I design and do advocate testing at a pucker lab (we only do precompliance - own EMC chamber, spec-ans analysers, LISN's, EMC receivers, antennas and a clean field site with tripod mounted York antenna, PMM receiver etc...).Defining in the manual who uses the products is a good idea.

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: April 26, 2022, 04:03:44 pm
content: Quote from: fcb on April 26, 2022, 03:43:02 pmAn EMC lab once told me that the only difference between a "quick-look, try what you can, tweak and repeat" day and a "formal" test is the lab's level of liability

author: coppice
author_rank: Super Contributor
timestamp: April 26, 2022, 04:33:25 pm
content: Quote from: fcb on April 26, 2022, 03:43:02 pmThe lab report is a little more than an opinion, but not much. The lab can only attest that one sample of the product on one day passed the compliance tests. Its the maker that is responsible for ensuring a production run consistently passes. Considering how much minor variations, like the torque on certain screws, can affect the outcome of a test, the lab's liabilities should be limited to ensuring they actually performed the tests according to the approval spec.

author: SiliconWizard
author_rank: Super Contributor
timestamp: April 26, 2022, 05:47:40 pm
content: You're not always "self-certifying". There are a number of regulated domains, such as medical devices, for which you can't self-certify. A notified body certifies your product. But you must provide all relevant technical documentation and test results. The notified body emits the certificate.A properly accredited lab can provide test reports that conclude on compliance with some given standards. Of course, it's not up to the lab to then conclude if the whole product is conforming to any standards or directives it's supposed to be compliant with.For classes of products that can be self-certified, then it's indeed the full responsibility of the company selling the product. You may even not have anything tested in a lab. But since you're claiming that your product is compliant, if you have no proof of the fact it is, then you'll obviously get into trouble if anything goes wrong in the field.

author: coppice
author_rank: Super Contributor
timestamp: April 26, 2022, 06:24:42 pm
content: Quote from: SiliconWizard on April 26, 2022, 05:47:40 pmThe lab's certificate merely says one sample of the product worked to spec on one day. You still self certify that that the production run is up to the same standard. Nobody else can. Smart customers sample test production batches. You can't hold the lab liable in any way for samples of a product that don't meet the spec. You can only hold them liable if they didn't perform the tests properly.

author: penfold
author_rank: Frequent Contributor
timestamp: April 26, 2022, 07:37:04 pm
content: Quote from: coppice on April 26, 2022, 04:33:25 pmThat's an interesting point. Firstly with the "little more than an opinion", I guess, as a type-test or design proving or verification exercise, it's only a statement considered universally valid on the day of the test with particular test gear, operator, room, weather, etc for that single (or few) DUT(s) built to whatever spec they were built to... I'm not sure I'd say opinion, but there is a fair amount of tenuousness in saying the results are true for every product coming off the production line. But with the ensuring all products off the production line meet the same spec, I wondered about this previously, because, even with so much weight put on the importance (or as it appears within the electronic engineering community) of good compliance data and test results, etc, my first instinct is product consistency is almost more important. I don't know if that's a common instinct, but it does concern me a little bit that "EMC testing" can start to appear more like a project manager's milestone whilst "making sure the documentation genuinely defines the product" can get pushed back. And yet, from last time I read up on CE/UKCA marking, I couldn't find anything that really settled my inner argument...But yeah, if a product turned out to be a disaster, gotta be able to work out the extent of the disaster.

author: karpouzi
author_rank: Newbie
timestamp: November 09, 2023, 08:02:48 pm
content: Quote from: ataradov on March 05, 2020, 04:20:15 amAre there any people who simply delay full compliance for a time until the product sells? Even if it means a new board revision and label for the next batches. Do regulators really go after small-volume startups?Compliance testing may be just a "business expense" for corporations, but it squashes small startups who don't have the money, or the knowledge whether their idea will actually sell or not. Even using a "pre-certified" Bluetooth module, your compliance starts at $20K (Bluetooth qualification fees, CE+FCC testing) just for US and EU market access.

author: coppice
author_rank: Super Contributor
timestamp: November 09, 2023, 08:13:20 pm
content: Quote from: karpouzi on November 09, 2023, 08:02:48 pmIf that small startup annoys one of the big players, its not unknown for them to set the regulator's on the startup as a way of shutting them down - at least for a while.

author: Kasper
author_rank: Frequent Contributor
timestamp: April 01, 2024, 06:01:23 pm
content: Quote from: coppice on November 09, 2023, 08:13:20 pmWhat does 'shutting them down' mean? Just can't sell any more until you get appropriate certifications? or fines or jail?

author: Kasper
author_rank: Frequent Contributor
timestamp: April 01, 2024, 06:45:16 pm
content: I made a table with some addressable LED strips in it, now I want to try selling some. Doubt I'll ever sell more than a few a month. Will probably only sell in Canada.I'm hesitant to sell any before sending it to an EMC lab but I'm hesitant to pay for EMC testing before I see if anyone wants to buy them. I don't have much appetite for risk. After working for about 20 years, I've amassed enough savings to worry about getting sued and losing it.It's been a while but last time I talked to an EMC lab, they wanted the final version of the enclosure and said any significant changes, particularly to metal components like screws should get retested. Sounded more like a recommendation than a requirement but I can't really remember, it was just a conversation years ago.Each piece of furniture will be hand made from live-edge wood, different shapes and sizes, different location of metal table legs and fasteners. Different lengths of LED strips. LED strips adhered to a metal plate that will be different size in each unit.Should I send each one for EMC testing or can I just get the electronics certified and ignore their 'enclosure'?If I just certify the electronics, would it be reasonable to go with the most LEDs I intend to use and expect some units will have less LEDs?If first unit is far enough below the limits, would that justify not sending the others?Should I sell a few to see if anyone wants them before I do EMC testing?Are there any other regulations for me to satisfy as well?I have a sole proprietor business right now focused on electronics contracting. Should I make a separate business, incorporate and get insurance before I sell any?What's the worst that can happen?What would you do?Power supply: USB-C (5V, dumb) with removable off the shelf USB battery.Regulator: 3.3V linearMCU: RP2040LED strips: 3 wire addressable (WS2812B). Up to 8 strips in parallel. Each about 1m to 2m long.LED wires: data from RP2040 goes through level shifter then 470ohm resistors then a foot or 2 of wire to LEDs strips.UX: trimpots and power switchIntentional radiators: none

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: April 01, 2024, 07:41:26 pm
content: Quote from: Kasper on April 01, 2024, 06:45:16 pmThat's what limited companies ( or equivalent in your country) are for.QuoteDesign it in such a way as to be reasonably confident that it would pass, but not waste money on testing.In jurisdictions like US and Canada I'd probably be more concerned about things like fire safety (overcurrent protection etc.).

author: BrianHG
author_rank: Super Contributor
timestamp: April 01, 2024, 08:20:01 pm
content: Quote from: Kasper on April 01, 2024, 06:45:16 pmMake sure you use an 'enclosed' fused power supply which has authentic UL/CA approvals. (No Aliexpress/Amazon Chinese garbage clone supplies, use authentic name brand stuff only.)This will get you around everything except FCC.For US FCC, just make sure you don't have any intentional radiators and when driving the LED strip's data lines, use the proper series resistor at the IO pins of your MCU so that you aren't driving a harsh super fast square wave into the wiring feeding the LED strip. (I think you said you have a 470 ohm series resistor already...)Follow these rules and you shouldn't have any problems in Canada, or the US.Fail on the UL/CA approvals for the power supply, then if your product creates a fire somewhere, the insurance company who pays out the damage and finds out during an investigation may come after you for some $$$.

author: Kasper
author_rank: Frequent Contributor
timestamp: April 01, 2024, 10:14:02 pm
content: Thanks for your responses. Here is what I'm thinking of for the power supply:Battery:https://www.amazon.ca/Anker-Portable-Charger-High-Speed-Charging/dp/B0BYP4Y1N8Wall plug:https://www.amazon.ca/Charger-Anker-Compact-Foldable-Included/dp/B0B2MMYZPLUser can leave the battery out and plug USB-C from wall plug into my device or they can plug battery into my device and charge it as needed.Does Anker count as cheap garbage? They rank well on lots of review sites and I've used them at home without problems.

author: BrianHG
author_rank: Super Contributor
timestamp: April 01, 2024, 10:46:20 pm
content: Quote from: Kasper on April 01, 2024, 10:14:02 pmAnker appear to be a modern compact Gan wall plug.However, what's important are the 'approvals' like UL, CE, CA listings.Their approvals arent shown on the Amazon website.

author: Kasper
author_rank: Frequent Contributor
timestamp: April 02, 2024, 01:10:34 am
content: Quote from: BrianHG on April 01, 2024, 10:46:20 pmIt seems approvals aren't often shown online. Couldn't even find them for Apple or Samsung, though I didn't look too hard. The ones in my home do have a variety of stamps at least.