Kickstarter Projects and CE Marking (And other certifications) - Page 1
Forum section: electronics / projects

author: 8086
author_rank: Super Contributor
timestamp: November 21, 2012, 11:21:10 am
content: I'm designing a project, that I intend to crowd-fund. It connects to 240V mains, and has a small SMPS module inside, with 3.3V out. All of the electronics is actually 3.3V, but there is also a solid state relay switching 240V so I figured to save having two power leads, I would just tap into that supply. So I'm looking at LVD and EMC certifications.In case you hadn't guessed, it's a reflow oven controller. I should add that the device is separate to the oven, not built in. So don't have to test the oven.So I've been reading up on CE marking - as I suddenly had a moment of realisation that if my thing is to connect to the mains supply, it might need CE.Now, since I'm not exactly made of money, and the expensive CE marking process as I understand it would steal just about all of the profit from this venture, what options do I have?Is it allowed to have a warning that the product is "R&D only" or something, and avoid the CE mark altogether?Also, RoHS is due to become part of CE in January - does this mean if you use even one part that isn't RoHS you can't ever have a CE mark? How would you sell your product?Cheers.

author: Unknown
author_rank: Unknown
timestamp: November 21, 2012, 12:01:22 pm
content: Quote from: 8086 on November 21, 2012, 11:21:10 am"R&D only" means in essence that the thing is not allowed to leave the lab. Selling it is out of the question. The only exception I am aware of is the kit airplane industry where each individual plane is inspected after completion and is required to display "EXPERIMENTAL" decal to warn prospective passengers that they might not want to fly in the thing.

author: AndyC_772
author_rank: Super Contributor
timestamp: November 21, 2012, 12:11:24 pm
content: If you're placing a product on the market in the EU, you have to CE mark it. I wrote a fairly lengthy explanation on the responsibilities this entails here:https://www.eevblog.com/forum/general-chat/the-path-to-commercial-product/msg159489/#msg159489RoHS applies already, and the fact that it's not currently part of the CE regime doesn't really make a difference to what components you may or may not use in your product. The simple rule is that, apart from some specific exemptions for particular types of component, NO component in your product is allowed to be non-compliant. If you have a non-compliant component in your product, you need to design it out.A small volume manufacturer might, of course, simply use the non-compliant part anyway and take the risk that nobody will ever notice - but I couldn't possibly advise you to do that as it would be illegal.Given that you're dealing with the mains, I'd strongly recommend that you get it properly safety tested and certified - and yes, I know that's expensive. Sadly there's no 'hobby' or 'small volume' get-out clause anywhere.

author: EEVblog
author_rank: Unknown
timestamp: November 21, 2012, 12:20:46 pm
content: You can market and sell it as a DIY kit.Or a "short form" kit, or even just the blank PCB.Dave.

author: Kremmen
author_rank: Super Contributor
timestamp: November 21, 2012, 12:25:10 pm
content: Firstly, your "apparatus" as the EU Directives name it, falls under Directive 2004/108/EC for EMC. If you place it on sale in the EU, then you must declare conformity. The declaration actually requires 2 things:1: you must explicitly declare conformity (usually this is on a leaflet accompanying the product) and keep it available to the enforcing authority for 10 years after the last date of manufacture of the product. It must include these items:- a reference to the EMC Directive,- a description of the apparatus to which the declatarion refers to,- the name and address of the manufacturer and its authorized rep,- dated reference to the spec under which conformance is declared,- the actual date of the declaration,- signature of an authorized rep of the manufacturer (the actual words are "empowered to bind" in the Directive)2: affix the CE mark on the actual apparatus. If this cannot be done then in one of the following in this order: packaging, instructions, conformance guarantee leaflet.Secondly, sorry, no go. R&D gizmos are definitely in the scope of EU EMI Directives - no exception there. If you can camouflage your box as self-built radio amateur gear it is free. Should it be other radio stuff controlled by R&TTE Directive then that one applies and not the EMI Directive. Military stuff will be excluded. Same if you can claim it to be aeronautical equipment subject to EC Regulation 1592/2002 but then it has to be installed into commercial civil aviation aircraft only. Also equipment demonstrated in trade fairs is excluded if they come with labels saying measures are taken to limit EMI. Otherwise, no excuse.If you read the text (it is actually available in the net for free) you will see that it does not give any detailed guidance. It just says that your equipment must not cause too much EMI and it must tolerate a reasonable amount of it. All the details are in CEN, CENELEC and ETSI standards that control testing and validation for EMC. Your hands down easiest path is to assemble the apparatus from certified components carrying the CE mark already. Then you have the "get free from jail" card right there because you can also claim CE compliance, havin outsourced it from the component vendors. But be aware that while "apparatus" comes under the directive, "component" does not. So a wiseass vendor may claim compliance, knowing that he doesn't have to demonstrate it whereas you do if you use said component in your apparatus. The distinction between the two is a line drawn in water.You could try the "benign equipment" gambit but the presence of a SMPS in your design makes that very very iffy proposition. A benign apparatus is one that is inherently incapable of generating or contributing to excessive EMI and that "will operate without unacceptable degradation in the presence of electromagnetic disturbance normally consequent upon its intended use". Both conditions must be met. I am sure the SMPS fails the "inherently" part.If you actually need any conformity testing we are talking about mega-€ and your profits fly away for along time. But, and this is a big but. You are required to perform an "EMC Assessment". It does not say anywhere that you need to actually test the equipment. In the first version of the Directive, the only way to validate for CE mark was to create what is known as a Technical Construction File and have it passed by a "Competent Body". In the current second version this went away and instead you are required to do the aforementioned "EMC Assessment". If you can demonstrate "... correct application of all the relevant harmonized standards whose references have been published in the OJEU" then it "shall be equivalent to the carrying out of the electromagnetic compatibility assessment".I highly recommend you invest a tiny sum and get Tim WIlliams's excellent book EMC for Product Designers. I have only good words for it and my copy is all dog eared already from all the thumbing. The info above is mostly from that source, but it in no way limits itself to the legalese only.http://www.amazon.com/EMC-Product-Designers-Fourth-Edition/dp/0750681705/ref=sr_1_1?ie=UTF8&qid=1353500600&sr=8-1&keywords=emc+for+product+designers

author: 8086
author_rank: Super Contributor
timestamp: November 21, 2012, 12:56:41 pm
content: Thanks guys. I'll reply in more detail later, but for now, what do we think of this?http://www.picbasic.co.uk/forum/showthread.php?t=3490&p=95947#post95947Quote

author: nctnico
author_rank: Super Contributor
timestamp: November 21, 2012, 01:21:54 pm
content: A CE mark says that you take responsibility for the product. If you play it safe you can have it tested for $$$$. If you design carefully and adhere to safety regulations (creepage distances / component ratings) and take care of potential EMC problems then CE marking is a matter of buying stickers and sticking them onto your product. Test houses would like to have you believe otherwise but that is their wallets talking.BTW: I'd use a USB mobile phone charger as a power supply. They are probably cheaper than the components required to put the SMPS together and I'd use a relay instead of an SSR.

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: November 21, 2012, 02:45:15 pm
content: Quote from: 8086 on November 21, 2012, 12:56:41 pmI think that's nonsense - if you making any money, it's a business. Ifyour product kills someone you'll be no less liable. AFAIUI CE applies to anything placed on the market or taken into service. I've never seen any reference to the type of organisation thet does either (other than clarifying responsibility for imported products).Offering it as a kit would seem to be a viable route, especially as your taget market shouldn't have a problem doing some assembly.A way round PSU EMC is to specify an off-the-shelf part for the user to source themselves - 5V USB PSUs would be the obvious choice, with the caveat that there is some real junk out there.

author: 8086
author_rank: Super Contributor
timestamp: November 21, 2012, 02:58:40 pm
content: Okay, so let's assume I sell it as a kit. How much assembly would it take to make it a kit? Could I perhaps have the boards presoldered and have the user wire in the SSR/bolt the heatsink on themselves, would that be enough?Quote from: nctnico on November 21, 2012, 01:21:54 pmI don't see the advantage, apart from cost I suppose. The fact I have mains in there means it's always going to be under LVD anyway. So why bother with multiple power leads?

author: nctnico
author_rank: Super Contributor
timestamp: November 21, 2012, 03:26:13 pm
content: A mains SMPS is much harder to be made compliant with EMC and safety regulations (you'll need a properly isolated SMPS transformer with to begin with). Its also more prone to failures. For very low power I'd use a good old transformer.

author: 8086
author_rank: Super Contributor
timestamp: November 21, 2012, 03:43:37 pm
content: Quote from: nctnico on November 21, 2012, 03:26:13 pmThe module is already CE marked so I would assume it's as quiet as it needs to be. Again, I don't see why it's safer, since I have mains in there anyway, with SSR or mechanical relay, so a bit more won't hurt.

author: AndyC_772
author_rank: Super Contributor
timestamp: November 21, 2012, 03:51:18 pm
content: You might assume that, but you'd be wrong. PSUs are notorious for being tested under one specific set of conditions (usually their full rated current into a resistive load) and just scraping through conducted emissions, but failing horribly when powering real equipment.I keep trying to drum into PSU suppliers that their products don't just need to pass EMC on a dummy load, but that they need to pass *with significant margin* under *all* load conditions. If they don't have this margin, the complete system consisting of my product with their PSU will fail EMC and cannot be sold.Unfortunately you can't just build a product out of CE marked parts and claim compliance - it doesn't work either legally or technically.

author: bitwelder
author_rank: Super Contributor
timestamp: November 23, 2012, 09:21:54 am
content: Quote from: EEVblog on November 21, 2012, 12:20:46 pmWhat does qualify as a 'DIY kit' ?I mean, if e.g. we are talking a board with a handful of components, they are all (SMD) soldered except a few ICs in DIP package that are included in a separate bag, but it is left to the DIYer to mount them to the board, can that be called a kit?

author: EEVblog
author_rank: Unknown
timestamp: November 23, 2012, 09:35:02 am
content: Quote from: mikeselectricstuff on November 21, 2012, 02:45:15 pmNot in Australia.The definition of a "hobby business" is that you have "no reasonable expectation to make a viable profit"i.e. you are allowed to make money, but if it doesn't cover your time and effort as would be the case if you ran it as a for-profit business, then it can be classed as hobby income.QuoteCorrect, and nothing will ever save you from personal responsibility. But unless you deliberately did something unsafe, and knew it, if you use best practice etc, you are pretty much in the clear. But of course, if you use best practice, it's not going to kill anyone anyway when used correctly. Unless it's a kit, in which case you just put all the relevant warnings and you are fine.Dave.