Selling open source hardware - Page 1
Forum section: electronics / general

author: homebrew
author_rank: Frequent Contributor
timestamp: September 09, 2016, 04:46:46 pm
content: Hi everyone!Dave was talking in his last video on the use of the open source hardware logo, which brought up a topic that I would really like to discuss.What can I actually sell as a hobbyist electronics designer?Of course, I can share the schematics and EDA files as I like. But with actual hardware, it gets apparently A LOT more tricky. At least here in the EU one has to declare CE conformity on pretty much everything. Even on kits and since this year I think also on evaluation boards.That includes at least the Low Voltage Directive, EMV and more, depending on the type of design. You need to do a risk assessment, provide a manual and so on and so on...That means it would be practically impossible to legally sell a simple shield for the arduino or the PI, just to make an example.So how do you deal with that? Simply never sell anything? Or has anybody really gone through that process for a hobby project design!?And no, it's not about earning money. For me it's more like a service thing. For example, economy of scale is pretty good, when it comes to PCBs so why not order 30 instead of 3 and sell the rest to anybody interested ...

author: rstofer
author_rank: Super Contributor
timestamp: September 09, 2016, 05:03:59 pm
content: Can you just sell the PCB with only ROHS compliance? Let the buyer purchase the parts from somewhere else.Or, just give up hope! I know I feel better having done that...

author: homebrew
author_rank: Frequent Contributor
timestamp: September 09, 2016, 05:11:08 pm
content: Probably not even that.The problem is, that a specific PCB will inevitably lead to a specific product. And this product has to be "safe" when built according to the design.So from what I understand, it would however be legal to (re)sell ROHS conform components and even breadboard-style PCBs. But selling PCBs for a specific design might actually be problematic ...

author: Tabs
author_rank: Regular Contributor
timestamp: September 09, 2016, 09:08:34 pm
content: Actually there may be some avenues open to you depending on the nature of your PCB.Confirm the following yourself....Firstly kits for assembly by the user do not need to be CE marked. If you supply the PCB then you have to make sure it's rohs (now part of CE). The PCB is electrically benign so no emc or lvd. This is especially true if the end user is supplying the parts.If your assembled PCB is for r&d then you don't need CE marking. Eg a dev board. The first arduino and pi were not CE. I think now they are....If your using the radio spectrum then above do not apply. You will need CE. Unless you are using 2.4ghz de regulated band.The following is what I see on quotes for testing products I helped design. This was true 2 years ago, since then I convinced my company to build it's own chamber so not had to outsource this for a while....The costs vary depending on your product class. An emc chamber can cost £1200 per day (more if you are present for the testing) or £4000 for a complete suite of tests.If your product is not powered off mains or if it uses a generic brick then you could test it with batteries then your cost comes down because you bypass most tests.The final cost on emc depends mostly on test time and the number of tests. The longest tests are usually conducted immunity. It's best to minimise the run time of these tests by using the minimum number of cables and to stick below 100mhz as the highest internally generated frequency as this let's you test to 1ghz only.Some tests you can do at home by hiring the equipment... ESD gun, FTB and surge generator, and conducted immunity, emissions. Typical cost of £200 per day per equipment.Safety testing can be more expensive £6000 to £10000. Again cheaper if not mains powered.If you do this then your costs will sky rocket if you fail and have to do exploratory tests, fix and retest.The biggest thing from a compliance point of view is that your product is safe and does not cause interference with other products. If your product is interfered with by something else and this isn't a safety issue then the authorities don't really care because this just represents a customer relationship problem for you. They only get involved if lots of your customers complain or bring class action law suite.There's lots of ways to minimise the cost, as always I'll cover my ass by stating you should seek your're own legal advice.Sent from my SM-N930F using Tapatalk

author: homebrew
author_rank: Frequent Contributor
timestamp: September 10, 2016, 07:36:18 am
content: Quote from: Tabs on September 09, 2016, 09:08:34 pmThe role of the "end user" might indeed be the problem. Apparently the argument for the kits and eval-boards does not hold anymore in current regulation. That might also be the reason for the rPI and Arduino to be declared CE - they are directly sold to the end user. Even large kit sellers (e.g. Velleman) now declare their kits conform:http://www.velleman.eu/images/tmp/CE%20modules%20081106.pdfRegarding the EMC regulations, I now found this:http://ec.europa.eu/DocsRoom/documents/9863/attachments/1/translations/en/renditions/pdfSee the flowchart on page 16:"Components or sub-assemblies" -> "intended for incorporation into an apparatus" -> "by the end user" -> APPARATUSSo selling benign components without any intention where they are to be used (e.g. selling assortments of resistors) should not be a problem. But I think one will have a hard time discussing away the intention from a custom made PCB ...The only way out would be to see the PCB as a single unique part, being completely passive and hence excluded (at least) from EMC. However, this argument feels awkward, because now the applicability of the regulation would depend on whether or not I sell (or even just offer) the PCB together with other components or not ...Seems wired .. and thus is probably wrong.

author: Srbel
author_rank: Frequent Contributor
timestamp: September 10, 2016, 09:53:50 am
content: I am glad my country is not part of the EU, and that it will never be.

author: EEVblog
author_rank: Unknown
timestamp: September 10, 2016, 09:54:03 am
content: Quote from: homebrew on September 09, 2016, 04:46:46 pmYet countless people do that don't they?

author: homebrew
author_rank: Frequent Contributor
timestamp: September 10, 2016, 11:23:29 am
content: Quote from: EEVblog on September 10, 2016, 09:54:03 amYes, in the same way as countless people smoke weed ... but that doesn't make the situation any better.I think what open hardware (besides the licensing framework) would also need is a clear and pragmatic approach to these regulatory demands. Otherwise open hardware will never evolve into a competitive environment (like OSS for example). It is just too easy to sue somebody if he doesn't adhere to the regulations and standards.On the open source software side, this has all been thought through during the last decades. But it was maybe far easier from the beginning, as nobody is ever liable for buggy software, even if it accidentally destroys all your data. Starting a fire because of a design flaw in an open hardware project is another story ...And yes, an acceptable answer to the initial question could really be, that is is just not possible in the EU to legally sell small scale projects...

author: CJay
author_rank: Super Contributor
timestamp: September 10, 2016, 11:45:56 am
content: Quote from: homebrew on September 10, 2016, 11:23:29 amSo yet another corporate stitch up eh...What a ridiculous situation yet our politicians cannot see why innovation is dead for all but corporates or well funded individuals.We've killed the man in the shed.

author: AndyC_772
author_rank: Super Contributor
timestamp: September 10, 2016, 11:58:42 am
content: Well, OK, but what if the man in the shed wants to sell something that's actually dangerous, or which does interfere with TV and radio reception?CE isn't perfect by any means, but it's one of a very few good things to come out of the EU, IMHO. Test your product once, to a common set of standards, and you can sell it anywhere in Europe. Without that regime in place, companies would have to test to each individual country's standards, which is a monumental pain in the backside, and hugely expensive and time consuming.Just ask anyone who ever designed telephone equipment back in the day.

author: homebrew
author_rank: Frequent Contributor
timestamp: September 10, 2016, 12:50:58 pm
content: Quote from: CJay on September 10, 2016, 11:45:56 amActually it is worse than that. We've killed the shed ... people are still there ...Sharing is fundamental to any *open something* community to work. For open hardware real sharing is apparently legally not possible. Sure, on one hand I see the need to protect the market from unsafe products. But on the other hand it eliminates the possibility of sharing at the level of open products, thereby eliminating any from of economy of scale. Yes, everybody can now order any component desired and can order pcbs of any complexity - but at what costs?In this framework also open hardware business models are not feasible (I mean real open hardware - not just PDF schematics), as the community could not properly be involved in the design process.So from that perspective, I totally understand why we don't have any significant open hardware projects ...

author: b_force
author_rank: Super Contributor
timestamp: September 10, 2016, 01:26:29 pm
content: Quote from: AndyC_772 on September 10, 2016, 11:58:42 amI think people have to agree with this.Yes there are downsides to all of it. I still don't get why CE has to be so expensive. There is no reason for it.But if you see what kind of bizarre things you can buy in other countries like China and even the US (the whole wall plug design leaves me full of questions, most dangerous type of connector I have ever seen).As an individual started you just have to be clever.All low voltage/power are pretty much fine. As mentioned above, kits are also fine.The problem starts with projects like SMPS power supplies etc.But if you sell it as some kind of DIY/test/development project I think you're still fine.

author: Zero999
author_rank: Super Contributor
timestamp: September 10, 2016, 11:29:36 pm
content: Quote from: homebrew on September 10, 2016, 11:23:29 amSoftware is totally different. It's just data, nothing else.As far as buggy software is concerned: no one gets killed if someone loses their data but with hardware people can die if it's unsafe. Indeed the same does apply to software: if it's safety critical such as an aeroplane autopilot, the software has to go through as many rigorous tests as the hardware.As far as the original topic is concerned: CE does not stop one from selling open source hardware, so long as it meets the relevant regulations, whether this is practical or no is another story.

author: homebrew
author_rank: Frequent Contributor
timestamp: September 11, 2016, 07:56:28 am
content: Sure hardware is a different thing than software. But the actual philosophy of open hardware as community of practice and sharing came from the world of software.Of course we have to accept and obey the rules!And of course we do not want to put people in any danger.And that brings us really back to the initial question: How do you deal with that, when you want to offer more than just the EDA-files?

author: AndyC_772
author_rank: Super Contributor
timestamp: September 11, 2016, 09:04:54 am
content: Quote from: b_force on September 10, 2016, 01:26:29 pmCE testing is just a commercial service, and there are plenty of places that do it. Just like any other commercial service, the price is determined by competition and by what the market will bear.It does require an awful lot of costly equipment, specialist facilities and expertise. I generally reckon about £1000/day for EMC lab time.

author: tggzzz
author_rank: Super Contributor
timestamp: September 11, 2016, 09:44:29 am
content: Quote from: Hero999 on September 10, 2016, 11:29:36 pmClearly you are young, inexperienced in the ways things fail, and lack experience. You -and everybody else on this forum- really should read comp.risks e.g. via the archive athttp://catless.ncl.ac.uk/Risks/It is a low volumeveryhigh quality group, and I recommend using the RSS feeds.Engineers, as opposed to technicians, have to be concerned with theoretical and practical failure modes. Indeed, large part ofengineeringis not about how things work (the easy bit); it is about how things fail and how to avoid the failures.

author: homebrew
author_rank: Frequent Contributor
timestamp: September 11, 2016, 11:03:43 am
content: Quote from: tggzzz on September 11, 2016, 09:44:29 amYes, maybe some of us are inexperienced ... so what? Get over it!For me this is fine - I would consider myself as an "advanced hobbyist" nothing less, nothing more.But in the current framing, open hardware is just fake. When no way of dealing with the regulations pragmatically can be found, it is nothing more than marketing BS for big companies. An open community can ONLY work if everybody has the right to modify and share a good and is at the same time the only person responsible himself for the goods he is using from the community.NOBODY with a sane mind would invest his spare time into designing/improving something if he has to take unmanageable legal risks in doing so. This would be an investment without any expected returns but high risks involved.But as long as open hardware is just treated just as open documentation about hardware, it seems fine (CERN-OHLhttp://www.ohwr.org/attachments/2388/cern_ohl_v_1_2.txt):QuoteThe TARP-license is even more explicit on that (https://www.tapr.org/TAPR_Open_Hardware_License_v1.0.txt):QuoteBut now compare this to OSS licenses such as the GPL (https://www.gnu.org/licenses/gpl.txt). You'll see it is pretty much the same, But remember the BIG DIFFERENCE there is that the software IS THE PRODUCT and not some meta-information.QuoteYou see, the members of the OSS community are pretty much protected in terms of being held responsible for mistakes. And they share products...For Hardware this will simply not work. When somebody want's to transform a design into real physical hardware, all regulatory hell breaks loose. And it doesn't matter if you sell it, give it away for free, sell it as a finished product or just as a kit ... It has to comply to the regulations (and needs to be safe)! The risks involved are not transferable to the user.So the question still persists: How do we deal with security in open hardware projects in a way that participative community development is still possible without violating the regulations?

author: Chris Mr
author_rank: Regular Contributor
timestamp: September 11, 2016, 12:07:53 pm
content: How about selling the postage more expensively and calling the item 'free' - just a (bad) idea!

author: homebrew
author_rank: Frequent Contributor
timestamp: September 11, 2016, 12:44:11 pm
content: Quote from: Chris Mr on September 11, 2016, 12:07:53 pmYes - these little 'tricks' don't work either. The regulations don't care if you make money with the product. As soon as somebody else gets in contact with your 'product' everything must apply.

author: b_force
author_rank: Super Contributor
timestamp: September 11, 2016, 01:16:29 pm
content: Quote from: AndyC_772 on September 11, 2016, 09:04:54 amAnd for startup companies, 1000-2000 bucks a day is not doable.I knew someone who worked in one of the notified bodies in NL. The main reason why they are so expensive, is because all work is done by people with a degree (Msc, Bsc etc) plus there is a lot of paperwork.Which comes down to the fact that I have to pay someone around 100-150 euro an hour (or more), just to sit behind a desk a type stuff into a computer..I just don't get it, this strategy would be like digging your own grave for every commercial company.Apparently it's standard in the world of licenses, blows my mind

author: Zero999
author_rank: Super Contributor
timestamp: September 11, 2016, 02:01:54 pm
content: Quote from: tggzzz on September 11, 2016, 09:44:29 amHow do you know what level of experience I have?I have been involved in the design of safety critical machinery before and although I haven't actually written safety critical software, I'm well aware of the requirements.Even thought there are some risks of identity theft or hacking, it's not in the same league as a plane crash.

author: tggzzz
author_rank: Super Contributor
timestamp: September 11, 2016, 02:28:06 pm
content: Quote from: Hero999 on September 11, 2016, 02:01:54 pmIf you read comp.risks as I suggested, you will find there aremanyways in which faulty code and even "just" lost dataarein the same league as a plane crash! Some are worse, since they could kill far more than a single plane's "self loading freight".If you prefer a book from the ACM Press, tryhttps://www.amazon.co.uk/Computer-Related-Risks-Press-Peter-Neumann/dp/020155805XNewmann is the comp.risks moderator, and regrettably little has changed since 1994. Anybody that doesn't know what the ACM is shouldn't be let loose with a keyboard

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: September 11, 2016, 03:03:27 pm
content: It is not mandatory to do any testing at all, third-party or otherwise.CE marking means you declare that the product meets the requirements for the product category.There are many ways to satisfy yourself that it does without using an expensive test house.

author: homebrew
author_rank: Frequent Contributor
timestamp: September 11, 2016, 04:29:45 pm
content: Quote from: mikeselectricstuff on September 11, 2016, 03:03:27 pmOf course. But especially this kind of argumentative 'proof' would require a really substantial knowledge on the regulations and even more so on the topics involved. Is that even possible as a community effort?Is there any guidance out there how to even approach this?

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: September 11, 2016, 06:18:37 pm
content: Something that those who have done some testing could do is publish their results. That would provide some useful baseline figures to compare similar designs.However the more pragmatic argument is OSHW is such a miniscule part of the market that unless your product kills someone nobody is going to take any notice.Look at all the lethal mains adapters from China on ebay - the people who enforce these things have a gazillion things to investigate before some piddly little OSHW gadget.If someone wants to challenge your CE marking, someone has to pay for some tests - who has the funds to do that ?

author: janoc
author_rank: Super Contributor
timestamp: September 11, 2016, 06:36:21 pm
content: Quote from: homebrew on September 11, 2016, 04:29:45 pmI believe the norms and limits to "fit into" are all published, it isn't some secret knowledge that only a cabal of hand-picked bearded guys in labcoats is ever allowed to see. Yes, it needs some knowledge to understand and if you want to do the testing yourself, some of the gear could be expensive. But still - a spectrum analyser and a set of probes is still cheaper than a day at a testing lab.But isn't the "substantial knowledge on the regulations" the same thing for every law? Like traffic rules or criminal code. You either invest time and learn yourself of invest money and pay someone smarter than you to do it for you, it is that simple ...On the other hand - if all you are attempting to sell is an Arduino/RasPi shield that doesn't have its own radio, then you can pretty well self-certify CE compliance. All it needs is a written declaration of conformity, which is a half page document. The chance that you would have problems with it are pretty much zero - the checks are done only if someone reports actual problems with your device (interference, for example) and on such a simple device the chance of issues is minimal if it is sanely designed. Compared to the US this is actually simpler - there you have to do the expensive and mandatory lab testing to get an FCC approval.If you are selling something containing a radio (even the 2.4GHz one!) or something that touches mains voltage, then the rules are stricter and a trip to the certified lab is likely going to be unavoidable if you want to avoid problems. Otherwise you could expose yourself to a legal liability should your gizmo cause interference to/failure of some critical equipment or cause an injury/fire.Quote from: b_force on September 11, 2016, 01:16:29 pmHonestly, if you are bringing a hw product to the market, the 2000 bucks for EMC testing is theleastof your problems. Every normal company does their own pre-testing at home (a spectrum analyser costs ~$2000) so that they don't have to go to the lab multiple times.

author: b_force
author_rank: Super Contributor
timestamp: September 11, 2016, 07:58:21 pm
content: Quote from: janoc on September 11, 2016, 06:36:21 pmIt all depends on your market. If you're market is small, you have a very close relationship with your customers, it's never a big deal.I have seen many smaller companies operate like that.That's exactly the whole point why you definitely don't need a 2k spectrum analyzer.BTW we were talking about 1000-2000 bucks a day. To get a full license you can multiple that at least by a minimum of 5.If everything goes according to plan!I personally think it's pretty much impossible for startup companies. Unless you find someone who wants to invest enough.The downside is that you always will be his little slave.It all depends what kind of products (read: IC's) and technology you're using.With certain solutions you just know you'll never get in trouble.

author: homebrew
author_rank: Frequent Contributor
timestamp: September 12, 2016, 06:36:39 am
content: Quote from: b_force on September 11, 2016, 07:58:21 pmWouldn't it be very useful to showcase such designs? Optimally we could come up with some guidelines and design spaces where we would not assume EMC related problems.Of course I know that it will depend on many factors but at least it would provide some reference.

author: Chris Mr
author_rank: Regular Contributor
timestamp: September 12, 2016, 07:31:16 am
content: How about looking at it from a slightly different angle ->The regulation is there to stop people making things that interfere with other equipment and to make sure it's safe; check.Things are imported (by lots of people) from China which are not made to either of these criteria which are cheap; the reason they are bought.So what happens to the people in China who are not working to the regulations?Does anyone know of a company that has been taken to task over equipment that doesn't meet regulations recently? I'd like to know which body (department of government?) it is that comes around and does this.There are now hundreds of thousands of regulations but who is it who polices them?

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: September 12, 2016, 08:08:53 am
content: Quote from: Chris Mr on September 12, 2016, 07:31:16 amIn the UK, it's local council trading standards departments, who will be far too busy with counterfeit drink & tobacco products, dangerous toys etc.In Germany they used to buy products at random and test them - don't know if this is still the case, but even so likely to only be for consumer-level volume products

author: Chris Mr
author_rank: Regular Contributor
timestamp: September 12, 2016, 08:39:04 am
content: And the Chinese people who sell dangerous / moody gear - any idea what happens to themStrikes me that nothing happens to the Chinese so why not just send all your open sauce gear to China and then get them to ship it to your customer.I once checked up on what effect the food hygiene regulations had done to reported cases of food poisoning; the answer was very little (and conforming to the regulations has cost billions). There are some people that set up selling stuff that don't care about regulations - the very people the regulations are there to prevent

author: janoc
author_rank: Super Contributor
timestamp: September 12, 2016, 01:37:22 pm
content: Quote from: b_force on September 11, 2016, 07:58:21 pmIf you are building custom, one-off stuff for a specific customer and not mass-market, then the directive may not even apply to you.Quote from: b_force on September 11, 2016, 07:58:21 pmYes, I understood that it was *per day*. Are you planning on camping in the lab and fixing your product there that you want to rent the lab (as opposed to having your product tested) for a minimum of 5 days? If you are a small scale manufacturer building a small gizmo - like those shields or a little wireless dongle or something on that scale, I somehow fail to see why would you need that long.If you are testing something on the scale of a computer or a TV, maybe - as there is mains involved, radio emissions, etc. But then you do your own pre-compliance measurements, that spectrum analyzer is certainly cheaper than extra one day in the lab (or failing the test). On the other hand, a little garage startup will likely not attempt to manufacture something like this alone neither, due to other costs.

author: zl2wrw
author_rank: Regular Contributor
timestamp: September 13, 2016, 10:10:19 am
content: Quote from: Chris Mr on September 12, 2016, 08:39:04 amI understand that China has huge problems with official corruption (some people in China bribe the government official rather than comply with Chinese law and or bribe the government official for protection from the foreigners that would otherwise sue/prosecute). The Chinese government effort to catch these corrupt officials is known as the "fox hunt".I can already download say a PCB design, send it to China, and have a stack of PCBs sent back to me, without the design author or the PCB house, having to certify the PCB as a "kit component" with the FCC etc. (I'd like to think that the PCB is as described though - if I order FR4, I expect it to actually be, you know, fire retardant...)The food business is possibly a good analogy - in this part of the world (New Zealand), ignoring the details, everyone is allowed to prepare their own food (even high risk foods like slaughtering and butchering your own livestock), but, the preparation of food for sale is regulated, and the regulations are more stringent for higher risk activities (ie compliance is more difficult for say an abattoir than it is for say a bakery). However, if you want to publish a book, say "how to raise, slaughter and butcher your own sheep", then as far as I am aware, in the eyes of the law here, it's just a book, subject to the same (rather lax) regulations as any other books, even though the subject is high-risk food preparation.So, maybe we should think of open source hardware in terms of "open source recipes" - we are (still) allowed to make our own electrical devices, for our own use, at our own risk, and we are allowed to share our recipes (designs) with others. I am not a lawyer, but if all you are doing is sharing your recipes (designs) with others, then you probably don't have to "stick our neck out" (accept liability without just reward) and claim CE etc conformance (don't claim conformance - just share your design!). Of course, we should "peer review" each other's designs and try to catch design errors or anything dangerous.In most parts of the world, an amateur radio licence permits the personal construction of home made "uncertified" radio transmitters (subject to the rules regarding ham radio in your country), and opens up lots of RF spectrum with rather generous TX power limits for your experimentation.With a credit card, internet access, and postal service, you can source parts to almost anywhere in the world, and unlike the old days, ultra small-batch runs of PCBs are affordable (and will probably become even more so as time passes).On the other hand, it does not help that many electrical safety standards are locked up behind copyright law. I understand that here in NZ, we used to have the NZECPs (NZ Electrical Code of Practice), and that these were "crown copyright", which basically meant that the government held the copyright, but everyone was allowed to copy the NZECPs verbatim (it was not permitted to modify the NZECPs and then to try to pass them off as being the real thing etc). Now, I believe that the rules are "locked up" in the joint Australia/NZ standards etc, which the standards body holds the copyright to, and Joe & Jane average can't read these standards, even though they are effectively LAW here, without first forking out $$$

author: Chris Mr
author_rank: Regular Contributor
timestamp: September 13, 2016, 11:31:54 am
content: zl2wrw - interesting points.I wonder though, where is the 'regulation' supposed to start / stop?Take the xyz processor manufacturing company. They sell their processors without any markings or approvals and pass the responsibility on to their customers.They probably argue that the processor is not a complete system - neither is a PCB or even an EVM. They could also argue that they don't sell finished products but they are, as far as conforming to the data sheets.So what constitutes a product that requires certification and where is the line drawn? I wouldn't even know where to start on that one - we all just go around assuming that the law will get us so we need approvals.This is turning into a very interesting thread.

author: void_error
author_rank: Frequent Contributor
timestamp: September 13, 2016, 01:27:20 pm
content: So, what happens if I design something, release it as open source hardware, order the minimum quantity of PCBs from a manufacturer which leaves me with a few extra boards after I build it and some people ask me if I want to sell any because it would be cheaper and less wasteful than they themselves ordering 5 PCBs from the manufacturer and using only one of them?

author: b_force
author_rank: Super Contributor
timestamp: September 13, 2016, 03:43:19 pm
content: Quote from: janoc on September 12, 2016, 01:37:22 pmOf course we aren't talking about a few shields. I am thinking more about a SMPS or something, which isn't that difficult to develop as a open source project with limited tools at all!In the end it all comes down to priorities that the governments have to make.(that in general for laws btw).If you're selling a handful of boards (say 500 or less a year), as kits or just like an extension kind of idea, the possibility you'll run into problems is very close to zero.Most people who will buy and use these products have some kind of knowledge, understand the nature behind the product and are gonna use it for hobby projects or small projects.If your boards explode, after a while people simply don't buy your (crappy) products anymore.It's different if you run a big international company developing full finished products or products that go into full finished products for the market (like a SMPS).Your product may end up in all kind of situations were money and reliability are involved.So if your SMPS blows up, that's already super annoying for the client, because he has a very angry customer with economical damage (if you're lucky)If your SMPS blows up, the loudspeaker box where it's used in catches fire and therefore half the building got up in flames.Than you have a serious problem!Exactly the same goes for EM/EMI noise.If your product is being used in the middle of no where it's not that much of a deal.But if your product is being used in very dense areas, people are not gonna appreciate it.That's the only reason to have a CE or any kind of license.Because after a while it's very difficult to find who's fault it was.In the end someone has to pay the damage.Include a bunch of amateurs developing absolute crappy and potential dangerous products and it will cost a lot of people (and the government) millions.Not even talking about danger to others.So yes, I agree with the fact that these kind of licenses are actually a good thing.Only the way to get them is to much of an hassle and way to expensive.

author: AndyC_772
author_rank: Super Contributor
timestamp: September 13, 2016, 03:48:40 pm
content: Quote from: Chris Mr on September 13, 2016, 11:31:54 amCorrect. They're selling a component, not a finished device which is usable by the end-user in the form in which it is sold.For commercial reasons, they do need to ensure that the device won't be the thing that prevents the finished product from being certifiable. So, for example, a CPU is likely to have to be lead free, because otherwise the finished product won't be RoHS compliant. The CPU is quite legal to sell, but in practice, nobody can actually buy it (unless their own specific end product qualifies for an exemption).I get into this discussion regularly with power supply manufacturers. A PSU might be (quite rightly) be CE marked, but so noisy that it only just scrapes below the limit line when powering a resistive load. The product is useless when connected to a real product, because the PSU manufacturer has taken all the permissible noise margin for itself, and left no room for noise emitted by the product it's powering.Quote from: void_error on September 13, 2016, 01:27:20 pmNothing stops you selling bare PCBs. You'd only need to consider CE compliance if you were selling the PCB ready assembled, or perhaps a complete kit for something which would qualify as a finished product once assembled by the buyer.Even then, it might depend on the PCB. If your project was (say) a kitchen timer, then that's a complete finished item it its own case, and would technically require a CE declaration.But, if it were a USB device, then it's part of a system which includes the PC it's connected to. Then, your obligation is to make sure it doesn't make a compliant PC non-compliant - and there's a whole can of worms right there.Or, maybe it's some kind of protocol converter, which is only usable as a sub-assembly on someone else's board. Then the obligation to declare compliance would fall to whoever designs the board incorporating your project, if that board is itself a finished good. You'd still have to make sure your design doesn't radiate too much noise, but only because whoever designs your board into theirs would complain.

author: janoc
author_rank: Super Contributor
timestamp: September 13, 2016, 07:18:08 pm
content: Quote from: b_force on September 13, 2016, 03:43:19 pmYes, if you want to design and sell something on the level of an ATX PSU or some high power inverter, the certification will be expensive and difficult.But why would you want to develop that?? Unless you are planning to build a huge series, this will never pay for itself. Even large manufacturers of electronics are buying pre-certfied supplies off-the-shelf and not designing their own for this reason.And a small, low power DC-DC converter that doesn't involve mains on some board should be manageable.

author: homebrew
author_rank: Frequent Contributor
timestamp: September 13, 2016, 09:13:46 pm
content: Quote from: Chris Mr on September 13, 2016, 11:31:54 amThat is indeed a very interesting question. And it probably depends on the type and function of the processor. While your favorite jelly-bean uC is most likely not labeled CE complient, an Intel/AMD desktop cpu has to be: It is a component meant to be installed into a system by the end user. Same applies to graphic-cards, etc,etc ...And sure enough ... they are:https://www-ssl.intel.com/content/www/us/en/declaration-of-conformity/cprs-doc/docs-boxed-processors.html

author: AndyC_772
author_rank: Super Contributor
timestamp: September 13, 2016, 09:26:22 pm
content: Interesting - though I suspect for a company as big as Intel, the cost of putting each major CPU variant through a set of EMC tests becomes vanishingly insignificant. The value in being able to say "yes, of course it's got approval X" to a major customer's (clueless) purchasing dept is far higher.

author: b_force
author_rank: Super Contributor
timestamp: September 13, 2016, 09:35:07 pm
content: Quote from: janoc on September 13, 2016, 07:18:08 pmWell, I know a lot of reasons to develop a new power supply.I don't agree it's gonna be expensive. Most difficult parts is the transformer, but you can wind these by hand (bit tedious)

author: homebrew
author_rank: Frequent Contributor
timestamp: September 13, 2016, 09:52:09 pm
content: Quote from: AndyC_772 on September 13, 2016, 09:26:22 pmYes, sure for a big company and a multi-million dollar project, the couple of bucks are completely irrelevant.But interestingly I can only find these declarations for their boxed type cpus - the ones sold in the stores ... But that can also be my faultOtherwise it comes down to the flowchart on page 16:http://ec.europa.eu/DocsRoom/documents/9863/attachments/1/translations/en/renditions/pdf

author: Chris Mr
author_rank: Regular Contributor
timestamp: September 14, 2016, 07:51:57 am
content: QuoteThis is getting fascinating.Does anyone know how you decide whether a product (being something that one sells) is a sub-assembly or finished?Given that virtually everything I can think of is used for something, what stops it being a sub-assembly! A computer on a network is a sub assembly of the whole network but is regarded as 'finished' even though it is useless without software.

author: AndyC_772
author_rank: Super Contributor
timestamp: September 14, 2016, 08:21:45 am
content: The PDF that homebrew posted contains everything you'd want to know, and a great deal you probably didn't.The definition in the flow chart is "Combination of finished appliances made commercially available as a single functional unit (i.e. system)".Not sure how helpful that really is, though!You're quite correct that software is a component of the finished product. It can most definitely affect the EMC signature of the equipment.

author: Chris Mr
author_rank: Regular Contributor
timestamp: September 14, 2016, 09:04:40 am
content: The flow chart makes the distinction of "appliance" and when you look that up you end up with things like toasters - something which is made to perform a specific task and more importantly stand-alone. An appliance does it's job with only the assistance of power (normally).I am still looking for the EU definitions of what these words mean (appliance, finished appliance, end user, sub-assembly).No can of worms this, a seething nest of poisonous vipers is more like it.

author: homebrew
author_rank: Frequent Contributor
timestamp: September 14, 2016, 09:41:03 am
content: Quote from: AndyC_772 on September 14, 2016, 08:21:45 amAs I understand it, a desktop computer would be a perfect example. You buy finished appliances or "apparatus" (PSU/CPU/Board/Ram/Case ...) and combine them into a single functional unite (i.e. "the computer"). The problem is though, that a combination of CE compliant parts does not automatically lead to a compliant system. Hence if you would offer it as a 'standard system' you would technically need to re-certify the whole thing.Dell for example does that:http://downloads.dell.com/RDOC/Dell%20Inspiron%203252,D14S,D14S001,DELL%20Regulatory%20and%20Environmental%20Datasheet.pdfNow I understand why my trusted hardware dealer would sell me each component separately and an extra fee for the assembly service. Hence he never offered a complete system ...So Chris Mr was right:Quote from: Chris Mr on September 14, 2016, 09:04:40 am

author: AndyC_772
author_rank: Super Contributor
timestamp: September 14, 2016, 12:00:50 pm
content: Provided you're not then selling that completed PC, you're OK, unless someone actually then complains that it interferes with their TV.You're quite correct that CE + CE doesn't automatically equal CE, and that an assembled PC does absolutely require testing if it's to be sold.You can test a worst-case combination of components and then claim compliance for 'lesser' products on that basis. So, for example, if you build and test a PC that has dual video cards, three hard discs and an optical drive, you could claim compliance for an otherwise identical PC with a single video card, two hard discs and no optical drive.You'd probably be OK even if, say, that 'lesser' PC actually has a faster CPU, provided the PC you tested has no emission spikes at harmonics of the CPU clock speed which were close to the limit line. There is a degree of pragmatism available here; provided you had reasonable evidence to suggest that each individual PC would be compliant, you don't actually have to test every possible variation.

author: b_force
author_rank: Super Contributor
timestamp: September 14, 2016, 01:31:25 pm
content: Quote from: AndyC_772 on September 14, 2016, 12:00:50 pmWell, as I understand that IS actually the case!!This is really the first time that I've seen someone saying otherwise.Otherwise it means that every PC builder needs to go through a very expensive CE license procedure.As far as I know, a PC definitely does NOT require extra testing for the same reason.Otherwise it would be completely useless to test your stuff anyway, if somebody else needs to retest it anyway.I have worked for quiet a few companies and had quiet a few clients and a lot of them work with already CE certified equipment to safe the hassle.As far as I know, the whole idea of CE is certifying separate parts, so a third company doesn't have to go trough the whole process AGAIN.Which is not beneficial for development and commerce. (another main goal of CE is not to obstruct the market and selling to much!)

author: arlipscomb
author_rank: Contributor
timestamp: September 14, 2016, 01:34:59 pm
content: I am working on a project that I would consider as a candidate for "open source hardware".To sell it to what I believe is my primary market it will have to be produce just like anything else in its class. The same regulatory requirements will have to be met.But the open hardware angle has advantages. It gives me a possible additional market. It may help by creating a support structure larger and better than I could on my own. It may develop improvements that I would have never thought of.It also lets me put my product into the hands of some who would not be able to get it otherwise. In those cases I don't lose a sale, I gain a community member.

author: AndyC_772
author_rank: Super Contributor
timestamp: September 14, 2016, 02:21:48 pm
content: Quote from: b_force on September 14, 2016, 01:31:25 pmEvery PC builder *does* need to certify - unless they're building a number of very similar PCs for which the 'worst case' variant has already been tested.Yes, it's expensive. No, many 'custom' builders probably don't, in practice, bother. Neither of these things change the rules, though.QuoteIt depends what your "stuff" is.If it's a component which the end-user - who is deemed to know nothing about EMC - installs into a product, then you need to ensure that your component won't make that product non-compliant. This, I suspect, is why Intel's boxed, retail CPUs have CE declarations, but not OEM components.QuoteNo, sorry, this isn't the case.Suppose you buy a mains PSU off the shelf. You can reasonably expect it to be CE marked, to show that:a) it's compliant with the LVD and other regulations which are also part of CE, andb) it's EMC compliant under the conditions under which it was tested.Now, further suppose you buy or build a low voltage product. That product can be CE marked too, because it's EMC compliant when running off the power supply it was shipped with. As it happens, the product itself is noisy, but its original power supply is well filtered, and not much of the product's noise makes it out up the mains cable.Then, suppose you plug the CE compliant product into the CE compliant new power supply.The new power supply doesn't generate much noise of its own, so it doesn't need much internal filtering. This in turn means the product's own noise can escape up the mains cable.The complete system becomes non-compliant, both legally and technically. They cannot be sold as a pair, to be used together, even though each item is individually compliant.There *is* a get-out clause, but it relies on each CE certified product being so ridiculously far below the limit line that in practice, it's never useful unless you're making watches or calculators.

author: b_force
author_rank: Super Contributor
timestamp: September 14, 2016, 03:22:10 pm
content: I still simply can't follow, sorry.Most PC builders haven't even heard of something like CE or EMC testing.In this case millions of PC build companies would be illegal?(and a lot of other companies, pretty much every company that buys in off the shelf parts like SMPS, amplifiers and so on)So I am clearly missing something here.

author: AndyC_772
author_rank: Super Contributor
timestamp: September 14, 2016, 04:06:08 pm
content: What's confusing?If you build a thing, stick it in a cardboard box and ship it to the end-user, then:a) that thing has to be compliant;b) you are soleley responsible for it actually being compliant;c) the marks and logos on the individual parts you've bought in from elsewhere to make up that thing, don't affect (a) or (b).It might be that component manufacturers' declarations of conformity will help reduce your own testing requirements. If, for example, you buy a mains PSU from a reputable manufacturer, the fact that it's already CE marked means you likely won't have to repeat the LVD testing. But you do still need to demonstrate EMC compliance for the complete product incorporating that supply.You're probably right, that PC 'custom' builders are ignorant of all this - or they might be OK...My laptop, for example, is a 'custom' unit. It's built on a standard chassis and motherboard, but with my choice (from a limited set) of display, memory, drives and so on.Chances are, the chassis manufacturer has already tested one with the fastest CPU, most memory, fastest network card and so on. Provided the system builder sticks to a combination of parts which have already been tested, or which are (in the opinion of a technical expert) likely to radiate less noise rather than more, then the system can be CE marked.This doesn't mean that it won't interfere with TV and radio, or that the system builder won't still be in trouble if one of their PCs is found to be non-compliant after all, but at least they'd have a reasonable defence and would be unlikely to receive a severe punishment. Commercially speaking, it's probably OK.

author: b_force
author_rank: Super Contributor
timestamp: September 14, 2016, 04:19:14 pm
content: The confusing part is that 99% of the people told me something completely different!In fact, it's even one of the major arguments to go for of the shelf parts (mainly SMPS units), for most companies.So therefore not only PC Builders are ignorant, a million other companies as well.It still doesn't completely make sense to me, but if that's the case, what can we say?To me it's pretty clear that supervision on these things is very limited.Only when things or going out of hand.Btw, let me guess, something like pcspecialist?

author: dmills
author_rank: Super Contributor
timestamp: September 14, 2016, 05:55:08 pm
content: I can only speak for my employer, but we buy off the shelf PSUs mostly because it bypasses most of the design NRE costs (Which include expensive things like UL cert, orders of magnitude more painful then CE). Sure I can design a switcher from first principles, why on earth would I want to?And no, CE + CE != CE, consider that I can buy a high voltage power supply (CE for EMC/ROHS/LVD), but add a 100M loop of wire (CE for ROHS), with a spark gap (CE for ROHS), the result will wipe out the medium wave band.The nice one with computers is all those guys with honking great perspex windows in the sides of the cases, also painted metal in loose contact with other painted metal (Can you say slot radiator), all of this sort of junk fails the giggle test for EMC.Now there are a couple of subtle things that go on:Firstly, CE applies when you bring a product to market, so if you are not selling the thing then you have no need to comply.Selling the PC case CE marked is fine, it doesn't contain any doings so no EMC/LVD issues, and you CE mark to declare conformity with ROHS.When you sell a PC power supply, you test it in a nicely made case with good metal to metal contact and gasket strips, EMC pass (Valid, it is a subassembly used in a PC case in normal use, you just pick the case to test in carefully).Same for all the other doings.Now if a know nothing punter buys all this junk and bolts it together the result will fail, but he is not bringing it to market, so it is outside the scope of the regs at that point (May still get the local Radio authorities around, separate issue).If you are Dell/IBM/HP you actually pay attention to this stuff, and indeed if you look at their stuff they do pay attention in many little ways, so passing is no problem.If you are 'Gamerz are us' one man band PC assembler, odds are nobody will notice you, and worst case trading standards will tell you to knock it off until you learn how to do it properly.The half life of any given combination of bits is so short in that market that you will probably not sell more then a dozen of so of any given combination, and the prohibition will apply to whatever they actually tested.Trading standards are going to be FAR more worried about those PC cases with the external hard drive slot in the top that were catching fire then they will be about a few dozen poorly done gamer rigs.Secondly, enforcement is mostly reactive and under funded....Low volume kits, not designed as radiators are unlikely to be a problem in reality, and even things like kits for ham radio gear (That is intended to be a radiator) are vanishingly unlikely to come to anyones attention (Hams are assumed technically competent to build transmitters anyway).Regards, Dan.

author: AndyC_772
author_rank: Super Contributor
timestamp: September 14, 2016, 06:19:37 pm
content: Quote from: dmills on September 14, 2016, 05:55:08 pmI think the empty box itself falls outside the scope of any of the CE directives, and I've a feeling it would actually be incorrect to put the CE mark on it at all. If no directives apply, it can't conform to them.Commercially speaking, though, it would have to conform to RoHS because it's a part which manufacturers will want to build into apparatus which *does* fall under RoHS (and the rest, of course). But it doesn't actually fall under RoHS itself, so no CE mark.

author: dmills
author_rank: Super Contributor
timestamp: September 14, 2016, 08:48:43 pm
content: I am not so sure, but it is possible (I would expect ROHS to apply but the rules can get complicated).Regards, Dan.

author: janoc
author_rank: Super Contributor
timestamp: September 15, 2016, 03:32:44 pm
content: Quote from: dmills on September 14, 2016, 05:55:08 pmActually HAM radio kits (or kits in general) generally don't fall under the EMC/CE compliance, because they are not sold as a finished product but as a component that is meant to be integrated into something else (even if it is just a BYO case). The directive doesn't apply in such case.They may need to complain with RoHS (no dangerous chemicals ...), but that is generally easy to satisfy, the kitter just needs to buy RoHS compliant components (pretty much everything on the market today).Moreover, the amateur radio license explicitly permits building and use of transmitters and other gear, provided that the necessary regulations (band, power, signal quality, non-interference ...) are followed, so no EMC testing by the kit maker is needed - it is the user's responsibility that they don't radiate signals outside of what they are allowed by law (or their permit conditions).The CE applies only if you are manufacturing finished equipment that is publicly sold (like Icom, Alinco, Kenwood, etc. do).

author: homebrew
author_rank: Frequent Contributor
timestamp: September 16, 2016, 07:10:24 am
content: Quote from: janoc on September 15, 2016, 03:32:44 pmCan you back up your claim with anything? IMHO this is just plain wrong!Yes, in the directive, kits for radio armatures and research environments are deliberately excluded. But that has nothing to do with the nature of being sold as a kit but rather that the buyer and user-group is restricted to (semi) professionals that can be held responsible for their doings.Quotehttp://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32014L0030&from=ENRegarding your second point, where CE applies: It definitely includes components (though not benign components) that are intended to be integrated into "something". So omitting a case will not exclude you from the EMC directive in many cases. The device will happily function without it but might not stay in the limits anymore.Many kit manufacturer (e.g. Velleman, Conrad etc.) declare conformity also for their kits. Of course one cannot know how the kit is built in the end but if the kit has been built according to the descriptions given (in the obligatory manual) it must reach compliant emission levels (EMC) and must be safe to use (LVD/MD).There is no way around it: If one brings an electronic product into the market of the EU it has to comply to the regulations. Being a kit or not is not the point!

author: homebrew
author_rank: Frequent Contributor
timestamp: September 16, 2016, 11:01:10 am
content: So let me try to wrap the discussion up:I think that the discussion showed the level of confusion and misinterpretations caused by the complexity of the topic. Most of you agree that whatever we design AND SELL in the EU need in most cases a declaration of conformity. For the discussion I now see several option:1) Ignore it an fly under the radar2) Find excuses why the product is excluded from the regulations3) Do a self-declaration with a minimum actual measurements in a responsible way.4) Full-blown rigorous testing in accredited laboratoriesFor me personally, option one and two are not viable. I want to stay in the legal region.The fourth one is not economically possible for small projects that some of us intend to do.For me, this only leaves option three. Therefore I think it would be a very good option to collect best practices i.e.:a) Options to safely power the device (thus that LVD does not apply). E.g. Batteries, wall warts etc. Fusing? Input Protection? Input Filtering?b) ESD protection of I/O, EMC filtering. E.g. RS232, USB, GPIOc) Ground-Plane options on 2-4 layer boards......

author: AndyC_772
author_rank: Super Contributor
timestamp: September 16, 2016, 12:01:55 pm
content: This sounds like a very good point at which to break and start a new thread, about best practice techniques that can help a design be compliant.Normally, if I'm asked how to get a product through EMC testing, the first thing I'll recommend is that it be designed from scratch by someone with experience. Design for compliance is a deep rooted, 'day 1' thing to get right, not something which can usually be added on at the end of a design cycle.For EMC, there's no set of design rules which guarantee a compliant product.There are, however, design rules which tend to increase the likelihood of a product ending up compliant. There are also common errors which greatly increase the likelihood of a product ending up non-compliant. Avoiding these is a good start.

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: September 16, 2016, 01:52:55 pm
content: Quote from: homebrew on September 16, 2016, 11:01:10 amThere is a 3.5 option - use a lab to do informal testing of the areas you're concerned about. Same equipment, the only difference between that and a formal report is the lab's level of liability. From memory of when I did it a while ago, an afternoon was something like GBP300.The big advantage of this is you can quickly find any issues and spend time on the spot doing tweaks & mods to see what fixes or at least improves things.If you have multiple products to test this can work out very cheap per-product. And if you're really organised, you can be tweaking/fiddling with one product while others are being tested.