FCC/CE marking for selling electronic products - Page 1
Forum section: electronics / projects

author: ElectronicCat
author_rank: Regular Contributor
timestamp: February 08, 2019, 06:00:17 pm
content: Hi all,I've been looking into the idea of getting some of my hobby projects turned into a small production run of probably around 100-1000 units, pick & place assembled, pre-cut housings made and mechanical and through hole assembly done at home myself to sell worldwide. However, the more I look into it I get the feeling I will need to get it FCC/CE approved in order for it to be sold at least in two major markets (are there similar requirements for other countries I'm missing?).Most of my projects are either DC powered or use a separately CE-marked power supply module so I'm not too worried about the mains safety part, as I know it is acceptable to include marked parts in an assembly without having to re-certify it. However, some of them do include mains PCB traces. Would this require it to be re-certified?I'm more concerned with EMI testing. Is this something that is required for every electronic product (both for FCC and CE)? Even if it is benign (for the sake of an example, a battery powered LED)? What mostly prompted it is an RF signal generator project I'm working on. Whilst it's designshouldn'tradiate any unwanted interference, I believe that it would still need to be tested as it produces a signal above a certain frequency (still playing around with designs, but will probably either be up to 500MHz or up to 1.9GHz+). This is somewhat fine, and I understand with CE marking I might be able to self-certify it to reduce costs but as far as I can tell there's no such option for the FCC. If it is required then it would add about +20% cost to the estimated price I could sell for! I can't seem to find any good resources either that cover what does/doesn't need to be tested (other than things which intentionally radiate and don't use pre-certified modules).I realise there's probably a low chance of anyone asking questions in this low quantity (are there even exceptions for low volume production?) and I would probably agree if it was just like 10 units hand assembled but for this sort of quantity I'll probably be setting up a company and the assembled items will be more 'professional' so I'm a bit more paranoid about it.Is there anyone who's been through the process who could answer some of these questions and let me know what, (if any) compliance standards would apply to my project and anything else related to compliance testing I might have overlooked?

author: nsrmagazin
author_rank: Regular Contributor
timestamp: February 08, 2019, 06:39:02 pm
content: You should ask the eBay support, they should know. I think in the EU it has to be marked with CE to be sold but for a home made device it should not matter.

author: Neilm
author_rank: Super Contributor
timestamp: February 08, 2019, 06:56:57 pm
content: If you are selling completed units in the EU or associated markets you will almost certainly have to have the CE mark fixed. I believe that kits don't need it.To apply the CE mark, you need to produce a declaration of conformaty. I signed piece of paper that says it meets all the relevent EU directives. You back this up with a technical file containing the proof it meets those directives. For your battery powered LED torch, you just write that it is inherintly benign. There generally isn't a a "minimum frequency" as the radiations are independent of the frequency, they depend on the slew rates (it is possible to fail EMI with a signal at 1 kHz). Emissions are generally tested at 30 MHz to 1 GHz or 5 times the highest frequency.I can't comment on the FCC requirements but the standards are reasonably harmonised world wide so if it passes EMI for the EU it will probably meet the requirements for the FCC. I seem to recall they are mostly concerned with emissions and not too fussed about immunity.In your position, I would check on the government website.https://www.gov.uk/guidance/ce-markingIt gives a pretty good idea of the steps you have to take, although they are very high level.Safety would have to be still have to be checked to ensure you have met the creepages & clearances for mains as required by the safety standard that is applicable (generally 3 mm). Again, this would be in a technical file.Please note that I am an engineer by trade not a lawyer, so if in doubt talk to test houses and they should be able to advise.After Brexit the UK will (probably) be outside the EU market, so the onus of fixing the CE mark will apply to the person / company that imports the item into the EU and first places it on the market. As this is all up in the air at the moment, we will have to see how this pans out but you may be able to get away with not fixing the mark. I also don't know what standard will be used in the UK and wether or not you would need to fix it as I do know it will be needed on fewer product types.

author: jbb
author_rank: Super Contributor
timestamp: February 08, 2019, 08:00:32 pm
content: It’s a bit of a mess. Many countries have their own rules. Over time, these rules are slowly being harmonised but it’s not done yet.Re the RF generator: I think - but I’m not certain! - that there are some exemptions for test equipment.Re mains: bad news! If your design handles mains in any way you’ll need to get it safety certified (maybe IEC60950??). Using CE compliant modules helps a lot, but it’ll still be expensive. The best bet is to use a certified plug pack so the mains never comes into your product.Unfortunately, plug packs can complicate EMC. They are typically EMC tested at 0%, 50% and 100% load. However, there may be a point somewhere in the 10% to 30% load range where they have low duty cycle, lots of ringing, and cause EMC emissions failures.Re UK: hopefully however the politics fall out they choose to keep the CE regulations. If they Brexit and change to their BS regulations (British Standards) then all they will do is increase compliance costs.

author: T3sl4co1l
author_rank: Super Contributor
timestamp: February 08, 2019, 08:15:27 pm
content: 1. Caveat emptor. Ideally, buyers should be aware that, if the product doesn't carry these certs, it may not be safe to operate for long, or in general. (Safe in regards to, say -- knocking out nearby emergency services, would be the worst-case sort of condition.) And therefore will make purchasing decisions accordingly. The reality is, ain't no one got time fo dat, price is king, and eBay is an unregulated marketplace.2. Typically, the end user or importer is liable. Obviously, the manufacturer or distributor bears responsibility too, but I think that comes down to truth in marketing. Don't claim it's FCC approved when it's demonstrably not; don't sell it as a general-purpose product when it's clearly a component, or test equipment, or whatever.3. Consider how violations are processed. A licensed user detects interference and submits a complaint; the complaint is investigated, and a source identified. The first letter is a C&D to the user -- stop operating the offending device. If they continue, the process escalates. If the device is approved but found to be faulty, it comes back to whatever the source is; if the device was imported, it may dead-end at the importer, since law doesn't usually extend beyond borders (but, depends on treaty).At least, I think that's a roughly accurate overview of the process here. YMMV, IANAL.4. Also along the gray line of the law -- reports seem to be quite rare. I know of products that were distributed in the 10k's quantity that never went through FCC, and that apparently never got a call about it. Testing is costly (figure ballpark $10k with a testing lab), and it doesn't make sense to do for small quantities.You want to air on the side of caution, but it is absolutely just another business gamble. If you're willing to take that risk, it may pay off. (Reminder that legal fees and fines are accounted for, and written off, just the same as any other business expense, even to the IRS themselves.)5. Speaking of test equipment: it is typically exempted. Since, a lot of TE intentionally makes nasty fields, at least on the hot end, so, what else could you do? The catch is, it must only be operated in a shielded room/facility, by authorized technicians. Which... who are you to judge? There is no state authorization of technicians, it's up to the buyer/end user to determine that. So, the manufacturer is not liable in this case, and it's up to the end user to follow procedure. (Again, "I think", IANAL and all that.)There are also exemptions for distributing articles intended for testing and not individual sale, but that I think is basically "dotting the i's and crossing the t's", not actually useful for marketing...6. FCC doesn't require immunity testing (they do at least suggest it), but CE does. YMMV.Tim

author: ElectronicCat
author_rank: Regular Contributor
timestamp: February 08, 2019, 08:35:13 pm
content: Quote from: Neilm on February 08, 2019, 06:56:57 pmThat's useful to know, thanks. I'll obviously do some basic EMI testing myself (after all, it'd be no use to anyone if it's super noisy itself). CE conformity seems relatively easier than FCC and I believe allowable limits are higher with FCC so you're right, if it passes CE it should also pass FCC. I guess this will reduce the cost as I'll only have to pay for the one test.Quote from: jbb on February 08, 2019, 08:00:32 pmThat would definitely be good news. I've just had a look at it seems there is an FCC exemption for test equipment. For CE it seems a bit more ambiguous, all I could find is exemptions for medical test equipment or 'equipment designed to be used by manufacturers'. I guess by some broad definitions this would include electronic test equipment but my main target audience would be other hobbyists who can't afford high end name-brand test equipment.Quote from: Neilm on February 08, 2019, 06:56:57 pmQuote from: jbb on February 08, 2019, 08:00:32 pmHmm, looks like I'll have to do some more digging on this then. I've got ample clearances and creepage distances so I know it would pass any test if needed but it's just another hoop I'd have to jump through that I don't really need to. Fortunately it wouldn't be too difficult for me to just include a DC plug pack instead but it's a bit messier (I hate power bricks floating around). The PCB traces literally just go from input terminal block > PSU module. Would switching to an off-board sealed module with crimped wire connectors be any different?

author: jbb
author_rank: Super Contributor
timestamp: February 08, 2019, 09:11:49 pm
content: Quote from: ElectronicCat on February 08, 2019, 08:35:13 pmI don't know, sorry. You'd almost certainly still need a lab to evaluate it.

author: Leo Bodnar
author_rank: Frequent Contributor
timestamp: February 08, 2019, 10:21:00 pm
content: I recommend this book:https://www.amazon.co.uk/EMC-Product-Designers-Tim-Williams/dp/0750681705/Put it towards your business costs when you register as a sole trader (you should.)It covers everything from legislation to design techniques to measurement protocols.You probably won't have to buy the EN standards either because a lot of them are quoted in the book.Leo

author: jmelson
author_rank: Super Contributor
timestamp: February 08, 2019, 10:36:30 pm
content: Quote from: ElectronicCat on February 08, 2019, 06:00:17 pmUGH! This is a major reason I do not sell "complete units" but only board-level products. I could make a lot more money selling complete, turnkey setups, but that DOES require emissions testing and at least in the US strongly pushes you toward safety testing, too. I did sell a device a long time ago that I had tested just for FCC compliance, and it cost about $3000. 30+ years later the cost has gone WAY up. With what I'm selling now, everybody would want a custom version, or at least some number of options, and every possible combination of options would need another test run.Lots of outfits simply ignore the testing requirements, and apparently are getting away with it. That's kind of scary, as bad EMI interference is not good, and really bad electrical safety practices are even scarier. You will likely be forced to go through all this if you want to get insurance.Jon

author: T3sl4co1l
author_rank: Super Contributor
timestamp: February 08, 2019, 10:56:34 pm
content: Quote from: Leo Bodnar on February 08, 2019, 10:21:00 pmIncidentally -- no relation (same name), but I understand the books are quite good. Also books by Henry Ott (not so much in relation to standards I think, but regarding testing and treatment).Tim

author: Neilm
author_rank: Super Contributor
timestamp: February 08, 2019, 11:04:09 pm
content: Quote from: Leo Bodnar on February 08, 2019, 10:21:00 pmI have found the books and articles by Keith Armstrong to be very useful - not too much maths and a lot of practical advise. Have a look athttp://www.compliance-club.com. You might have to register (for free last I checked) and look up some of his past articles.

author: OwO
author_rank: Super Contributor
timestamp: February 09, 2019, 07:24:16 am
content: This is why you should consider running your business from ChinaAbout the mains safety part, yes, if any kind of mains voltage pass through your device then it is problematic. Even if mains wiring goes straight into the pre-certified module there are tons of potential issues that can be lethal: inadequate strain relief on wires, heat dissipation problems, EMI from your device interfering with the power supply controller, etc. I would go for an off the shelf plugpack to be safe.FCC testing however I don't see much moral issues skimping on. I would do some basic tests, look at the spectrum analyzer with an antenna (even a cheap SDR will do), and make sure there aren't any high peaks in the spectrum (compared to when the device is off). If there are some HF emissions that are slightly over the limit, who cares?

author: T3sl4co1l
author_rank: Super Contributor
timestamp: February 09, 2019, 08:29:30 am
content: Oh and power supply modules are assumed to pass regs -- they're tested separately for mains stuff like conducted and surge. This makes it a whole lot easier to make a product with a wall wart, than with an integrated supply!Tim