To which standards must we conform for our electronics/electrical  product? - Page 1
Forum section: electronics / general

author: ocset
author_rank: Super Contributor
timestamp: September 14, 2019, 04:48:59 pm
content: HelloMy company has developed a way of removing body and facial hair for cosmetic reasons. It involves high frequency flashing (~1KHz) of high intensity light into the skin. The skin is flashed with pulses of light, and each light pulse is further divided up into finer light pulses. Nobody else is doing it like this, and it works better.The equipment involves an offline 70W Flyback SMPS. This feeds a flash capacitor which is charged up to 400V, and then pulse flashes into a xenon tube which fires the light at the skin.The problem is, we don’t completely know exactly which regulatory approvals we must conform to. How can we find out? (We wish to sell to EU, UK and USA)From offline SMPS datasheets we can see that there are standards such as EN55015 etc that we must conform to etc …..but how can we possibly know the complete spectrum of standards to which we must conform?......i mean, we could go into production, sell 100000 products, and then find out that we have not conformed to some vague standard which applies to our use case……we would then be fined all our profits and forced to close down.If we cannot find out the full list of standards to which we must conform, then we will have to sell out to a huge corporation who is interested in buying us out. This corporation has warned us that we have no way of knowing every single standard which applies to us, and therefore we must sell out to them. They have told us that if we go it alone, they will scrutinise our product, and find which standard we are falling foul of, and report us to the regulatory bodies and get us closed down.The corporation has told us that the standards themselves are brought in by big corporations lobbying politicians to bring the standards in….they warn us that if we go it alone, they will lobby for a standard to be introduced which we do not meet, and make it impossible for us to stay in business.How can we find out every single standard to which we must conform?Or must we simply sell out and give up?

author: tggzzz
author_rank: Super Contributor
timestamp: September 14, 2019, 05:02:38 pm
content: Quote from: treez on September 14, 2019, 04:48:59 pmSo, your company developed a product without knowing what is necessary for it to be defined as electrically safe.So, your company developed a product without knowing whether it would be classified as a medical product, with all that entails.Give up, sell out.Or licence the patents you hold. Oops, you've just disclosed the key features. Shame about that. Oh well, easy come, easy go.

author: Kilrah
author_rank: Unknown
timestamp: September 14, 2019, 05:17:35 pm
content: Quote from: tggzzz on September 14, 2019, 05:02:38 pmUmm patents are public, that's the whole point of them, once they've been filed you can talk all you want about them...But yeah that sounds like strange... unless it was so easy to figure out the product it seems strange to not have researched first what goes into such kind of product.Out of the blue there will likely be things like a xenon flash throws out tons of UV you'll have to shield from, can burn your skin if power is inappropriate so you'll certainly need some way to measure the skin color and figure out the max allowable power and very sophisticated redundant systems to ensure it can't be misevaluated/exceeded,...Why not go buy an existing light based device and see in the manual and on labels everything it conforms to?Apart from that there are likely consultancy cabinets around offering their services to find that kind of stuff.The other company definitely seems a bully, but their attitude also proves that your stuff is interesting.

author: SiliconWizard
author_rank: Super Contributor
timestamp: September 14, 2019, 05:39:20 pm
content: So, as I got it, your company is specialized in SMPS and lighting devices, and it wants to address a new market, cosmetics?Oh sure, after all, there is both SMPS and light in this project.Anyway, I don't know what level exactly you're at in your company. But I'd say the decision to go through such a project with all it entails, market- and regulatory-wise, is a job for managers, or even top managers here. So I'm hoping you're one. If not, you're just being walked all over and your bosses are not taking responsibility. Well, just saying. It's none of our business.For CE marking, the top-level element you have to consider to classify a product is a directive, not standards. So, you gotta start where things start.You can start here:https://cemarking.net/eu-ce-marking-directives/GO through all the directives, read the description, see what kind of products are concerned. And select the most appropriate one(s).Once you're done with that, there may be some additional classification to do. Such as if it's considered a medical device (93/42), you'll have to find out which class it is.

author: Benta
author_rank: Super Contributor
timestamp: September 14, 2019, 06:31:55 pm
content: Forget the project.Hairy pussies are coming back.

author: MosherIV
author_rank: Super Contributor
timestamp: September 14, 2019, 06:40:39 pm
content: I agree with siliconwizard, CE marking and the various product categories within it.I do not think your product is medical, far too stringent rules for a small company to obey.I think the product is more a domestic beauty product.Technically, CE is self certifying. The company is expected to collect the evidence that tests were done to pass the various tests required for that category of product. If something goes wrong with the product and the authorities investigate, find the company did not do the tests or have the evidence (test reports, certificates etc) then the company can be prosecuted.

author: nctnico
author_rank: Super Contributor
timestamp: September 14, 2019, 06:50:13 pm
content: Quote from: treez on September 14, 2019, 04:48:59 pmDo you really consider giving in to this kind of crap?And the answer to your question is simple: your device isn't new so download the safety declarations for competing products to get a list with applicable standards. After that consult a lawyer to deal with product liability issues.

author: DimitriP
author_rank: Super Contributor
timestamp: September 14, 2019, 07:07:19 pm
content: QuoteYou can start here:Chartered Trading Standards Institute1 Sylvan Court Sylvan Way, Southfields Business ParkBasildon, Essex, SS15 6THand here:https://www.gov.uk/government/organisations/office-for-product-safety-and-standardshttps://www.tradingstandards.uk/QuoteYeah...what he said ^^^

author: ebastler
author_rank: Super Contributor
timestamp: September 14, 2019, 08:12:16 pm
content: Quote from: treez on September 14, 2019, 04:48:59 pmThere are service providers and accredited test labs who make their living providing advice on this, and testing your product for compliance. The various branches of TUV (Rheinland, Nord, Süd) are well-known, but there are many others. A NRTL (nationally recognized test lab) is what you want. Their services are not cheap, but you may need their test reports anyway, e.g. for a UL listing in the US, or you maywanttest report to minimize your liability risk.I find it hard to believe that neither you nor your company has ever worked with such test labs?!

author: 2N3055
author_rank: Super Contributor
timestamp: September 14, 2019, 08:41:20 pm
content: Quote from: ebastler on September 14, 2019, 08:12:16 pmThis!There are consultants that come in and sort it out for you. Do not do it yourself, too much work...

author: Red Squirrel
author_rank: Super Contributor
timestamp: September 14, 2019, 10:44:16 pm
content: Quote from: tggzzz on September 14, 2019, 05:02:38 pmMaking a product safe, and knowing what red tape you need to conform to in order to be legal is two different things. Take building codes for example, you can build the hell out of something and make it super safe and sturdy, but not know what the codes actually are and end up not passing inspection even though it's better than code.

author: tooki
author_rank: Super Contributor
timestamp: September 14, 2019, 11:58:35 pm
content: Quote from: treez on September 14, 2019, 04:48:59 pmGiven how hopelessly clueless you guys are in every key aspect of running an electronics company (and the extent to which you're helpless in finding the info you need), you'd be better off liquidating and going into... some other industry where you all have more aptitude. Perhaps lawn care services? Street sweeping? Busking?

author: Dundarave
author_rank: Regular Contributor
timestamp: September 15, 2019, 12:23:24 am
content: Regardless of any applicable regulations, you should probably first investigate if your "original idea" isn't already treading on somebody else's patents. Or you'll be paying defense legal fees and damages in addition to any regulation-testing services...As was pointed out earlier, depilation using pulsed light has been around for decades, and there are likely many dozens of enforceable patents already granted. It's highly doubtful that there's any new ground to be ploughed in this space.

author: Red Squirrel
author_rank: Super Contributor
timestamp: September 15, 2019, 02:10:42 am
content: Patents tend to be a huge barrier to trying to make and sell a product sadly. It's what discourages me from wanting to make and sell anything. I have lot of ideas but the red tape is the issue to getting it off the ground. Even if I make a product I think I will just sell it as a DIY kit for hobbyists as it would narrow my target audience enough that I hopefully stay under the radar. IP law related lawsuits are no joke. You lose everything including your house as they typically want millions which an individual won't have.It's near impossible to come up with a 100% original idea without using some concepts that may have been done before. Need to do a patent search and it can be very expensive.As for the standards you could contact a company like CSA, ULC, ETL etc and ask them and it might point you in right direction. Since this is sorta a medical device there are probably some standards for stuff like that too you'd need to follow. Check out those devices that make your muscles spasm and see what standards they have, as those use high voltage too. Basically you might need to do a bit of digging by looking at devices that are somewhat similar to yours to see what they conform to.The patent stuff is what I'd worry about the most though. I'm not sure what the fines are for not conforming to a standard but don't think they're as high as patent infringement.

author: ebastler
author_rank: Super Contributor
timestamp: September 15, 2019, 06:29:35 am
content: Quote from: Red Squirrel on September 15, 2019, 02:10:42 amWhere did you get that notion? Royalties on IP are always related to revenue (a few percent of it, up to say 10% if the product really is enabled by a key patented invention). If you sell a product on a small scale, I don't see where demands for "millions" would arise.The worst "fine" you could get is triple damages, if youwillfullyinfringe on a patent in the US. Perform an IP search before you go ahead, and document the results. That's sufficient proof that you took adequate care to ensure your freedom to operate and are not willfully infringing (if you should have overlooked someone's IP).

author: tszaboo
author_rank: Super Contributor
timestamp: September 15, 2019, 08:27:25 am
content: Quote from: tooki on September 14, 2019, 11:58:35 pmIts just treez being treez. I'm surprised it is not another thread, that rambles that SMPS or an LED is cheaper in china. I imagine a company with 4-5 people. O are only working part time, because they realize that the company makes nil profit, and they have a family. Having meetings with no idea about what the company is actually supposed to sell. And all the products are really mundane, because the lack of expertise.It is really sad, if you think of it.

author: Zero999
author_rank: Super Contributor
timestamp: September 16, 2019, 12:36:43 pm
content: What's new? As mentioned above pulsed light has been used for years to remove hair.Going from the little I've just Googled, laser is better, than pulsed light from a xenon lamp, because it's narrow band radiation, which can be tuned to the absorption band of the hair.https://www.telegraph.co.uk/beauty/skin/does-ipl-hair-removal-really-work/https://en.wikipedia.org/wiki/Intense_pulsed_light#Hair_removal

author: themadhippy
author_rank: Super Contributor
timestamp: September 16, 2019, 01:14:47 pm
content: if your selling in he uk forget the ce mark after29 March30 June 201931 October 2019some date in the future ,were getting a new onehttps://www.gov.uk/guidance/prepare-to-use-the-ukca-mark-after-brexit

author: Red Squirrel
author_rank: Super Contributor
timestamp: September 16, 2019, 03:20:50 pm
content: Quote from: ebastler on September 15, 2019, 06:29:35 amSeems to me IP related lawsuits are always in the millions. Even a single user downloading an MP3 or movie tends to get hit for insane amounts. They tend to settle but it's still 10's if 100's of thousands. Though it's been a while since there's been any download related lawsuits. Patents seem to be the bigger thing now. You can patent the most oddball thing that others won't think about even doing a search for so you can still get dinged if you accidentally infringe. Very lucrative for the patent holders.

author: Zero999
author_rank: Super Contributor
timestamp: September 16, 2019, 03:46:16 pm
content: The patent system went full retard along time ago, especially in the US. I don't think they even bother having engineers or scientists properly check applications. Nowadays it seems to be a way for the government to make more money, than its original purpose, which was to encourage innovation. Look at the really stupid stuff Microsoft have managed to patent.https://www.eff.org/deeplinks/2015/12/stupid-patent-month-microsofts-design-patent-sliderhttps://www.edwardtufte.com/bboard/q-and-a-fetch-msg?msg_id=0003Y1

author: CatalinaWOW
author_rank: Super Contributor
timestamp: September 16, 2019, 04:02:45 pm
content: You have other paths forward. First, the business tactics you are describing are very possibly illegal in your venue. If you have your claims documented you might have real negotiating power in this area. Second, if a large company is interested enough to strong arm you in this way there are surely other large companies that might be interested. You can at least shop around and get a good price for your product. Think of the joys of a bidding war. But recognize also that all of the regulation threat may be a bluff, just a negotiation tactic.Of course there must be a lot more going on here than described. How did the big company find out about your product? How much of the critical detail (the secret sauce that makes your device better) have you revealed? How much do you know about how much better it is? Does it work equally well on all hair tints and textures or does each type require tuning? Perhaps you have developed an auto tuning method.The details will be the essence no matter which direction you go.

author: ebastler
author_rank: Super Contributor
timestamp: September 16, 2019, 04:12:22 pm
content: Quote from: Zero999 on September 16, 2019, 03:46:16 pmThe first is adesignpatent. That doesn't really count; it does not lay claim to the underlying functionality, but only to the specific graphical rendition. Draw your arrows or slider a bit differently and be done with it. (As witnessed by the many sliders in competing operating systems; rest assured that they don't pay license fees to MS...)The second one is an application for a "proper" utility patent, and a patent was actually granted on that one:https://patentimages.storage.googleapis.com/46/99/48/9470918f93e889/US10289671B2.pdf.But the granted claims much narrower than what they applied for. It seems that MS, under pressure from the examiner, did limit the subject matter to something that was "new" at the time (although I don't know about "inventive"...). And a full book by Mr. Tufte, who complains on the web page you cited that he thought about this before,wasconsidered in the examination process.It's easy to state "the patent system is broken". But if all you look at are patentapplications, that statement does not have merit. Anybody can make a wish, but not all wishes are granted (by the patent examiner, in this case).

author: CJay
author_rank: Super Contributor
timestamp: September 16, 2019, 04:40:06 pm
content: Your company developed nothing, that's an age old proven technology that's been in use in beauty parlours and cosmetic hair removal clinics for decades.Do your own due diligence.

author: Zero999
author_rank: Super Contributor
timestamp: September 16, 2019, 08:17:10 pm
content: Quote from: CJay on September 16, 2019, 04:40:06 pmTo be fair, we haven't seen the details of the design. There have been plenty of novel designs, based on old ideas.

author: Red Squirrel
author_rank: Super Contributor
timestamp: September 16, 2019, 09:44:29 pm
content: That and there's nothing wrong with making a product if an existing one does not already exist. That's how you end up with competition and variety. Imagine if there was only one company that made cars.

author: Halcyon
author_rank: Unknown
timestamp: September 16, 2019, 11:53:55 pm
content: Quote from: treez on September 14, 2019, 04:48:59 pmIsn't this what laser hair removal essentially is?Ultimately, real medical devices used by real medical professionals require approvals. Any old crap which is purported to do something really doesn't (apart from being electrically safe). Anyone can be a beautician with no formal training. Would I be trusting my body to these devices/people, absolutely not!

author: soldar
author_rank: Super Contributor
timestamp: September 17, 2019, 06:57:17 am
content: Better get good insurance and legal representation because sooner or later someone is going to sue you alleging your product burnt their skin or gave them skin cancer, dry skin, oily skin, flaky skin, wrinkled skin, loss of appetite, cramps, hair growth, loss of vision, damage to eyesight, loss of sexual desire, loss of sexual opportunities, increase in sexual frustration, etc. It does not matter whether the claim has any basis in fact, they will sue you in the hopes of getting some settlement and you better be ready.

author: tooki
author_rank: Super Contributor
timestamp: September 17, 2019, 10:05:06 am
content: Quote from: Zero999 on September 16, 2019, 03:46:16 pmWell, I think the US patent system hit “peak retard” around 10 years ago, and a number of court precedents since then have begun to curtail patent trolling.That said, not all patents are frivolous, and design patents certainly are not within the scope of what I consider abusive. (I think it’s perfectly legitimate to be able to protect the look of your designs. Others can make their own designs. Make your own sliders. Choose your own corner radius and button location.)As for “not bothering to have engineers or scientists check applications”, that’s nonsense. The patent and trademark office has tons of subject matter experts who review a ton of applications in less time than we should be giving them. The problem is that when a dumb application is rejected, the applicant can resubmit it, and by law it must go to a new patent reviewer. And you can do this ad infinitum. So what happens is that the application gets resubmitted and rejected until they’ve exhausted all the subject matter experts, so it goes to reviewers who have less expertise in that area. Eventually, one of them will approve it, and boom!, you have a frivolous patent that should never have been issued.

author: tooki
author_rank: Super Contributor
timestamp: September 17, 2019, 10:08:45 am
content: The other thing is that many applications are deliberately worded to make them difficult to review, so as to either sneak in a broader patent definition than appears at first glance, or simply to get a knowledgeable reviewer to reject it as “this is nonsense”, so as to deliberately exhaust the subject matter experts and get it into the desk of a patent reviewer from a different department.

author: CatalinaWOW
author_rank: Super Contributor
timestamp: September 17, 2019, 04:25:46 pm
content: Quote from: tooki on September 17, 2019, 10:08:45 amSounds like a simple problem to fix. A typically American solution would be a three strikes and you are out rule. If three different examiners find your application valueless it probably really is valueless. I know there will be scams to get around a rule like this, but there are ways to suppress those also. The problem is to suppress the influence of money that changes hands at the legislative level so the patent office can accomplish what I am sure the technical experts want and know how to do.

author: tooki
author_rank: Super Contributor
timestamp: September 17, 2019, 04:36:46 pm
content: With the caveat that I am not an expert on the patent approval process, I agree that something like that would make sense. Or the ability for a reviewer to reject without prejudice (so free to resubmit) or reject permanently (resubmission prohibited) when they think it’s abusive. Or something like that.