EMC/compliance experience for low volume - Page 1
Forum section: electronics / projects

author: dctech3
author_rank: Newbie
timestamp: February 20, 2018, 05:12:39 pm
content: Does anyone have any firsthand positive/negative experience with selling low volume products worldwide without 100% regulatory paperwork in place? I'm not talking about products that are dangerous or do not meet the standards. It's just that the cost to be 100% compliant with every country is prohibitive if you might sell 500 units a year worldwide, and just get a few orders from XYZ country. I found a few comments and opinions here and there on this forum regarding low volume producers, but not really any reports of success or failures with shipping or other issues. It seems like with it being easier and cheaper than ever to become a "maker" , that this would be a hot topic. Maybe there is another place these people hang out?For example, getting a CE mark and FCC testing _might_ be budget-able, but not all the other countries.

author: dmills
author_rank: Super Contributor
timestamp: February 20, 2018, 05:34:56 pm
content: If you do CE and FCC at the same time in a lab that is suitably certified your costs to get a CB report is not that much extra and that can then be used as evidence for certification in MOST countries (FCC and the EMC bit of CE tend to be very similar at least for unintentional radiators so do tell the lab you want both).The major ball ache at that point tends to be all sorts of mandated statements in manuals in many, many, languages.Off to the local UL lab to start dealing with this stuff tomorrowRegards, Dan.

author: rx8pilot
author_rank: Super Contributor
timestamp: February 20, 2018, 05:38:06 pm
content: I have been selling low volume products worldwide with no testing and no marks for a number of years. My current offerings are probably performing rather well, but I am positive earlier iterations were a mess. None have been properly tested.My guess is that my volume is increased to the point where I will need to do it. There are a few EU dealers that have avoided buying from me because I will not put a CE mark on the product although that only represents a tiny amount of what I sell.

author: plazma
author_rank: Frequent Contributor
timestamp: February 20, 2018, 05:52:54 pm
content: This is an interesting topic. I have been developing a product with a pre-certified BLE module and a LiIon battery. I guess I have to do basic EMC immunity test and something related to the LiIon battery. Estimating sales in only hundreds.

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: February 20, 2018, 05:57:55 pm
content: CE marking for EU does not necessarily require any testing (for non intentional RF radiators at least - not sure what the current position is on these).By applying a CE mark, you are declaring that your product meets the requirements for that type of product.Complying with applicable standards is the typical way to show that you meet the requirements. Figuring out which standards are applicable can be the hardest part, and the way you describe and market the product can have a bearing ( hint : "Kit" is a good get out in some cases).3rd party testing is not always necessary. If your own design/test process convinces you that you meet the requirements then you can self-certify based on that.If you have multiple products and do want to do EMC emissions testing, you can book a half day at a lab for a few hundred $ and test as much as you can in that time. The test results are perfectly valid to self-certify. The only difference between doing that and getting a formal certification is the test house's level of liability.Bear in mind that the enforcement process is generally complaint-driven, and the people in charge of this are typically snowed under with lethal kids' toys and incendiary phone chargers.Probably the biggest hurdle, as mentioned, is distributors that want to see paperwork.

author: Ice-Tea
author_rank: Super Contributor
timestamp: February 20, 2018, 06:16:17 pm
content: Quote from: mikeselectricstuff on February 20, 2018, 05:57:55 pmBecause, by importing your stuff in the EU they become liable. AFAIK, they inherit the manufacturers responsbilities. And so they must be able to demonstrate the products compliancy.

author: wraper
author_rank: Unknown
timestamp: February 20, 2018, 06:41:41 pm
content: Quote from: mikeselectricstuff on February 20, 2018, 05:57:55 pmBased on reflow ovens from thishttp://cif.fr"wonderful" manufacturer, nobody bothered and they were successfully selling at Farnell and other distributors by just slapping CE onto them. There is no way something like this would pass HV insulation test.https://www.eevblog.com/forum/reviews/deadly-insane-design-(cif-ft-02-reflow-oven)-teardown-rant-safety-fix/

author: rx8pilot
author_rank: Super Contributor
timestamp: February 20, 2018, 06:50:34 pm
content: I decided not to self-certify even if my confidence was high. I would rather tell people that I make no claims than making a claim that can be proven wrong.

author: Neilm
author_rank: Super Contributor
timestamp: February 20, 2018, 07:18:19 pm
content: Quote from: plazma on February 20, 2018, 05:52:54 pmIt would need to meet the Radio Equipment Directive if put on sale in the EU. This would also need some EMC emission tests and I think the RED means you have to test around the transmission frequencies to ensure there are no unwanted side bands.

author: plazma
author_rank: Frequent Contributor
timestamp: February 20, 2018, 07:30:23 pm
content: Quote from: Neilm on February 20, 2018, 07:18:19 pmThe BLE module is already certified (SiLabs BGM111). According to one guy (who does certification stuff for work) you can use the BLE module certification and skip the emission tests. Only immunity is needed and some tests related to the battery.

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: February 20, 2018, 07:36:47 pm
content: Quote from: plazma on February 20, 2018, 07:30:23 pmAccording to this :https://community.cypress.com/docs/DOC-10579For Europe the end product needs to be tested for emissions

author: TimNJ
author_rank: Super Contributor
timestamp: February 20, 2018, 07:39:17 pm
content: You may have run across this thread I started a few months ago. The responses might be helpful:https://www.eevblog.com/forum/chat/bringing-a-product-to-market-certification-markings-not-getting-sued-etc/msg1344574/#msg1344574

author: T3sl4co1l
author_rank: Super Contributor
timestamp: February 20, 2018, 07:59:23 pm
content: In that case, you have two problems:1. Finding buyers/distributors who will accept inferior goods (i.e. no cert),2. The risk of regulators discovering your product is out of compliance and taking action (blocking the device at customs, or taking fines).#1 is easily solved with a direct sale to end user. No one checks, and no one cares (until it affects them, or someone else).#2 is harder to deal with. I wouldn't think the expected cost is very much, for a quantity that low. But the worst-case cost can be quite high. That might be the kind of thing business insurance can cover, but that's rather expensive already, so you'd be better off doing it your own way (save up some cash to cover possible expenses), or just getting it tested.Tim

author: rx8pilot
author_rank: Super Contributor
timestamp: February 20, 2018, 08:08:30 pm
content: Quote from: T3sl4co1l on February 20, 2018, 07:59:23 pmAt the moment - I only sell directly to the end user. It could change this year, but there is a clear simplicity in direct sales. After some analysis - I found that I would have to at least double my output to make the same money. Since I am already operating close to my limits - I would have to buy more equipment, hire a person, and lease more space to double my output. Now, I would have to quadruple my sales to make the exact same amount of money.4x the work/risk for the same money. The easiest math ever, lol.I think I can do something around an 8-10x this year that makes it worth it. Once you get over the hump, production increases become incremental. At that point, I will be looking to properly test and certify.

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: February 20, 2018, 08:59:36 pm
content: Quote from: T3sl4co1l on February 20, 2018, 07:59:23 pmIf you're exporting, this is only the importer's problem as they are the people bring it in to their country - the worst that can happen to you is the product is blocked from being imported.

author: dctech3
author_rank: Newbie
timestamp: February 21, 2018, 02:15:47 pm
content: Thanks for all the comments and opinions. Thanks especially to rx8pilot for bearing his soul about selling unmarked products! Any other success/failure stories would be much appreciated. That was my primary question so that I can judge what the risk level is for low volume in actual practice. So far I haven't heard any horror stories. Also so far it seems like the best cost/benefit/risk plan would be to get CE & FCC testing done in a lab in China, add those marks, and take my chances on the other countries.

author: jmelson
author_rank: Super Contributor
timestamp: February 21, 2018, 09:46:03 pm
content: Quote from: dctech3 on February 21, 2018, 02:15:47 pmI've been making motion control hardware since 2002 with no certification or testing. I sell these as modules (controller, servo amp, encoder converter, etc.) that the end user assembles and wires up into a system. I've never had a problem (yet!!) with this. I do make the boards to be as CE compliant as I can. I'm also one of VERY few manufacturers that put an LC output filter on my PWM output stages to reduce EMI. I have sold several hundred of these servo amps over the years, as well as several hundred of the controller boards. I think I'm closing in on having sold 2000 boards of all the different types combined.Jon

author: dctech3
author_rank: Newbie
timestamp: February 22, 2018, 08:10:57 pm
content: Here's a useful reference:https://gma.ul.com/about/globalmarkets/It's not 100% complete, but you can see the very high-level requirements for several countries, split by Safety/EMC and radio equipment. For example, for Brazil, it shows:End Product Testing Required When Using an Approved RF Module? = YES

author: AndyC_772
author_rank: Super Contributor
timestamp: February 22, 2018, 08:22:26 pm
content: If you're using a pre-tested radio transmitter, then you may not need to do R&TTE testing on it, provided you use it in accordance with the manufacturer's instructions (esp. antenna type and gain).Legally you do, however, still need to do the same emissions testing as you would on any *un*intentional radiator.