Multiple product certifications without repeating tests - Page 1
Forum section: electronics / general

author: liteyear
author_rank: Regular Contributor
timestamp: June 24, 2019, 01:46:30 am
content: We're deep into the big commercialisation push on a new industrial electronic product. The design has been frozen and getting it through the test-houses it fast becoming urgent to meet customer demand.Initial target markets are Australia, North America, Latin America and Europe. We've requested quotes to get certs to cover all these regions and they've been delivered back to us region-by-region. The costs for Latin America are relatively low. FCC and RCM have been bundled together and are significant. The CE one has just come in and is mind bogglingly, project killingly high, and doesn't even include RoHS or WEEE. Given the millions of dollars that have gone into the project, this is, as you might expect, a bit of a drama...My impression was that enough harmonisation has occurred now that a lot of the test reports could be re-used for multiple regions. So my questions, dear EEs, are:Is our testhouse taking the long way around and charging us for the journey? They haven't been responsive to enquiries along those lines.Is CE certificaiton just not worth it, and we should upskill to do self-assessment pronto?Should it cost >$100k to gain the major certifications?Are we better off just specifying tests and doing the docs ourselves?Our product is powered by ELV DC and contains pre-certified cellular and WiFi modules, encased in a custom metal enclosure with cables running to external antennas. It uses Gigabit Ethernet internally and a 1.9GHz processor.

author: Tomorokoshi
author_rank: Super Contributor
timestamp: June 24, 2019, 02:58:03 am
content: That's a tough situation. It can take being on a few product cycles before the method of working with standards and agencies starts to become familiar and make sense. Then the team is changed around, and it starts again in the middle.This is particularly dangerous if management isn't quite aware of the situation, and gets concerned about schedules and spending money.1. Test agencies operate differently. Not sure how yours is set up. They may not have all the certifications to do the regional tests you request. How much is done locally and how much is distributed out?2. Not sure what is involved in your particular situation. However, in general anything with intentional transmitters is very expensive.3. US $100k is on par with complex, multi-region, ratio-enabled products. Could be worse.4. That doesn't work. You will spend way more than that on salaries, easily that much on equipment, and you will still not have the laboratory certifications.Multi-region EMC testing alone without intentional transmitters might be in the $15k range alone for an AC-powered device. Transmitters alone seem to be adding around $50k these days.

author: windsmurf
author_rank: Frequent Contributor
timestamp: June 24, 2019, 04:00:29 am
content: This might be helpful...https://cemarking.net/what-are-the-costs-of-ce-certification/

author: OwO
author_rank: Super Contributor
timestamp: June 24, 2019, 05:18:09 am
content: If there is no mains power or safety risk involved, just do whatever test you are capable of doing and slap on a CE certified label yourself. If it passes FCC that's good enough reason to believe it complies with CE as well.$100k to get a product certified when it poses no safety risk is unthinkable. No better way to stifle competition and ensure only the big players rule. $100k is pocket change for the big megacorporations but it's unaffordable to any home business and a sting for a small startup.

author: liteyear
author_rank: Regular Contributor
timestamp: June 24, 2019, 06:45:25 am
content: Thanks for each of the very enlightening replies.They do seem to be sending each regional certification to a different office around the country.That's why I'm thinking we just do whichever cert has the most thorough tests, and then use those results as our documentation of the other certs.You hear so much range in costs. But 6-figures is hard to take for something we'll be lucky to sell 100 of each year. Internally it's a complex device, but fundamentally it's a largely self-contained, ELV device with no moving parts and an off-the-self cellular and WiFi radio. It is what it is, but there's a lot of incentive there for us to find another way!I wasn't very clear - I meant instead of getting the full service we could specify to a test house which tests we want them to perform (after studying the cert requirements) and then collate the documentation ourselves. It was an option an earlier test house offered.The test house responded today and said they can discount by $2k due to the common tests.I still don't think I can recommend we accept the quotes as is. So would either of these be feasible:Accept the big CE quote and hand wave FCC/RCM?Accept the smaller FCC/RCM quote and hand wave CE?

author: OwO
author_rank: Super Contributor
timestamp: June 24, 2019, 07:10:18 am
content: Quote from: liteyear on June 24, 2019, 06:45:25 amI would go for the latter. FCC is mandatory but CE can be self certified. Self certified means you can slap the label on without doing anything, but if units are found non-compliant the responsibility falls on you. If it passes FCC I wouldn't be worried.

author: sokoloff
author_rank: Super Contributor
timestamp: June 24, 2019, 10:16:23 am
content: Quote from: liteyear on June 24, 2019, 01:46:30 amQuote from: liteyear on June 24, 2019, 06:45:25 amIf you're millions of dollars of development into the project, presumably that was done under a business case where selling 100 a year still has a positive ROI on a DCF basis. The question of certification costs must be considered in light of that business case.Though you must ignore the sunk costs of development, because you can't get those back, but looking forward only, if paying 6-figures for CE cert allows you to more quickly and confidently enter the European market, what course of action has you making the most money? Given the presumed marginal profit on each item (that got this project the green light), it would seem like being able to rapidly enter the EU market would be the priority.It seems like perhaps you've spent 95% of the product development total cost already and are now hung up on the last 5% that will give you a world-wide marketable product. (By all means, I support economization, but sometimes that economization can be false.)

author: liteyear
author_rank: Regular Contributor
timestamp: June 25, 2019, 09:46:23 pm
content: Quote from: sokoloff on June 24, 2019, 10:16:23 amIt's a fair point. It's all about established budget. It was a big development effort but much of that was capability and trust building - guiding a complex development project through corporate jaws to produce an in-demand product is a delicate process and that has been achieved with great success. Now there's a bucket of money set aside for commercialisation, but only ~$60k was budgeted for certs. Spending un-budgeted money on the team to improve the product is easier to justify than on an external body for activities we're not sure are necessary, and may have to be repeated 18 months later.It's a high value, low volume product, so regional costs have to be amortised over a small number of units and a long sales cycle. The global business case is there, but Europe starts looking shakey if it has unique, significant costs.FWIW, it's not my money. I'm just a consultant trying to do the best by my client. Doesn't really change much but thought I'd mention it.

author: Mr. Scram
author_rank: Super Contributor
timestamp: June 25, 2019, 09:57:57 pm
content: Quote from: liteyear on June 25, 2019, 09:46:23 pmBe sure to look closely at the cost reward. Europe may be expensive, but for many types of devices it's the largest market in the world. Gaining access to to may end up being more profitable than gaining access to South America at a lower cost.

author: GlennSprigg
author_rank: Super Contributor
timestamp: June 26, 2019, 11:57:07 am
content: Sorry if this doesn't relate !! (just some old info...)Back in the 1980's I worked for E.T.S.A. (Electricity Trust of south Australia), our power authority then.Every piece of 'new' equipment, from light switches to the latest Washing Machines etc, had to be testedby us. We would load up all machines to the max, & beyond, with countless temperature sensors etc onmotors, PCBS, etc. Individual Switches were loaded above full current, and operated by mechanical meansthousands of times under load, and then disassembled to look for 'failures'. If a 'machine'/electronic devicehad any variances like 'parts', then it was re-tested fully, again, before being allowed on the market...They, then, didn't rely on the individual 'part' having a 'ce' certification/pass.Obviously with todays complex electronics, individual 'modules' make life very difficult

author: Ice-Tea
author_rank: Super Contributor
timestamp: June 26, 2019, 12:19:52 pm
content: My 0,02$100k doesn't seem outlandish for a WW certification. I've seen worse.I wouldn't "just slap the CE label on". Sure, that's what almost all chinese do but I assume you'd want to set yourself apart from them. If you'd be looking at selling 10pcs in the EU and your first customer asks "can I have a look at your CE dossier" that would be 1 customer gone, never to return.QuoteIf I'dhaveto choose between the two: accept FCC. But with one caveat: at least draw up some kind of CE file. Could be fairly easy: waive conducted testing as you'd use a pre-certified DC/DC brick/wart (I would assume), use the FCC radiated data as a reference (maybe try to figure out the differences, make a note why you'd think you'd comply,... Perhaps not 100% equivalent but good enough to convince customers and probably shielding enough to avoid a conviction for malevolent operating in case shit ever hits the fan.But my prime suggestion would be this: hire an independant consultant. You'll probably loose 5k on that, but he'd be able to point out the backdoors, set the testhouse straight and educate you/your company on the subject. You'd probably get a multitude back, if not on this project then at least over the years to come.I know one or two of these guys but, well, not exactly your neck of the woods

author: windsmurf
author_rank: Frequent Contributor
timestamp: June 26, 2019, 06:40:15 pm
content: Quote from: GlennSprigg on June 26, 2019, 11:57:07 amHow much did you charge the manufacturers for that testing you did?

author: Jester
author_rank: Frequent Contributor
timestamp: June 26, 2019, 08:41:46 pm
content: FWIW, I certified a product last month it passed FCC A with margin but failed CISPR15 for CE, a couple of tweaks later it passed both.

author: GlennSprigg
author_rank: Super Contributor
timestamp: June 28, 2019, 10:04:15 am
content: Quote from: windsmurf on June 26, 2019, 06:40:15 pmGood question... I really don't know if they 'charged' ANYTHING !It was a requirement then, by State, mainly for proof of safety, so it was just 'done' as a public service ??Back then, E.T.S.A. never seemed to think in terms of 'money'... For instance...I remember within our OWN testing Laboratories, if we had a damaged/non-functioning Multi-meter etc., then wewould ALWAYS have to fix/repair it in-house! Even if a 'new' one was say $10 - $20, it was cheaper to spend $80repairing it, than all the paperwork & manhandling to get a new one !!!Go figure......P.S... I remember working on a lot of their old original 'AVO' (Amps, Volts, Ohms) Meters too !!!Mind you, these were NOT cheap & nasty multi-meters! Am sure a lot here will remember them, though i THINKfrom memory, that they only had an internal rating of 20,000 ohms/volt. Not good enough these days....

author: mikeselectricstuff
author_rank: Super Contributor
timestamp: June 28, 2019, 10:21:07 am
content: Quote from: liteyear on June 24, 2019, 01:46:30 amNeither of these require any third-party certificationEven if you want to go fully formal, test results for other regions can be used as the basis for CE marking.

author: fcb
author_rank: Super Contributor
timestamp: June 28, 2019, 10:50:35 am
content: My understanding is that CE is ALWAYS self-certified. You create a TCF (technical construction file) that contains the evidence/test-reports/etc..The test house will give you reports/made up certificates etc.. that show that on this day/this sample/in their lab met a certain criteria.w.r.t CE you are responsible for deciding which tests you perform on the product if any. In some cases (such as EV charging) there are specifications as to what EN tests are expected, probably the same for other sectors.Good source of what to test to is often finding out what your competition is testing to. If you need to buy standards, then buy them cheaply (& officially) from the standards body in Estonia (in the EU!) -www.evs.eethey are something like 10x cheaper.It also sounds like your product falls under RED (Radio Equipment Directive)ec.europa.eu/growth/sectors/electrical-engineering/red-directive_en