RE: Re: CE certification

["Nikola Kasic" <nikola@xxxxxxx>]

Thanks Tony.

One more interesting question:

If I sell everything as a kit consisting of CE compliant components what's the situation then.

E.g. I found all the components to build TiVo or similar and I prepare software, self unpacking ISO image. Then I don't want to bother assembling and installing the things, but I sell it as a kit. All the components are CE compliant.

Will I be responsible, if when assembled resulting product is not, or do I have to certify resulting product?

Cheers,

Nik

-----Original Message-----
From: Bricknell, Tony [mailto:tony.bricknell@xxxxxxx]
Sent: 29 May 2002 14:24
To: ukha_d@xxxxxxxSubject: RE: [ukha_d] Re: CE certification

Sorry, I started typing this before lunch, then came back and saw several
replies.  I hope what I've written helps and doesn't overlap anything others
have said:

In order to bring to market a product in the EU the manufacturer or, where
the manufacturer is not in the EU, the manufacturers representative or,
where the manufacturer does not have a representative in the EU, the
importer needs to show that the product meets all appropriate standards.
This is done by holding a "Certificate Of Conformity" stating which European
Directives the product complies with.

For our type of stuff, that means the Low Voltage Directive (LVD) and the
ElectroMagnetic Compatibility (EMC) Directive.

The LVD is basically there to ensure that users of your product are not
exposed to any hazards during normal use and single-fault conditions.  It
covers products operating at voltages greater than 50V (there is an upper
limit, but I can't remember it off the top of my head).  You make your life
easier if your product is powered >from inside your product are less than 50V.  If
not, you need to ascertain which British Standard / European Norm your
product is categorised under, and claim conformance to that standard.

EMC is somewhat worse(!)  Unless your product has no electromechanical
components, or you can prove it has a negligible EMC signature (such as a
wrist watch), you need to show that your product complies with the relevant
EMC standards.  This is where it gets messy -

You can either go the "Standards Route" to compliance : there are 100's of
standards, and probably only one or two that your product falls into.  Try
the EMC Compliance Journal web site http://www.compliance-club.com/index.php
for a start.  Be prepared for a lot of reading.  Alternatively, look for a
friendly EMC testhouse (we use ETS in Dunmow, Essex - 01371 856061) - at a
minimum I would imagine two days testing is required - at circa ?700 per
day!

Or the "Technical Construction File (TCF) Route" to compliance : this is
where you prepare all technical, design, and in-house test documentation,
send the lot off to a "Notified Body", pay them ??k's up, and await their
comments.  If you have designed it using sound engineering practices, with
regard to EMC from the start, then they might just issue you with a
certificate of compliance.  This route is now mainly used where the designed
product doesn't easily fit into one of the categories for the "Standards
Route".

As for Dave's comment about small-time PC assemblers - IIRC, a year or so
ago Trading Standards took a small-time PC manufacturer to court and won.
They had been assembling PC's using CE marked components however, the final
PC's did not meet the EMC standards (even though each component part therein
was CE marked). CE + CE does not naturally equal CE.

But as for Nik's original question - yes, there is a legal requirement for
you to have a certificate.  However, you don't _have_ to do any testing at
all - it's all a matter of showing due diligence.  I can't remember the
origin of it but the phrase "You have to be 80% certain that 80% of your
product would pass (the EMC tests)" sticks in my mind from many years ago.
You may decide that because your products are small, low powered, and sold
in very low quantities (Trading Standards would not expect you to spend
?2000 getting a product EMC tested if it sells for ?30 and you're likely to
only sell six products in its lifetime), then the simple act of operating an
AM radio close to the circuit and confirming that radio reception is not
interfered with may be sufficient.

In reality, you're not likely to get any problems unless a user of your
equipment finds it malfunctions when, say, the microwave is on.  Or their
television reception is interfered with by the use of your product.  That
coupled with the fact that Trading Standards don't have the manpower or
finance to effectively police the directive.

(Apologies if my definitions are not 100% correct as I'm running from
memory.  Standard disclaimers apply.)

HTH
Tony

-----Original Message-----
From: Downes, David [mailto:David.Downes@xxxxxxx]
Sent: 29 May 2002 12:11
To: 'ukha_d@xxxxxxx'
Subject: RE: [ukha_d] Re: CE certification


If I remember correctly all electrical equipment which is sold has to
guarantee meeting the standards for electromagnetic compatibility.  This
guarantee is either by testing or via documentation and someone taking legal
responsibility.  This is not an area I'm familiar with, and wonder what the
situation is with regards to small time PC assemblers.  Are all the
components supposed to be CE certified and therefore the product as a whole
is?

Dave

-----Original Message-----
From: paul_watkin [mailto:paul_watkin@xxxxxxx]
Sent: 29 May 2002 11:59
To: ukha_d@xxxxxxxSubject: [ukha_d] Re: CE certification


From memory if you use an external power supply that is CE approved
you still need to have your product tested but as you don't have
mains going into it the testing is less complex and therefore cheaper.

Regards

Paul

--- In ukha_d@y..., "Nikola Kasic" <nikola@k...> wrote:
> Does anyone knows:
> If I want to design and start selling some electrical device, when
do I need
> to get CE certification.
> I think that proces for obtaining such certification is expensive
so, for
> the cheap things and small series, probably it's not worth taking
such
> route.
> However, I would like to know, is there any legal requirement to
have such
> certificate if you want to sell such devices.
> I think that someone mentioned that if your device has separate
power supply
> then it doesn't need it.
> Anyone to put some light on this issue?
> Nik



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