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Home > Archive > Electrical code Compliance > June 2006 > CE marking newbie
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| Steve Sousa 2006-04-13, 7:21 am |
| Hello:
I'm suposed to design some products to put on the market in europe, as
far as i've been able to find out, i must design them to meet the CE
marking, and that implies at least compliance with emc emission and
resistance.
What other standards does it need to comply with?
What about safety?
The base product is small pcb with a cpu, a gsm modem, and a lithium-ion
rechargeable batery (oem cell, not a pack, i.e without any
electric/electronic protection circuits). It measures temperature, and
responds to digital inputs with digital outputs, thru a transistor or
relay.
There are 2 variations:
One is to install on car/motorcicles/trucks that includes a gps receiver
and bluetooth transceiver, housed on an entirelly metalic case.
The other is a fixed instalation powered by the mains thru an
off-the-shelf power suply, meant to be installed on houses or on
factories, that has a keyboard, an lcd, bluetooth, and optionally a
serial port, and/or a video camera input, housed on a plastic case.
Does the LVD apply? the supply input is specified as 10~40 VDC, which is
bellow the 75V mentioned on the Low Voltage Directive.
The modem manufacturer design guidelines state that "it is essencial the
application power supply is designed to comply with the specification in
section 3. This will be sufficient to pass type approval, no RF testing
will be required if it meets these specifications"
The bluetooth stack is developed in-house.
Can we really avoid the RF tests?
Sorry for the cross-post to sed but seec looks dead with only a couple
of posts on the last week.
Thanks in advance.
Best Regards
Steve Sousa
| |
|
| "Steve Sousa" <etsteve@yahoo.com> wrote in message
news:443e1f6b$0$92471$892e0abb@auth.newsreader.octanews.com...
> Hello:
> I'm suposed to design some products to put on the market in europe, as far
> as i've been able to find out, i must design them to meet the CE marking,
> and that implies at least compliance with emc emission and resistance.
> What other standards does it need to comply with?
> What about safety?
> The base product is small pcb with a cpu, a gsm modem, and a lithium-ion
> rechargeable batery (oem cell, not a pack, i.e without any
> electric/electronic protection circuits). It measures temperature, and
> responds to digital inputs with digital outputs, thru a transistor or
> relay.
> There are 2 variations:
> One is to install on car/motorcicles/trucks that includes a gps receiver
> and bluetooth transceiver, housed on an entirelly metalic case.
> The other is a fixed instalation powered by the mains thru an
> off-the-shelf power suply, meant to be installed on houses or on
> factories, that has a keyboard, an lcd, bluetooth, and optionally a serial
> port, and/or a video camera input, housed on a plastic case.
> Does the LVD apply? the supply input is specified as 10~40 VDC, which is
> bellow the 75V mentioned on the Low Voltage Directive.
> The modem manufacturer design guidelines state that "it is essencial the
> application power supply is designed to comply with the specification in
> section 3. This will be sufficient to pass type approval, no RF testing
> will be required if it meets these specifications"
> The bluetooth stack is developed in-house.
> Can we really avoid the RF tests?
> Sorry for the cross-post to sed but seec looks dead with only a couple of
> posts on the last week.
> Thanks in advance.
> Best Regards
> Steve Sousa
I'm also a bit of a newbie to CE, and am not a lwayer ... but ...
afaik you can mark anything as CE, but it's down to you to get sued if
someone gets injured/killed.
So although our stuff is used in an eng lab, within secure company sites, we
make a long document stating how we think all requirements are met, and what
reasoning behind that. So if anyone sues, we canpoint to it and say we
tried our best.
Some tests are performed to check emi/emc status. If the emc limits aren't
met we just warn the customer, who then waives it (nice huh).
Worth calling some expert who does it for a living, to check costs.
If you are in UK, then the guy I know is Ian Attoe on +44 (0)1634 844400
(big site, need to ask for him), who may or may not be able to help.
The costs of emc tests are bbbiiiggg though.
Probably help to use a separate (certified) power supply plugged in to your
unit, to avoid any worries on that side of things.
hth
Neil
| |
| Electric dabbler 2006-04-13, 3:21 pm |
|
"neil" <a@a.com> wrote in message
news:l6v%f.52770$wl.17310@text.news.blueyonder.co.uk...
> "Steve Sousa" <etsteve@yahoo.com> wrote in message
> news:443e1f6b$0$92471$892e0abb@auth.newsreader.octanews.com...
> I'm also a bit of a newbie to CE, and am not a lwayer ... but ...
> afaik you can mark anything as CE, but it's down to you to get sued if
> someone gets injured/killed.
> So although our stuff is used in an eng lab, within secure company sites,
> we make a long document stating how we think all requirements are met, and
> what reasoning behind that. So if anyone sues, we canpoint to it and say
> we tried our best.
> Some tests are performed to check emi/emc status. If the emc limits
> aren't met we just warn the customer, who then waives it (nice huh).
> Worth calling some expert who does it for a living, to check costs.
> If you are in UK, then the guy I know is Ian Attoe on +44 (0)1634 844400
> (big site, need to ask for him), who may or may not be able to help.
> The costs of emc tests are bbbiiiggg though.
> Probably help to use a separate (certified) power supply plugged in to
> your unit, to avoid any worries on that side of things.
> hth
> Neil
Hi Steve,
For electrical items used in vehicles there is separate approval called the
e-mark, I believe this applies only to items that are 'installed' into the
vehicle, either during manufacture or after market.
CE marking applies to other electrical devices, for instance a mobile phone
may be CE marked but a hands-free kit that needs to be installed into the
car's electrical system would be e-marked.
Hope I've not added to the confusion,
Philip
| |
| billb@abc.net 2006-04-13, 4:21 pm |
| If the product operates at below 50VAC or 75VDC it is outside the scope of
the Low Voltage Directive.
If this is the case it must meet the requirements of the General Product
Safety Directive.
The product will in both cases have to meet the requirements of the EMC
Directive.
For more information on the directives please have a look at the guidance
booklets on http://www.dti.gov.uk/strd/strdpubs.html
Regards
BillB
| |
| Roy L. Fuchs 2006-04-13, 5:21 pm |
| On Thu, 13 Apr 2006 18:25:12 GMT, billb@abc.net Gave us:
>If the product operates at below 50VAC or 75VDC it is outside the scope of
>the Low Voltage Directive.
>If this is the case it must meet the requirements of the General Product
>Safety Directive.
>The product will in both cases have to meet the requirements of the EMC
>Directive.
>
>For more information on the directives please have a look at the guidance
>booklets on http://www.dti.gov.uk/strd/strdpubs.html
>
Great link!
| |
| pooter 2006-04-13, 9:21 pm |
| neil [a@a.com] said
> I'm also a bit of a newbie to CE, and am not a lwayer ... but ...
> afaik you can mark anything as CE, but it's down to you to get sued if
> someone gets injured/killed.
You can only self-certify if you use standards that have been published
in the Official Journal (OJ) and comply with them in their entirety,
otherwise you need to produce a Technical Construction File (TCF) and
get it approved by a Competent Body.
> So although our stuff is used in an eng lab, within secure company sites, we
> make a long document stating how we think all requirements are met, and what
> reasoning behind that. So if anyone sues, we canpoint to it and say we
> tried our best.
It would actually be an issue, in the UK, for Trading Standards and they
would deal with you. In the first instance, they would probably just
stop you from selling until you fix the problem but this could stretch
to a product recall if they deem it appropriate. Either of these actions
could of course be quite sufficient to financially ruin a business.
Trading Standards will generally only prosecute as a last resort.
> Some tests are performed to check emi/emc status. If the emc limits aren't
> met we just warn the customer, who then waives it (nice huh).
Contractual arrangements with your customers do not revoke or replace
your liabilities under the law and if you are not complying with the
appropriate standards in their entirety then you need to produce a TCF
and get it approved by a Competent Body.
> Worth calling some expert who does it for a living, to check costs.
There are many views and opinions to be offered as to the appropriate
way forward for any given bit of kit so it is always worth getting a few
proposals and quotes.
I was recently looking to get a TCF put together and approved using the
railway standards (which are not published in the OJ) and a number of
different proposals were put forward with varying degrees of test and
analysis with costs ranging from £10,000 to £60,000.
> If you are in UK, then the guy I know is Ian Attoe on +44 (0)1634 844400
> (big site, need to ask for him), who may or may not be able to help.
Is this just someone you are suggesting for free advice as you do not
give this person any context? What is the company?
> The costs of emc tests are bbbiiiggg though.
Out of interest, there is no requirement to actually test although for
small, large volume items it is perhaps the most appropriate path. A TCF
route with analysis and some (or no) testing can be a much cheaper
option for large and/or low volume products even though it requires
specialist expertise.
> Probably help to use a separate (certified) power supply plugged in to your
> unit, to avoid any worries on that side of things.
> hth
> Neil
| |
| Paul E. Bennett 2006-04-14, 7:21 am |
| pooter wrote:
> neil [a@a.com] said
>
>
> You can only self-certify if you use standards that have been published
> in the Official Journal (OJ) and comply with them in their entirety,
> otherwise you need to produce a Technical Construction File (TCF) and
> get it approved by a Competent Body.
One should produce the TCF anyway as you may be called upon to produce it at
anytime. The notice period for its production isn't that long either. This
is whether or not a Competent Body examines the file.
>
> It would actually be an issue, in the UK, for Trading Standards and they
> would deal with you. In the first instance, they would probably just
> stop you from selling until you fix the problem but this could stretch
> to a product recall if they deem it appropriate. Either of these actions
> could of course be quite sufficient to financially ruin a business.
>
> Trading Standards will generally only prosecute as a last resort.
In an industry where we have to support a full, up to date, safety case we
view the document as the complete reference of arguments that can be used
in a court of law should any incident lead us there. In other words, it is
our entire defense case prepeared before we even have the consideration of
any trial. If your document is that good you have probably identified all
the risks you face and have dealt with them to minimise the your
liabilities (in law and financially).
>
> Contractual arrangements with your customers do not revoke or replace
> your liabilities under the law and if you are not complying with the
> appropriate standards in their entirety then you need to produce a TCF
> and get it approved by a Competent Body.
Any equipment that does not comply with the requirements of the EMC
directive are not permitted to be brought into service in the EU (with a
very few exceptions to do with research).
>
> There are many views and opinions to be offered as to the appropriate
> way forward for any given bit of kit so it is always worth getting a few
> proposals and quotes.
>
> I was recently looking to get a TCF put together and approved using the
> railway standards (which are not published in the OJ) and a number of
> different proposals were put forward with varying degrees of test and
> analysis with costs ranging from £10,000 to £60,000.
There are a number of links between the railway standards and standards that
are recognised by the EU official journal. It takes some time to explore
all the references. A published cross reference would, though, be useful.
[%X]
>
> Out of interest, there is no requirement to actually test although for
> small, large volume items it is perhaps the most appropriate path. A TCF
> route with analysis and some (or no) testing can be a much cheaper
> option for large and/or low volume products even though it requires
> specialist expertise.
If you, as a manufacturer or importer, are unsure of your ground seek the
best expert opinions you can afford to ensure that you comply with
legislation. Indications are that it is going to get tougher.
--
********************************************************************
Paul E. Bennett ....................<email://peb@amleth.demon.co.uk>
Forth based HIDECS Consultancy .....<http://www.amleth.demon.co.uk/>
Mob: +44 (0)7811-639972
Tel: +44 (0)1235-811095
Going Forth Safely ..... EBA. www.electric-boat-association.org.uk..
********************************************************************
| |
| hrhofmann@att.net 2006-04-14, 8:21 pm |
| That is a great site that I had not seen before.
H. R. (Bob) Hofmann - USA
| |
|
|
| Joerg 2006-04-22, 10:21 pm |
| Hello Steve,
> What other standards does it need to comply with?
> What about safety?
>
> The base product is small pcb with a cpu, a gsm modem, and a lithium-ion
> rechargeable batery (oem cell, not a pack, i.e without any
> electric/electronic protection circuits). It measures temperature, and
> responds to digital inputs with digital outputs, thru a transistor or
> relay.
>
> There are 2 variations:
>
> One is to install on car/motorcicles/trucks that includes a gps receiver
> and bluetooth transceiver, housed on an entirelly metalic case.
>
With this one you might have to be careful. If it becomes an integral
part of the vehicle, for example if mounted on the chassis and connected
to some vital parts of the vehicle, it might need a type certification
for that vehicle. Most European countries are stricter with this than
the regulations you find on other continents.
When I moved to the US I was amazed by the modifications people did to
their cars. In Europe they would have pulled me off the road for most of
that.
Regards, Joerg
http://www.analogconsultants.com
| |
| Jim Thompson 2006-04-22, 10:21 pm |
| On Sun, 23 Apr 2006 00:45:56 GMT, Joerg
<notthisjoergsch@removethispacbell.net> wrote:
>Hello Steve,
>
>
>
>With this one you might have to be careful. If it becomes an integral
>part of the vehicle, for example if mounted on the chassis and connected
>to some vital parts of the vehicle, it might need a type certification
>for that vehicle. Most European countries are stricter with this than
>the regulations you find on other continents.
>
>When I moved to the US I was amazed by the modifications people did to
>their cars. In Europe they would have pulled me off the road for most of
>that.
>
>Regards, Joerg
>
>http://www.analogconsultants.com
Around here we're commonly referred to as "FREE"!
All that is mandated here is "safety" equipment... basically the
brakes and steering, head and tail lights (and smog stuff) can't be
arbitrarily modified... everything else is free for the playing...
even neon lighting under the body and suspension systems that hop up
and down on command ;-)
...Jim Thompson
--
| James E.Thompson, P.E. | mens |
| Analog Innovations, Inc. | et |
| Analog/Mixed-Signal ASIC's and Discrete Systems | manus |
| Phoenix, Arizona Voice 480)460-2350 | |
| E-mail Address at Website Fax480)460-2142 | Brass Rat |
| http://www.analog-innovations.com | 1962 |
I love to cook with wine. Sometimes I even put it in the food.
| |
| Roy L. Fuchs 2006-04-22, 10:21 pm |
| On Sat, 22 Apr 2006 17:53:44 -0700, Jim Thompson
<To-Email-Use-The-Envelope-Icon@My-Web-Site.com> Gave us:
>On Sun, 23 Apr 2006 00:45:56 GMT, Joerg
><notthisjoergsch@removethispacbell.net> wrote:
>
>
>Around here we're commonly referred to as "FREE"!
>
>All that is mandated here is "safety" equipment... basically the
>brakes and steering, head and tail lights (and smog stuff) can't be
>arbitrarily modified... everything else is free for the playing...
>even neon lighting under the body and suspension systems that hop up
>and down on command ;-)
>
No longer legal in California. You can build them, but you can't
put them on the street any more here.
| |
| phil-news-nospam@ipal.net 2006-04-23, 2:21 am |
| In sci.engr.electrical.compliance Roy L. Fuchs <roylfuchs@urfargingicehole.org> wrote:
| No longer legal in California. You can build them, but you can't
| put them on the street any more here.
What do you expect from a socialist state? They are working on banning
incandescent lights, too, because they don't want power plants around.
California needs to be divided up into at least 3 or 4 states.
--
-----------------------------------------------------------------------------
| Phil Howard KA9WGN | http://linuxhomepage.com/ http://ham.org/ |
| (first name) at ipal.net | http://phil.ipal.org/ http://ka9wgn.ham.org/ |
-----------------------------------------------------------------------------
| |
| Roy L. Fuchs 2006-04-23, 9:21 am |
| On 23 Apr 2006 04:06:10 GMT, phil-news-nospam@ipal.net Gave us:
>In sci.engr.electrical.compliance Roy L. Fuchs <roylfuchs@urfargingicehole.org> wrote:
>
>| No longer legal in California. You can build them, but you can't
>| put them on the street any more here.
>
>What do you expect from a socialist state? They are working on banning
>incandescent lights, too, because they don't want power plants around.
>
>California needs to be divided up into at least 3 or 4 states.
You're a goddamned idiot.
| |
| Keith 2006-04-23, 12:21 pm |
| On Sun, 23 Apr 2006 04:06:10 +0000, phil-news-nospam wrote:
> In sci.engr.electrical.compliance Roy L. Fuchs <roylfuchs@urfargingicehole.org> wrote:
>
> | No longer legal in California. You can build them, but you can't
> | put them on the street any more here.
>
> What do you expect from a socialist state? They are working on banning
> incandescent lights, too, because they don't want power plants around.
>
> California needs to be divided up into at least 3 or 4 states.
....or given back to Mexico. They're working on it.
--
Keith
| |
| Roy L. Fuchs 2006-04-23, 4:21 pm |
| On Sun, 23 Apr 2006 10:31:26 -0400, Keith <krw@att.bizzzz> Gave us:
>
>...or given back to Mexico. They're working on it.
Fucking idiot. We PAID Mexico for it. It is ours. The jack-off
that think we stole it are utter fucking retards.
What they should be doing is giving us the Baja peninsula.
| |
|
| On Sun, 23 Apr 2006 18:37:19 +0000, Roy L. Fuchs wrote:
> On Sun, 23 Apr 2006 10:31:26 -0400, Keith <krw@att.bizzzz> Gave us:
>
>
> Fucking idiot. We PAID Mexico for it. It is ours. The jack-off
> that think we stole it are utter fucking retards.
We paid for Manhattan too, fuch-off and I'd prefer we give that back too.
> What they should be doing is giving us the Baja peninsula.
No, they're _taking_ the whole SW whether you like it or not, fuch-off.
--
Keith
| |
|
| Joerg wrote:
> Hello Steve,
>
>
>
> With this one you might have to be careful. If it becomes an integral
> part of the vehicle, for example if mounted on the chassis and connected
> to some vital parts of the vehicle, it might need a type certification
> for that vehicle. Most European countries are stricter with this than
> the regulations you find on other continents.
>
> When I moved to the US I was amazed by the modifications people did to
> their cars. In Europe they would have pulled me off the road for most of
> that.
>
> Regards, Joerg
>
I am afraid that it is a *lot* more serious than that Joerg.
Throughout the EU if *any* electrical apparatus is connected to the
electrical supply of a vehicle in any way it *must* be 'e' approved.
(eg if the charger of an electric toothbrush plugs into the cigarette
lighter socket it must be approved - the electrical apparatus does not
necessarily have to be fixed to the vehicle - just designed (or
promoted as being able) to be connectable to the vehicle supply).
The logic of this is to ensure that it cannot interfere with the
'normal' electrics/electronics (such as corrupting the EMU or disabling
the ABS etc etc)
It is not possible to self certify.
Approval awards the product an 'e' number issued by the certifying
authority.
This is a small 'e' confering compatability - not to be confused with a
capital 'E' approval which is a performance standard approval
applicable to certain automotive components/equipments.
Having said that the approval system and technical requirements are not
that onerous or expensive - so do not be put off.
| |
| Steve Sousa 2006-05-02, 12:21 pm |
|
"Electric dabbler" <no.spam@microsoft.com> wrote in message
news:YbCdnZyREJRnDaPZRVnyvQ@bt.com...
> Hi Steve,
Hi:
> For electrical items used in vehicles there is separate approval
> called the e-mark, I believe this applies only to items that are
> 'installed' into the vehicle, either during manufacture or after
> market.
I came across this on my search, and from what i gathered it definitely
has to be e-marked.
> Hope I've not added to the confusion,
Your help is apreciated
Best Regards
Steve Sousa
| |
| Steve Sousa 2006-05-02, 12:21 pm |
|
<billb@abc.net> wrote in message
news:cIw%f.41887$g76.8503@newsfe2-gui.ntli.net...
> If the product operates at below 50VAC or 75VDC it is outside the
> scope of
> the Low Voltage Directive.
> If this is the case it must meet the requirements of the General
> Product
> Safety Directive.
> The product will in both cases have to meet the requirements of the
> EMC
> Directive.
>
> For more information on the directives please have a look at the
> guidance
> booklets on http://www.dti.gov.uk/strd/strdpubs.html
>
> Regards
>
> BillB
Thank you, that a very good link.
Best Regards
Steve Sousa
| |
| charlieB 2006-06-01, 10:21 am |
| >One is to install on car/motorcicles/trucks that includes a gps receiver
>and bluetooth transceiver, housed on an entirelly metalic case.
going in a car -as others have said - this will have to be e-marked,
which is a non-trival exercise
>The other is a fixed instalation powered by the mains thru an
>off-the-shelf power suply, meant to be installed on houses or on
>factories, that has a keyboard, an lcd, bluetooth, and optionally a
>serial port, and/or a video camera input, housed on a plastic case.
>Does the LVD apply? the supply input is specified as 10~40 VDC, which is
>bellow the 75V mentioned on the Low Voltage Directive.
there is bluetooth in the device - therefore is falls under the R&TTE
directive - this covers requirements for:
EMC emissions and immunity
Radio spectrum usage - the fact that you are using a 3rd party
bluetooth device will save you from bluetooth qualification testing,
but not spectrum performance radio testing
Safety - the R&TTE directive applies the LVD without the lower voltage
limit.
Also "fixed installation" is ringing some alarm bells - various CE
marking directives have slightly differing requirements on fixed
installations, and the requirements are different to units placed onto
the market to be installed by the user.
I do this for a living, so drop me an email if you'd like more info
Charlie
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