Safety issues and CE Certification

[TomMcLeod]

send me a mail if you need further assistance regarding compliance testing and UL/CE marks. Happy to help.

Sent from a beardy guy with no clue

 

[druidaudio]

We know that in order to get CE and FCC marks we need a lot of money out of our capabilities. In particular, UL/CSA/VDE certifications requires an outside company testing our products for compliance to their respective standards while CE declaration can also be self declaration if we declare that our product meets requirements set by the appropriate directives. In this case, the CE compliance is the sole responsibility of our company.

You are correct, CE compliance is your responsibility

In particular, we have to meets two main directives in order to get CE self declaration mark: Low Voltage Directive (LVD) Directive 2014/35/EU and Radio and Telecommunications Terminal Equipment Directive (RTTE) Directive 2014/53/EU. For the former, all we need is to purchase a pre-approved (CE marked and compliant) external AC-DC power supply and ship it with our product. So it is relatively simply to solve.

Good to see you are quoting the latest Directives, which will come into force on 20th April 2016, but cannot be used before then. Your suggestion of using a pre-approved PSU is a good one, especially if it is of the plug into wall socket type, but if you have to add mains wiring, sockets or fuses you will have to do some safety assessments to cover these aspects. In addition, R&TTE (soon to become Radio Equipment Directive RED) means that any radio (bluetooth wifi) modules must be fully approved and documentation will be required to prove this.

Regarding the latter directive we cannot afford measurements from external lab. All the electronics board that we use are CE marked. We know that this not guarantee that the whole product respects all the requirements of the directive. So we have to make measurement in our lab and to produce the corresponding documentation. We think that we do not require a Notified Body since the directive states: when the manufacturer did not use Harmonised Standards, or when these do not exist, it must present its technical file to a Notified Body, which will review it.
Do you think that we need a Notified Body?
Do you have any suggestions about how to proceed in order to meet all the requirements?

The old adage is CE+CE does not equal CE, it is good to get all CE approved parts and please bear in mind that RoHS is now part of the CE marking process, so ALL of your components must be RoHS compliant and you should collect all the certification for this.
If you are using CE marked boards, PSUs etc you should gather ALL the relevant safety EMC and RoHS documentation you can.
EMC testing is not cheap, this is because the labs are very expensive to set up and maintain, but I would recommend some testing to ensure that none of your circuits are combining in any way to produce unwanted emissions.
You can indeed self declare compliance to CE certification, remember that you will have to sign a Declaration of Conformity for your product and that makes you personally as well as corporately liable.
I am not touting for business here, but I help people with product approvals for a living, see link below for info on the new directives;

New Directives on the way! 2014/53/EU, 2014/35/EU and 2014/30/EU - Gainspeed

 

[AndrewT]

Druid,
would you like to reveal a bit more about yourself in your profile?

 

[spartan]

Hi all,

I have a buyer in Europe interested in a tube amp I'm selling that has no CE marking. The amp is used and this is a private transaction. Can they create any trouble at customs?

 

[BudP]

Yes they can and depending on which agency is handling the CE process in the country of interest they will or they may or who knows. You might investigate if gifts are still allowed an uncleared entry, but if the amp was made before CE certification was introduced it is likely they will not want it in the EU.

 

[BudP]

Thanks for the heaads up Druid, I have been away too long it would appear. I only need worry about linear transformers though and so as long as we follow either the UL 4mm/4mm or the old CE 6mm/3mm creepage and clearance along with ROHS materials it looks like we can still export to the EU. Of course our new president could manage to add some unintended roadblocks...