Legailities of Selling into Europe / CE Compliance

Hey guys, don't know if this is the right place for this but seemed the most appropriate place.

I'm hoping someone might be able to shed some light on the legalities of selling into Europe and CE compliance for 500 series modules.  I know there are some forum members who have/do sell finished units, but not sure who stateside might be selling into Europe or if anyone can share what they know or thier experiences.

From what I understand, anything electronics that is sold into Europe must have a CE compliance sticker, does this apply to 500 modules as well (since they are not self powered?)  Would this apply even if it was a personal DIY unit?

As far as I know, I can self certify an item as long as I can verify it complies, since 500 modules are below 50V I know they would fall in the "low voltage directive", but for the life of me I have been unable to find a clear outline of exactly what the critera that must be adhered to is.  As big a deal as CE is, seems like they make the details pretty hard to find (or maybe I just didn't google enough).

Thanks.

from the Elysia XPressor 500 Manual:

CE Conformity
elysia GmbH, Ringstraße 82, 41334 Nettetal, Germa-
ny, declares with sole responsibility that this product
complies with the following norms and directives:
• 2006/95/EG Low Voltage Directive (formerly 73/23/EWG or 93/68/EWG)
• 89/336/EWG EMC (Electromagnetic Compatibility) Directive
• DIN EN 55103-1 EMC of audio equipment - Emission
• DIN EN 55103-2 EMC of audio equipment - Immunity

It is basically the same as UL and FCC compliance which I assume you already do. The only thing is the specs are a little different but for the last 20 years of so there has been a harmonisation process with the aim of making European and US/Canadian specifications highly compatible.

In the US you submit your unit to a UL/FCC test house and use their test results as the basis of certification. You do exactly the same thing in Europe. In Europe we have test houses that are certified to test to UL/FCC etc specs as well as European ones. I am sure you have test houses in the US that can test to European specs.

Cheers

Ian

Not really. I don't know anyone in germany doing the CE certification outhouse.
It is just: too expensive.

CE certification means: you sign for the compatibility (and you are responsible for this).
You sign for the needed standards - thus a valid question asked for which standards for a non self powered 500 / 51X module.

I'm not an expert on this, but I think Elysia know what they are doing, and they reference the standards they use.

CE is a declaration, not a certification - you are declaring that your product meets requirements set forth in the appropriate directives. UL/CSA/VDE are certifications, with an outside company testing your products for compliance to their respective standards.

The Directives are laws enacted in EU countries that harmonize safety and other standards throughout the union. The Standards are drafted by various committees to instruct manufacturers on how to construct and test products for compliance to the directives.

Yes, your modules need to be marked for both CE and WEEE (trash can with slash through it). I am pretty sure that, technically, kits would need to be marked as well but I have never seen it.

There are published standard books that you purchase and basically follow the steps for testing and marking. You compile a technical file as you go.

I would think your safety standard is going to be the usual  EN 60065, that's the audio/video standard with immunity EN55103-2, and emmision EN55103-1.

A 500-series module should be cake compared to something powered off the wall, or if it had microprocessors or switcher in it. Immunity and emmision is nearly impossible to test on your own and is expensive to have done.

The published stadards are expensive to purchase and not published online. I bet you have a compliance officer at work, and he may have the standard (or access to it) and can save you 400 bucks.

Search Amazon as well as there are many how-to books on testing for compliance.

M.

Crusty2 said:

CE is a declaration, not a certification - you are declaring that your product meets requirements set forth in the appropriate directives. UL/CSA/VDE are certifications, with an outside company testing your products for compliance to their respective standards.

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yes, thanks for clearing this up.

the standards are free on the web while the DIN writings are expensive.

The DIN (and AES) information is usually to be found at the libraries at technical/engineering schools

Jakob E.

Thanks guys.  After 3 days of googling and talking to various engineers/quality guys at my office I'm still at a loss here.  As far as testing/certification here in the states, it's pretty much a joke.  No formal certification is required for a low voltage device like a 500 module, so self certifying it is a piece of cake.

As far as CE, I can't find a shred of mention about it by any manufacturer besides Elysia, and they're EU based, so no surprise there.  But none of the US manufacturers (not even API) mention it anywhere whatsoever.  So what are those guys doing?  Anyone have any US mfg based 500 modules?  There a CE sticker on em?  This still seems like a very gray area to me because it's passing the buck onto the 500 rack itself.

And again, I have to wonder, if I build a unit that is not CE certified, and somebody from the EU purchases it knowing this, and it is shipped from the US direct to them, what can be done to stop that?  Is it breaking any laws by me shipping it?  I'm not saying I'm going to do this, I'm just trying to understand how this kind of stuff is even inforced.  It's not like I'm setting up shop there.

Kits I don't see how/why they would fall under CE ruling.  It's merely a bag of parts, what the end user decides to do with those parts is up to them.

Seems kind of silly that (Volker), you could sell me a 51X rack kit, I could build it here, but I'm not allowed to send it back to you.  Seems like a rather uneven playing field, but I guess that's a different discussion entirely.

Far as I can tell, only safe bet would be to self certify it, I have the DIN's here so that's not an issue.  Formal testing is many thousands of dollars per item, so it's not even an option.  Self EMC testing seems the tricky part, not sure where to even begin with that.

I just looked at my API Lunchbox and their L200 Rack - both don't have a CE sticker on it ...

OK, the L200 is a "passive part", but I have a CE sign on each of my daughters playmobil toys (which is passive too, isn't it ;D)

Once I worked in a company selling 19" enclosures for Apple computer.
It was expensive doing the CE certification outhouse.
It was a passive metal enclosure ...
But hey, CE was new that time, and nobody knew if it needs to be done etc.
Today I just would put the sticker on it.

If you don't plan to sell millions of your units think like a Punk ;D
I do. If you sell me a unit without CE sign I don't mind.
But if I would I could I bring you to court?
You are in the US, I'm in the EU - this would be an expensive law case.
And you didn't brake any law in your country.
If there are complains just take it back and refund the money.

However, stuff like this (and there are even more regulations / yearly changing regulations) kills small business. One reason I still have no store online.

I pay around EUR 120 each month for a woman doing at least the tax and book holding for 51xAudio right.
I would need an attorney to check (and regular recheck) the terms of conditions etc in an online store.

If I would do this all on my own I even wouldn't have the time to pack and ship the sales.
Or develop new projects.
One way would be to outsource all this stuff, but my guess would be three time higher sales prices.

Funny system.
Stupid system.
Rant over.

ruckus328 said:

As far as CE, I can't find a shred of mention about it by any manufacturer besides Elysia, and they're EU based, so no surprise there.  But none of the US manufacturers (not even API) mention it anywhere whatsoever.  So what are those guys doing?  Anyone have any US mfg based 500 modules?  There a CE sticker on em?  This still seems like a very gray area to me because it's passing the buck onto the 500 rack itself.

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the sticker or CE mark is not utterly necessary, in particular if there is not a sufficient area on the unit to put it on. the CE mark is supposed to be on the rear panel, but on a 500 module, you don't have a rear panel. The frame, however, should bear the CE mark, even if it's passive, because the WHOLE SYSTEM and ALL POSSIBLE COMBINATIONS should be certified. Anyway, for many units (USB drives, guitar tuners, watches...), it is accepted that only the user manual has the CE mark.

And again, I have to wonder, if I build a unit that is not CE certified, and somebody from the EU purchases it knowing this, and it is shipped from the US direct to them, what can be done to stop that?  Is it breaking any laws by me shipping it?  I'm not saying I'm going to do this, I'm just trying to understand how this kind of stuff is even inforced.  It's not like I'm setting up shop there.

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You're absolutely right, as long as your deal can be considered as a private transaction. Worst case, if someone built a unit that creates large RFI, the unit could be confiscated - most likely, he would be asked to turn it off.

Kits I don't see how/why they would fall under CE ruling.  It's merely a bag of parts, what the end user decides to do with those parts is up to them.

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This is debatable. A kit with instructions is meant to become a specific unit; if this unit does not conform (and again who would enforce the regulations?) the company distributing it (the importer) would be liable. The thing is that it's the customs who are concerned there, so the company/person who imports the kits must produce the relevant certificates.
I had to produce CE certificates for passive headphone mult boxes, because it was easier for the importers than having to explain to the customs that the CE marking was not needed. In fact even for public tenders, the CE certificates are very often requested.

Far as I can tell, only safe bet would be to self certify it, I have the DIN's here so that's not an issue.  Formal testing is many thousands of dollars per item, so it's not even an option.  Self EMC testing seems the tricky part, not sure where to even begin with that.

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You may have only EMC done by a lab, but if you have no RF, SMPS or microcontroller in the unit, you can do without testing. Regarding PSU's, many manufacturers have chosen to test a limited number of units, each one typical of a range; in my former company, we had only 3 units tested, one with a 15VA PSU typical of 1RU units), one with a 30VA (typical of 2U units) and one with an 80VA.

ruckus328 said:

And again, I have to wonder, if I build a unit that is not CE certified, and somebody from the EU purchases it knowing this, and it is shipped from the US direct to them, what can be done to stop that?  Is it breaking any laws by me shipping it?  I'm not saying I'm going to do this, I'm just trying to understand how this kind of stuff is even inforced.  It's not like I'm setting up shop there.

Click to expand...

The way it was explained to me years ago was that yes, a private transaction is perfectly legal. You are not placing your product in the European market; someone is purchasing from you and importing it for personal use. But...

It is not a CE-compliant product, and so it is illegal for the purchaser to resell it to someone in the EU.

Also since it hasn't been CE - marked, it is only legal for personal use. It cannot be used professionally or where the general public would have interaction.access to it. This includes, commercial studios, clubs, houses of worship, and so on.

Not usre why silent-arts boxes aren't marked, but here's a shot of the API PSU with its CE mark:

http://www.apiaudio.com/cl200ps.html

The lunchbox has one too...

Crusty2 said:

Not usre why silent-arts boxes aren't marked

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all boxes I have built are marked (and some are even EMC tested  8))
I write a CE declaration if I sell a finished product or do a custom job (which isn't often)

but I can't write one for PCBs or kits.
if someone builds it wrong it might fail some or all tests 
dangerous

I was referring to your API gear:

[silent:arts] said:

I just looked at my API Lunchbox and their L200 Rack - both don't have a CE sticker on it ...

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It would seem reasonable to me that if a kit of a CE-compliant product were assembled as per the provided instructions, the finished product would be considered CE-compliant. Yes?

Crusty2 said:

It would seem reasonable to me that if a kit of a CE-compliant product were assembled as per the provided instructions, the finished product would be considered CE-compliant. Yes?

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The CE compliance is the sole responsibility of the manufacturer. With a kit this compliance can not be garanteed by the manufacturer so the assembled kit can not bare the CE marking (basically your just selling parts). So if you want to sell the assembled kits (commercially) in the EU you would have to test the finished product (could be done by yourself) and fill out all the needed documents. Moreover those documents need to be present in the EU held by a authorised representative. And i'm not even talking about the implications of selling someone else's kit as your own only now assembled (commercially off course).

with 500 modules i have no clue ... i've even seen guitar pedals with a CE marking so and the low voltage directive states that it applies to anything from 50Vac to 1000Vac and 75Vdc to 1500Vdc. (probably emc testing or just safety stuff)

I'm no expert but i believe this is true. Recently (like just before this thread started, talk about reading my mind) i've been researching this heavily. I don't have a product that i want to release but i am thinking about it and i find it enormously interesting (although it does hurt my brain)...

greetings,

Thomas

(back to playing team fortress II  ;D )

Crusty2 said:

It would seem reasonable to me that if a kit of a CE-compliant product were assembled as per the provided instructions, the finished product would be considered CE-compliant. Yes?

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No!

hobiesound brought it to the point.

another view: there was (sometimes still is) a time german broadcast only used RBT proofed equipment.
they checked every module, and later came in to check the whole installation / studio.
space issues made them creative to put their label where ever was a place for it.
in V672 cards mostly a transformer. the sticker is for the whole card.
now tell me, is the Jensamp card showed [url0http://www.groupdiy.com/index.php?topic=45341.msg569269#msg569269]here[/url] proofed by RBT?

I haven't seen any electronic PART with a CE sign yet. not even Haufe or Pikatron transformers.
it is part of the end-manufacture OR re-seller of a product to provide CE compliance.

Yeah that makes sense, there is no manufacturing control in the end. I guess kits will always be "punk"...

[silent:arts] said:

I haven't seen any electronic PART with a CE sign yet. not even Haufe or Pikatron transformers.
it is part of the end-manufacture OR re-seller of a product to provide CE compliance.

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Really? I see plenty of CE marks on parts, and every transformer I have (aside from antek) has CE marks on them...

Can we turn this one around? If I am a European wanting to sell a 500 module into the USA do I need to meet any specs?

Cheers

Ian

ruffrecords said:

Can we turn this one around? If I am a European wanting to sell a 500 module into the USA do I need to meet any specs?

Cheers

Ian

Click to expand...

UL compliance? yuuurgh.

The '500 modules are part of a kit though.

With my employer, we've been able to get around some of the CE/UL games by suggesting that our evaluation boards are not a finished, complete product suitable for consumer use. A customer purchasing an eval board must put extra work in themselves to make a complete working product.

For example, take a look at: http://focus.ti.com/docs/toolsw/folders/print/rdk-value-sb.html

Everything comes in the package, other than speaker cables and speakers. We included a 24V 2.5A DC power supply too. (that was already certified).

I initially wanted to include some cables and speakers, but the powers that be said that as a complete product, we'd need all the wonderful certification.

I suspect that '500 modules would be quite similar.

/R

ruffrecords said:

Can we turn this one around? If I am a European wanting to sell a 500 module into the USA do I need to meet any specs?

Cheers

Ian

Click to expand...

Nothing to do; sell away.