CE marking compliance

[ruffrecords]

I believe it is, but if asked, you will need to be able to support that declaration with a Technical FIle.

Cheers

Ian

 

[[silent:arts]]

You may just look at comparable products declaration.
Attached one from a 19" Audio Processor with Mains IEC and linear PSU.

 

[ruffrecords]

Here is a proforma declaration;

http://www.conformance.co.uk/info/Resources/dofc_sample.pdf

and another:

https://www.chemyx.com/wp-content/uploads/2016/07/Chemyx_-_EU_Declaration_of_Conformity_2016.pdf

Cheers

Ian

 

[Brian Roth]

Egads....tis always amazing to see the bureaucrats in action as they erode our freedom.

I guess the next directive will be compliance that all the bathrooms at the factory are acceptable to transgender people. 

Not that I give a flying flip about who is in the bathroom...just the fact that there are now specific rules and regs about sooooooooooooooo many "who cares?" issues.

Next thing I know, there will be rules issued about how well I care for my two pets....bobbing birds who drink water from a coffee cup on top of my ice box.

http://www.tintoyarcade.com/original-drinking-bird-scientific-toy.html?language=en&currency=USD&gclid=CP3y2czu284CFQuMaQod-b4PeQ



Bri

 

[gyraf]

..just the fact that there are now specific rules and regs about sooooooooooooooo many "who cares?" issues.

This is the simple result of lobbyism having proportionally too much power under a technocratic rule.

Jakob E.

 

[JAY X]

Hi!

After searching and reading a lot... Self certification, asks for a construction technical file. The hard part is making the measurements that demonstrate compliment with the directives. Those measurements seems that only can be performed at a laboratory... to test EMC radiation, PSu security , etc.. and this costs money!! ... unless there is another way...

So, in short: To place an Audio product in  the market you can use the self certification way: User manual/Technical file & tests/ Declaration of conformity & CE marking.

 

[ruffrecords]

Hi!

After searching and reading a lot... Self certification, asks for a construction technical file. The hard part is making the measurements that demonstrate compliment with the directives. Those measurements seems that only can be performed at a laboratory... to test EMC radiation, PSu security , etc.. and this costs money!! ... unless there is another way...

So, in short: To place an Audio product in  the market you can use the self certification way: User manual/Technical file & tests/ Declaration of conformity & CE marking.

This is a complex subject. A lot depends on the total value of the production run. If you are making thousands of a product then the per unit cost of paying for the necessary tests is relatively small. If you are making one or a small number of devices the cost is prohibitive unless each product is sold for many thousands of pounds/dollars. This is typical of all such legislation including UL and FCC for the US.

In the EU, the central reason for harmonisation of standards is to promote the free movement of goods by obviating the need to meet the separate standars of each an every country you want to sell to. Harmonisation also extends quite well to the US and much of the rest of the world. This most definitely was not the case when I began designing  products back in the 70s and obtaining approvals for each country was a positive nightmare.

Despite this, there is still a considerable bias towards big businesses that sell large quantity or large value items and can afford the  full set of approvals tests. Self certification was, I believe , intended as a way to allow smaller businesses to access the market without the expense.

Having said that, you will surely want to test your product to make sure it is safe - which means it will not kill or harm people. So it must be electrically safe, it must not get too hot or burst into flames nor emit harmful radiatiion. Most of these tests you can do quite easily with normal test equipment with the addition of what is called in the UK, a PAT tester for mains electrical safety. The only prblem is the harmful radiation but as long as you don't have lasers or gamma ray sources you are usually exempt from this requirement. This is an important point - the EU requires only that you comply with the relevant portions of the applicable standards. Actually this is not quite true. You only need to comply with the directive, If you comply with the relevant standards then that is accepted as sufficient to comply with the directive but it is not the sole way to comply (unless that has changed in the recent updates). Most of the rest of safety compliance is simple good engineering practice; proper earthing of exposed metal and use of approved components like transformers, sonnecting wires, fuses and connectors. This will be part of your normal design documentation and can go in your techical file as demonstration of compliance.

EMC can be much more difficult. For pure analogue devices with linear power supplies you have little to worry about and you should be able to claim exception from emitted radiation tests. You might need to make conducted tests but you can build a conducted interference tester quite cheaply.  For digital kit with oscilators running at megahertz there is really no avaoiding testing by someone with the right (expensive) gear.

In  the EU your device also needs to be shown not to be susceptible to outside interference. For most audio devices this is not a problem because the susceptibilty  is defined in terms of how the unit continues to perfom or not in the presence of inteference and in analogue gear you might get noise or hum or blocking but the unit will be finewhen the interference is removed. For digital stuff you need to be sure it does not lock up.

There is a lot more I could say but I am running out of steam!

Cheers

Ian

 

[neil.johnson]

Hi,

Long time listener, first time poster.  Interesting thread (I used to be an EMC engineer in a former life...)

Following on from Ian's post I would strongly suggest to anyone putting anything onto the market to at least get hold of (beg, borrow, phone a friend, etc) an RF spectrum analyser and to check that their analogue circuit is not radiating any unintentional HF, for example a video op-amp that is merrily humming away at several hundred kHz because the designer forgot to tame the gain.  I keep an old HP spectrum analyser and some home-made sniffer probes just for this kind of test.

HF emissions is one of the reasons I keep an original 8-transistor (and one diode!) Roberts Rambler in my home lab.  That, and the shipping forecast...

Neil

 

[ruffrecords]

Agreed, you do not need a spectrum analyser to pick up radiated emissions. All you need to know is if they are there or (prefeably) not and a radio receiver, long, medium and VHF will usually be sufficient.

Cheers

Ian

 

[Iskrem]

Hi,
I stumbled upon this page some time ago..
http://emctestinguk.co.uk/
Anyone have any experience with them? Too good/cheap to be true? (EMC testing from £390 + VAT)

Lars

 

[ruffrecords]

Hi,
I stumbled upon this page some time ago..
http://emctestinguk.co.uk/
Anyone have any experience with them? Too good/cheap to be true? (EMC testing from £390 + VAT)

Lars

I guess there is a clue in the 'from £390'. The simplest EMC test you can do is a conducted emissions test and it will take less than an hour to set up and run. £390 just for that would not be cheap. However if they did that, a radiated emissions test and a susceptibilty test (the three maisn EMC tests) for £390 that would be good value.


Cheers

Ian

 

[FETlife]

On a related note, does anyone know where we stand with the FCC and selling from the EU to individuals in the US? 

The FCC Declaration of Conformity[1] or the FCC label or the FCC mark is a certification mark employed on electronic products manufactured or sold in the United States which certifies that the electromagnetic interference from the device is under limits approved by the Federal Communications Commission

Since I'm neither manufacturing nor selling in the US, it would seem I don't need to worry about it...But that just seems too simple to be true!

 

[andre tchmil]

interesting reading.
What if you put in some commercial available SMPS with CE approved stamp on it ?
I mean, if you use use quality parts like IEC mains sockets and respect the basic safety rules, what can go wrong ?
I have seen far worse commercial available equipment with and without CE labeling.
What about the boutique shops that repair 70 year old guitar amps, how do they deal with safety regulations when they hand back the invoiced equipment ?
This is all a big grey zone to me.

 

[ruffrecords]

interesting reading.
What if you put in some commercial available SMPS with CE approved stamp on it ?
I mean, if you use use quality parts like IEC mains sockets and respect the basic safety rules, what can go wrong ?
I have seen far worse commercial available equipment with and without CE labeling.
What about the boutique shops that repair 70 year old guitar amps, how do they deal with safety regulations when they hand back the invoiced equipment ?
This is all a big grey zone to me.

I am not a business but I make one off mixers for people. I use CE/UL/FCC approved SMPS for heaters and a CE/UL approved transformer for the HT supply. I also use an approved IEC inlet with built in filter. Then provided you get the grounding right you should be OK. To verify this I carry out a safety check using an approved PAT tester. Ths checks ground continuity to exposed metal parts and earth leakage. I can then attach an official PAT sticker to prove it has been tested because I am more concerned for my customers safety than causing a little interference.

Cheers

Ian

 

[Newmarket]

interesting reading.
What if you put in some commercial available SMPS with CE approved stamp on it ?
I mean, if you use use quality parts like IEC mains sockets and respect the basic safety rules, what can go wrong ?

Basic CE 'rule' is "CE + CE does NOT equal CE". In concept the certification applies to the whole system.
Additionally, only 'stand alone' products can legally best a CE mark. eg your standard type of SMPSU for chassis mounting should not be CE marked. Although it might be stated that it meets the same technical standards as used for particular EMC product standards.

 

[warpie]

I am not a business but I make one off mixers for people. I use CE/UL/FCC approved SMPS for heaters and a CE/UL approved transformer for the HT supply. I also use an approved IEC inlet with built in filter. Then provided you get the grounding right you should be OK. To verify this I carry out a safety check using an approved PAT tester. Ths checks ground continuity to exposed metal parts and earth leakage. I can then attach an official PAT sticker to prove it has been tested because I am more concerned for my customers safety than causing a little interference.

Cheers

Ian

Do you have your own PAT tester or you rent one? I wasn't aware of PAT testers. It might be a good idea to own one even for the diy stuff.

 

[ruffrecords]

Do you have your own PAT tester or you rent one? I wasn't aware of PAT testers. It might be a good idea to own one even for the diy stuff.

I own my own one. Mine is made by First Stop Safety

I have their Memory PAT

Cheers

Ian

 

[ccaudle]

I own my own one. Mine is made by First Stop Safety

I have their Memory PAT

I was not familiar with the term PAT, do you know if there is a different term used commonly in North America for the same thing? I know when I was designing commercial equipment we had a final factory hi-pot test which applied a high common mode voltage and measured leakage current to verify insulation integrity. Is that basically the same thing the PAT checks?

 

[ruffrecords]

I was not familiar with the term PAT, do you know if there is a different term used commonly in North America for the same thing? I know when I was designing commercial equipment we had a final factory hi-pot test which applied a high common mode voltage and measured leakage current to verify insulation integrity. Is that basically the same thing the PAT checks?

Yes. PAT stands for portable appliance test. It is two basic tests. One is leakage exactly as you describe. The other is a continuity check between mains earth and exposed metalwork.

It is used mostly in industry to carry out an annual check on the safety of office equipment like PCs, kettles and so on.

Cheers

Ian

 

[Newmarket]

Yes. PAT stands for portable appliance test. It is two basic tests. One is leakage exactly as you describe. The other is a continuity check between mains earth and exposed metalwork.

It is used mostly in industry to carry out an annual check on the safety of office equipment like PCs, kettles and so on.

Cheers

Ian

Just add that PAT testing also includes visual/manual checks.eg product casings not damaged/cracked; power cable jackets not damaged/ nicked, mains plugs correctly fitted etc.
I guess we've all seen kit where the cable grip is gripping only the inner cores rather than the outer insulation. Also correct mains fuse in plug where applicable.