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Originally Posted by Melanie
NO, Here Malanie is bending the rules.
Yes "If your product meets ANY Directive, you are entitled to stick a CE mark on it and certify saying so"
BUT you are required to test to standards that are relevant to the use of the product, so you can't do as Melanie suggested AND stay legal.
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The part that hurts the most
When Melanie said:
This in itself wouldn't "officially" be enough. How can you say something meets the standard if you don't have an actual copy of the standard?
Even Lester says "just read the legislation, it's not difficult".
Here is the problem with the whole system. They "SELL" the standards. They aren't free to download for review. It really makes it hard on the small entrepreneur to get a product into Europe. Some of them aren't cheap either. I'm in the laser safety business and IEC 60825 alone has 15 parts which cost ~$65 each. On top of that I need the machinery directive, the low voltage directive, the EMC directive, and most likely something else I've never thought of.
I guess paying for a testing house to tell you that your product meets the standards is worth the $6k to $12k.
In the end, I think Europe loses out on some innovative products because people are afraid to introduce something new. At the very least, movement of products into Europe is delayed because of the added bureaucracy.
They say it will take something like 20 years to get back to where we can put a man on the moon. It's hard to believe we once did it in 8. It all boils down to bureauracy.
John
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John I ahve to agree with your sentiments. Right now the bureaucracy in the EC is at a crzy level and does not look like its going to ease.
Yes its sensible to have harmonisation of standards, but when it's implimented as it is right now, it is simply restrictive.
Maybe thats why we have so many poeple working in software and so few in hardware and firmware.
AND, with so much legislation that is both costly and difficult to identify, its easy to see why we end up with "the blind leading the blind" which ultimately defeats the very purpose of the legislation.
However it works both ways, I find it really difficult to find a route to FCC Type approval that does not cost over 3 times as much as EMC testing and CE marking!
Incidentally, there is one supplier over here in the UK, that has a rather novel approach in sales incentives. They have their own EMC test facility and if you use parts supplied by them in your design, they will allow you to use their test facility for free. They have a qualified engineer on hand to assist.
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A note aside:
We have witnessed here that a lot of Chinese suppliers have been providing "CE" and all kinds of other documents to their customers at sampling stage.
When the customer(s) tests and approves the samples, they place the order as they have the documents provided by the supplier.
However, what the suppliers ship are not the same quality as the samples they had provided.
In order for this kind of supplier to get the approval for CE and other types of standards, they make a real good samples and submit these good samples to the testing labs. The samples pass and get the approval.
When the customer receives the shipment, the products are still good and do the job with no problem at customer's side. But if you submit a sample from this shipped lot to the labs, it will not pass.
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"If the Earth were a single state, Istanbul would be its capital." Napoleon Bonaparte
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Lester, could you expand on this please
Thanks
Keith
www.diyha.co.uk
www.kat5.tv
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To sum it all up . . .
Hi, this is GaryAviation. Thanks to all of you who have provided a post since last Spring. Please allow me to provide you folks with an update on my company’s progress with “CE” certification.
We hired a professional firm here in the US to evaluate and test our product to meet the required CE standards. Based on their evaluation of our product and their recommendation of the EMC standard; we tested and certified our product to the EMC standard and our product passed. Great. We then “Self-Certified”. Great.
Then one of our customers challenged our certification (one of over a 100) by saying that we need the LVD standard. None of our other customers had a problem with what we did. To make a long story short, we went back to the professional firm we hired and asked why they did not recommend the LVD the first time around?? They answered that “Anyone in the UK can challenge your CE certification. They can also demand that you test to any standard that they think is relevant.”
Folks, please excuse me, but this is a big pile of crap! In a nutshell (and I use that term for several reasons – this whole thing is NUTS), it seems to me that, as a user of the CE self-certification, there are several issues that need addressing. Allow me to explain.
1. The intent of the CE certification seems to me to be a great idea. HOWEVER . . .
2. The application of the CE certification is best described as follows: “An idea someone thought up and then never though through.”
3. I have done a lot of research on this subject since my first post last Spring. To date, I have not found two people that agree on any relevant information or guidance concerning this CE certification program. Everyone has their own idea of what to do when and how. One person says certify my equipment to “Choking hazard for small children” and another person says certify to “LVD”.
4. The main problem here is that nobody in the CE certification body, OFCOM or the League of Extraordinary Gentlemen (whatever they want to call themselves) has taken the time to think out the certification process. What needs to be tested to what standard is harder to figure out than the 9,955th digit in the answer of Pi. Sorry, Lester – with all due respect – I have read the legislation and (true it is easy reading) but it is also full of ambiguity. There is no clear guidance that the average man or woman could make a decision on.
5. I totally agree with the post from “Hansknec” who basically stated that you could spend thousands of $$ of standards and 10 of thousands of $$ of testing and not even be sure that you have tested to the right standard.
6. To sum it up – CE certification is a GREAT program in theory. In practice – Good Luck! ! ! ! !
Once again – seriously, thanks to everyone who has provided their insight on this project of mine.
Last edited by GaryAviation; - 18th December 2006 at 14:28.
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To GaryAviation,
So one of over one hundred customers is challenging your certification? Does this halt your sales or can you simply tell this one customer to take a hike? Losing <1% of your customers doesn't seem too bad, or is this process of filing a complaint more formal?
A more generic question perhaps someone can answer: I have interpreted the Low Voltage Directive in such a way that it is my understanding that a device powered by an external 24VDC Wall Wart power supply would NOT fall under the directive. The device does not accept or provide any voltages higher than 24VDC. The Wall Wart is CE certified and of course would plug into the mains.
Thanks,
John
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European Agencies can re-interpret Directives...
About 10 years ago I worked for a company that had units sold into Germany. About 4 years after they were sold RWTUV tagged the units as not meeting CE, and made the company shut them down until my company had fixed the problem. Interesting thing to note, is that we were being accused of not meeting certain parts of the Low Voltage Directive, even though we had previously been given a clean bill of health by TUV Rhienland based here in the US.
In order to try and make things right, we invited RWTUV from Germany, and TUV Rhienland to meet with us. This turned out to be nothing more than a big waste of time and money. Neither TUV agency could come to an agreement, and it actually turned into a very heated argument, with both parties dropping in and out of German as they spoke (very unprofessional, considering that we had no idea of what they were saying). Of course we were footing the bill to get RWTUV over here in the first place.
After many more meetings, and some very expensive proof-of-concept tests, we were finally able to establish what was minimally required to satisfy RWTUV (they had problems with contactor sizing, safety loop wiring, and indicator light colors). Funny thing is, they even re-interpreted the LV Directive's indicator light clause pertaining to one light we were using to indicate that a high pressure fault had occurred. In the directive it states that an AMBER colored light should be used to indicate a fault or cautionary condition has occurred, one that requires no user intervention (automatic shutdown). In our case this is exactly how were implementing it, since the light would only appear following the system shutdown for high pressure. Well guess what? RWTUV insisted that the indicator light needed to be RED. They would not budge on this, and we were ultimately forced to change the LED we were using on our system control board to RED. Just another case of a standard that really isn't.
To sum it all up; we had to submit to whatever changes RWTUV wanted in order to be allowed to continue selling units into Germany, and to prevent all existing systems from getting shutdown for non-compliance to CE. So even when you think you have done everything right, used a third party agency for verification, and paid out tons of money, you can still be cited for non-compliance.
As it was explained to me; the Directives are simply guidelines, and not law. What CE should have been, a declaration of having met a unified European standard, has never come to pass. There is no simple answer when it comes to European compliance, and it changes depending upon which country and/or agency you are dealing with.
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Hi,
If the "wal mart" power supply is CE marked and the secondary voltage is below 48v then you will not need your product to meet the LVD (unless it is a radio device where the directive states that the voltage limits are zero!!). However, if the product is electronic in nature it may still need to meet the EMC directive
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