Not necessarily,  I worked for a design house for many years (until a few 
months ago) and got embroiled in this many times. CE "Certificates" mean 
nothing in essence, as you can self certify. So in reality you can do 
nothing and still sell your product, often even with the CE mark on it if 
you believe that it is truely compliant. The problem is that you can be 
called up, by anyone, on its compliance and then it is up to you to 
demonstrate its compliance (usually by pulling a technical report out from 
under the desk). You can have fun E-Mailing companies for their CE 
certificate / technical file on their products and see what gets sent to 
you - I used to do this regularly with competitors to a design I was 
working on for a client mainly to see what standard their product was 
tested to as a guide for myself!

The most common route followed for EU is to get a final pre-production 
prototype ready and get it EMC tested (Radiated / Conducted emissions and 
Susceptability). Then, if thats all good and if its a physical product for 
consumer use (rather than a PCB to go into something else / a kit etc) then 
also get it Safety Tested (I handled a custom LED lamp design which turned 
into a nightmare here...). This safety testing can vary a lot based on the 
EN category (which are fairly broad - lab (EN61010) / industrial / medical 
(EN60601)  / consumer / Audio Visual / Railway / lighting) it falls into 
(this also affects the EMC testing as different limits for different types 
of product). Then you are pretty much good to go, take out some libility 
insurance and your golden. Expect to pay £2500 for EMC and about the same 
for safety. Get a friend in a university / academic institution who has 
access to the standards library to download you the EN standards you want 
for free (otherwise they can be £100's).

Again, you can skip all this and write your own tech report - if you get 
called up do the testing then, if it failes on EMC you can just say 
"whoops" - pull it from sale and re-start selling with it fixed. There is 
rarely recalls for EMC issues, and it will only be your competitors that 
haul you up on it usually (unless it is literally broadcasting like a 
beacon). If it fails on safety you have a bit more of an issue. Most of 
safety testing is looking at the flamability of the design / materials 
(they will set fire to the prototype / burn holes in it during testing) and 
the VDE / UL approval of Critical Components (bits with mains going into 
them / user interactive bits). It is usually about 70% document exercise / 
tickboxes and 30% trying to tip it over / burn it / throw it at the ground 
and see if live parts become visible. They will check PCB gerbers for 
creepage and clearance distances of tracks too, and measure with 
thermocouples all possible hot spots (transformer cores / user touch areas) 
and block off fans to see if it burns up with no air flow. All in all 
fairly logical stuff but your paying for the boringness of it all / 
letterhead.

US testing is quite different - different EMC limits (often simpler - you 
dont test susceptability iirc, as if everything complies with radiated 
emissions then why would there be a problem with received erronious 
emissions?) and of course all different safety compliance standards - but 
the process is much the same - though not "self certified" - you have to 
get UL or MET approved. A good test house will quiz you on your intended 
markets and can do all the testing to both limits at once and will charge 
you for each regions compliant report.

So I Would argue US is for sure just as hard, if not harder than EU as you 
have to get it tested from the get go... Oh, and you dont need to worry 
about WEEE unless your selling over a certain quantity or weight, but all 
you need to do anyway is provide a return address people can ship stuff 
back to you at the end of its life.

As an aside, bespoke items dont need testing nearly as much / at all - so 
"Custom made to order" is a good get out for low volume / Etsy kind of 
things.

Just wait for the kitemark to come back what with brexit...

- Alex


On Friday, 1 November 2019 21:04:45 UTC, newxito wrote:
>
> Selling electronics seems to be very complex in the EU. Even for small 
> series you apparently need the CE certificate... and many other 
> paperwork. You even have to register and pay for future recycling. And I 
> think is better to have a good insurance because of the “product liability”.
> Selling kits seems to be a little bit easier. Anyway, I have decided to 
> never ever sell any self-designed/self-made electronics.
>
> If someone is interested, google for "auf dem Weg zum eigenen Produkt", 
> there is a very informative drawing from the German “Make”, if you click 
> on the icons you get a more detailed explanation ... if you understand G
> erman :-)
>
>>

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