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CE marking newbie

Discussion in 'Electronic Design' started by Steve Sousa, Apr 13, 2006.

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  1. Steve Sousa

    Steve Sousa Guest


    I'm suposed to design some products to put on the market in europe, as
    far as i've been able to find out, i must design them to meet the CE
    marking, and that implies at least compliance with emc emission and

    What other standards does it need to comply with?
    What about safety?

    The base product is small pcb with a cpu, a gsm modem, and a lithium-ion
    rechargeable batery (oem cell, not a pack, i.e without any
    electric/electronic protection circuits). It measures temperature, and
    responds to digital inputs with digital outputs, thru a transistor or

    There are 2 variations:

    One is to install on car/motorcicles/trucks that includes a gps receiver
    and bluetooth transceiver, housed on an entirelly metalic case.

    The other is a fixed instalation powered by the mains thru an
    off-the-shelf power suply, meant to be installed on houses or on
    factories, that has a keyboard, an lcd, bluetooth, and optionally a
    serial port, and/or a video camera input, housed on a plastic case.

    Does the LVD apply? the supply input is specified as 10~40 VDC, which is
    bellow the 75V mentioned on the Low Voltage Directive.

    The modem manufacturer design guidelines state that "it is essencial the
    application power supply is designed to comply with the specification in
    section 3. This will be sufficient to pass type approval, no RF testing
    will be required if it meets these specifications"

    The bluetooth stack is developed in-house.

    Can we really avoid the RF tests?

    Sorry for the cross-post to sed but seec looks dead with only a couple
    of posts on the last week.

    Thanks in advance.

    Best Regards

    Steve Sousa
  2. neil

    neil Guest

    I'm also a bit of a newbie to CE, and am not a lwayer ... but ...
    afaik you can mark anything as CE, but it's down to you to get sued if
    someone gets injured/killed.
    So although our stuff is used in an eng lab, within secure company sites, we
    make a long document stating how we think all requirements are met, and what
    reasoning behind that. So if anyone sues, we canpoint to it and say we
    tried our best.
    Some tests are performed to check emi/emc status. If the emc limits aren't
    met we just warn the customer, who then waives it (nice huh).
    Worth calling some expert who does it for a living, to check costs.
    If you are in UK, then the guy I know is Ian Attoe on +44 (0)1634 844400
    (big site, need to ask for him), who may or may not be able to help.
    The costs of emc tests are bbbiiiggg though.
    Probably help to use a separate (certified) power supply plugged in to your
    unit, to avoid any worries on that side of things.
  3. Hi Steve,

    For electrical items used in vehicles there is separate approval called the
    e-mark, I believe this applies only to items that are 'installed' into the
    vehicle, either during manufacture or after market.

    CE marking applies to other electrical devices, for instance a mobile phone
    may be CE marked but a hands-free kit that needs to be installed into the
    car's electrical system would be e-marked.

    Hope I've not added to the confusion,

  4. Guest

    If the product operates at below 50VAC or 75VDC it is outside the scope of
    the Low Voltage Directive.
    If this is the case it must meet the requirements of the General Product
    Safety Directive.
    The product will in both cases have to meet the requirements of the EMC

    For more information on the directives please have a look at the guidance
    booklets on


  5. Roy L. Fuchs

    Roy L. Fuchs Guest

    Great link!
  6. pooter

    pooter Guest

    neil [] said
    You can only self-certify if you use standards that have been published
    in the Official Journal (OJ) and comply with them in their entirety,
    otherwise you need to produce a Technical Construction File (TCF) and
    get it approved by a Competent Body.
    It would actually be an issue, in the UK, for Trading Standards and they
    would deal with you. In the first instance, they would probably just
    stop you from selling until you fix the problem but this could stretch
    to a product recall if they deem it appropriate. Either of these actions
    could of course be quite sufficient to financially ruin a business.

    Trading Standards will generally only prosecute as a last resort.
    Contractual arrangements with your customers do not revoke or replace
    your liabilities under the law and if you are not complying with the
    appropriate standards in their entirety then you need to produce a TCF
    and get it approved by a Competent Body.
    There are many views and opinions to be offered as to the appropriate
    way forward for any given bit of kit so it is always worth getting a few
    proposals and quotes.

    I was recently looking to get a TCF put together and approved using the
    railway standards (which are not published in the OJ) and a number of
    different proposals were put forward with varying degrees of test and
    analysis with costs ranging from £10,000 to £60,000.
    Is this just someone you are suggesting for free advice as you do not
    give this person any context? What is the company?
    Out of interest, there is no requirement to actually test although for
    small, large volume items it is perhaps the most appropriate path. A TCF
    route with analysis and some (or no) testing can be a much cheaper
    option for large and/or low volume products even though it requires
    specialist expertise.
  7. One should produce the TCF anyway as you may be called upon to produce it at
    anytime. The notice period for its production isn't that long either. This
    is whether or not a Competent Body examines the file.
    In an industry where we have to support a full, up to date, safety case we
    view the document as the complete reference of arguments that can be used
    in a court of law should any incident lead us there. In other words, it is
    our entire defense case prepeared before we even have the consideration of
    any trial. If your document is that good you have probably identified all
    the risks you face and have dealt with them to minimise the your
    liabilities (in law and financially).
    Any equipment that does not comply with the requirements of the EMC
    directive are not permitted to be brought into service in the EU (with a
    very few exceptions to do with research).
    There are a number of links between the railway standards and standards that
    are recognised by the EU official journal. It takes some time to explore
    all the references. A published cross reference would, though, be useful.

    If you, as a manufacturer or importer, are unsure of your ground seek the
    best expert opinions you can afford to ensure that you comply with
    legislation. Indications are that it is going to get tougher.

    Paul E. Bennett ....................<email://>
    Forth based HIDECS Consultancy .....<>
    Mob: +44 (0)7811-639972
    Tel: +44 (0)1235-811095
    Going Forth Safely ..... EBA.
  8. RHRRC

    RHRRC Guest


    There is an oligation to keep a Technical File of the product
    available for 'the authorities'.

    A Technical Construction File is a different thing - to replace the
    Technical File - for products/situations where published standards are
    not theoretically and/or practically applicable.

    Confusing the two can be *very* costly.
  9. pooter

    pooter Guest

    Paul E. Bennett [] said
    As there is no a legal requirement for a TCF if you self-certify there
    can be no requirement to "produce it at anytime."

    A company might of course consider it prudent to keep appropriate
    documentation so as to be able to show due diligence but there is no
    requirement under EMC legislation to produce any document other than the
    Declaration Of Conformity when taking the self-certification route.
    Fair enough, but that is outside of the scope of EMC legislation.
    Which I think kind of what I said. :)

    And in the UK SI, the word used is "supply". ;-)
    While EN50121 is harmonised, it is not in the OJ so where this is the
    appropriate standard, and it is for both trains and traction, there is
    no choice but to go TCF and Competent Body.
    I am very sure thank you and was just trying to briefly explain the
    position to someone who was a self confessed newbie. :)
  10. Roy L. Fuchs

    Roy L. Fuchs Guest

    If you want all of your shipments of product to europe turned back
    at the docks...

    If want to be COMPLIANT to the spec, and want to place the logo on
    your product via "self certification", you had better have your firm
    set up correctly.

    If you want to place the logo on your product via "self
    certification", yet do not really want to actually be compliant, it
    WILL eventually bite you in your dishonorable ass.
  11. pooter

    pooter Guest

    Roy L. Fuchs [] said
    LOL! Stop messing about. :)
    CE Marking and EMC has little to do with how your firm is set up and
    everything to do with your understanding and actioning of the
    requirements of the law.
    Not quite sure why you are posting this at someone who has just spend
    the last 6 months of her life getting a load of products through EMC to
    CE Marking and therefore knows large chunks of the legislation pretty
    well at this stage of the game, but in reply, unless there is a genuine
    and practical problem with your kit it is unlikely that there will ever
    be an issue whether or not the CE Marking attached to that equipment is
    valid or not.

    Therefore your donkey will *not* inevitably get bitten.
  12. Guest

    That is a great site that I had not seen before.

    H. R. (Bob) Hofmann - USA
  13. Guest

  14. Roy L. Fuchs

    Roy L. Fuchs Guest

    You really don't know much about it then, because that is EXACTLY
    what they would do if you were ever found to be fraudulent.
    It has to do with compliance with accepted norms and standards in
    the industry. Having the ability to have the logo silk screened onto
    your product is NOT all that is required to be capable of self
    That depends on what the product is. With high voltage power
    supplies, for instance, you can bet that the product WILL get
    scrutinized, and it had better pass the scrutiny.

    You assume far too much. 6 months is nothing. I worked for a firm
    that has plants in both the US as well as the UK, and for a decade we
    went over self certification requisites. It isn't something they just
    let any maker of goods do without a fair modicum of scrutiny.
  15. pooter

    pooter Guest

    Roy L. Fuchs [] said
    I know pretty well *everything* about CE Marking and EMC from a point of
    view of what paper work etc is required. :p
    I'm talking about CE Marking and EMC, what exactly are you talking
    Actually it has to do with meeting the Essential Requirements of the
    But you do not have to put the CEO Marking onto the product and instead
    can put it on the packaging, instructions or warranty - so no silk
    screen printing is required. :)

    And this BTW, is all that is examined at "the docks" and this is why
    there is some wisdom in putting it on the packaging.
    Can I humbly suggest that you re-educate yourself by reading a copy of
    the EMC Directive and the LVD Directive. The law in the individual EU
    states are sometimes a little different (in the UK for example the work
    "supply" replaces all the other terms used in the directive and in
    Germany some advisory parts are treated as being nominative) but it
    gives 90% of the information you need.

    I'd suggest that you start with the EMC Essential Requirements and then
    move on the the bits about what documentation is required and who it
    needs to be made available to.
    LOL! Get off your high horse. :)

    As a full time job, it is well long enough to time to read, understand,
    seek advice and implement the legislation.
    Perhaps you need a refresher course them, or you should maybe seek
    advice from someone who can actually understand what they read.
    <Panto mode on>

    Oh yes it is.


    The _whole point_ of CE Marking is to allow the free movement of goods
    *without* them having to be scrutinised at every juncture.
  16. Roy L. Fuchs

    Roy L. Fuchs Guest

    But your remarks about self cert were off.
  17. Roy L. Fuchs

    Roy L. Fuchs Guest

    Again, you miss the intent of the statement.
    Like I said, the capacity to place the mark on something is not all
    that is needed to self cert. It has to actually BE compliant, and
    your firm actually has to have enough brains to ensure that it is.
    If they know how to make a product, but do not know about the
    requisites of the industry, they shouldn't be self certifying.
  18. Roy L. Fuchs

    Roy L. Fuchs Guest

    The whole point of self certification is that you have enough brains
    to actually scrutinize it yourself, not just willy nilly claim to be
    self certs and willy nilly place the mark on everything you make.
  19. Joerg

    Joerg Guest

    Hello Steve,

    With this one you might have to be careful. If it becomes an integral
    part of the vehicle, for example if mounted on the chassis and connected
    to some vital parts of the vehicle, it might need a type certification
    for that vehicle. Most European countries are stricter with this than
    the regulations you find on other continents.

    When I moved to the US I was amazed by the modifications people did to
    their cars. In Europe they would have pulled me off the road for most of

    Regards, Joerg
  20. Jim Thompson

    Jim Thompson Guest

    Around here we're commonly referred to as "FREE"!

    All that is mandated here is "safety" equipment... basically the
    brakes and steering, head and tail lights (and smog stuff) can't be
    arbitrarily modified... everything else is free for the playing...
    even neon lighting under the body and suspension systems that hop up
    and down on command ;-)

    ...Jim Thompson
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