CE Conformity

Good morning!
I've recently finished designing a product we are intending to sell to customers here in Europe, and my boss has approached me with this question.... "Are we going to get in trouble with the CE marking....???"

Ok, this project involves:

  • Arduino Mega
  • Ethernet shield
  • Relay module
  • RFID reader
  • Power Supply
  • LCD+keypad

So far I've used, for prototyping, compatible (chineses) Arduino+eth clones. They don't have any CE marking. Official Arduino products DO have CE marking

I've googled this for hours with no luck so far.
Does anyone know if:

  • We can get in trouble by not using CE marked components?
  • If we use all CE marked components, does this make our product compliant? Because on top of the components, there 1)My program, which could have bugs, 2)My wiring which could be wrong (let say I have a 9V-GND shortcut, that may cause a fire even with a CE marked Arduino)
  • Is ANY electronic device sold here in the EU obligued to comply with CE?

Any answer here will be really helpful as I feel lost, I've googled it but I can't only find 300-400 pages bulletins that I don't even know if they relate to what I'm building.

Thank you!

edugimeno:
Good morning!

  • We can get in trouble by not using CE marked components?

CE marking HAS NOTHING TO DO WITH COMPONENTS!

CE MARKING IS NOT FOR COMPONENTS!

CE marking is for final PRODUCTS only!

So you will NOT find any CE marking on resistors, capacitors, transistors or other type of components.

Also any kind of "Arduino board" is treated as a component only, so it does not need to have CE marking.

But if a manufacturer puts together different components to a final product, then the product has to show its conformity to all relevant EU regulations, otherwise the product is not marketable within the EU.

Have seen this page from Arduino.cc :

https://www.arduino.cc/en/Main/warranty

Yes I understand resistors and so on don't need CE marking, but maybe the relay module? The RFID reader?

Arduino official website has a page that states that all their products comply with FCC and CE, that's why I was wondering if by using clon boards it would make things harder, but according to what you say...it wouldn't really matter cause in both cases I would have to show our conformity, right?

Is it hard to get? The problem is that it may not be worth for us as we are selling, so far, only 9 of them to our customer. And we don't know whay sales forecast we can have.

Yes the stated warrany page is where I found it was FCC/CE compliant.
Also, we are selling this product as a complete solution, I mean, this is not like "Device 1: 200€"...No, we sell a solution which involves the product, a custom software application, services, etc... not sure if this changes anything.
I mean, this is not technically marketing a product, we market a complete solution that involves a product, not sure if it matters

Thanks everyone!

A spanish company products sub systems incorporating arduino boards, maybe you could benchmark what they have done in term of CE conformity:

we are selling this product as a complete solution

you will have to get the "complete solution" CE certified (at least, the hardware part.) I do not know exactly what is involved, but...

If we use all CE marked components, does this make our product compliant?

I don't think so. UL, which is similar, wants to poke a "UL Standard Finger" into box openings, to see whether it could hit HV power connections, for example.
I'd definitely look for a CE-rated power supply, though. The mains connection tends to be the most troublesome part. For UL/etc, you can save a lot of trouble by providing a "LV DC in" jack, and using a pre-certified power supply.

I'd expect Chinese import boards not NOT conform to current european RoHS regulations. Lead-containing solder is still very common.

"Conformance Engineering" is a whole separate specialty. Learn, or hire outside help :frowning:

We can get in trouble by not using CE marked components?

You can use non CE marked components, no problems, but you have to certify the completed product.

If we use all CE marked components, does this make our product compliant?

No.

edugimeno:
I mean, this is not technically marketing a product, we market a complete solution that involves a product, not sure if it matters

You are clearly putting a product onto the 'Market' so it needs to be CE marked\compliant.

And before we spend many posts looking for clever 'loopholes', dont bother, there are none that I am aware of.

From the parts you described, the problem part would be the RF reader, the requirements for RF devices are stricter.

Whilst you can 'self certify' most devices, once you have worked out the requirements, it is my understanding that RF devices need (expensive) independent testing, although I have never found a definitive answer on this.

Thanks, they do offer a PDF with the compliance for their product. But if I check the standards they state in the document (ie EN 61131-2:2003) they are specific for PLC's, which is what they sell.
I don't know where to find what I should comply with for a punch-in device....

srnet:
You are clearly putting a product onto the 'Market' so it needs to be CE marked\compliant.

And before we spend many posts looking for clever 'loopholes', dont bother, there are none that I am aware of.

From the parts you described, the problem part would be the RF reader, the requirements for RF devices are stricter.

Whilst you can 'self certify' most devices, once you have worked out the requirements, it is my understanding that RF devices need (expensive) independent testing, although I have never found a definitive answer on this.

Yes I understand, my issue is that getting a CE mark for this device is going to be 10X out benefit in selling this device. This is a 100% custom device we created for the specific requirements of a client, it's not a "global market" product that can be offered at any shop...It belongs to a much bigger project where at a certain point, our client asked us if we could find a device that would fit his infrastructure requirements (pretty customized), so not finding anything in the market that would do it, we decided to build one. But we will sell 9 of these to this customer, and that will be it

If its a custom device then its perfectly reasonable to pass on any costs of compliance.

If the buyer wont meet the costs of compliance, then just dont sell it.

my issue is that getting a CE mark for this device is going to be 10X out benefit in selling this device.

Welcome to the cult that is the EU.

You have two options:-

  1. Get the tests done either yourself or from a certified test house.

  2. Don't bother and self certify. But saying they are all sub assemblies with approval does not in any way constitute any due diligence for not testing your system as a whole.

The loophole that srnet has failed to see, is that no offense is committed until a system is tested and found to be none complaint. So some one has to test your system or pay some one to test your system and then make a complainant to the regulators. So unless some one is gunning for you, like a rival, or your system ends up in court for some complaint or damage it caused, in practice you could get away with it. If you don't punishments include a banning order on you supplying them, a fine of about £2,000 to £3,000 and confiscation of any stock you hold.

Just as a side note, in a location close to us some one was caught speeding. He proved in court that the speeding equipment did not have full CE compliance. Result - He still got done for speeding and the company suffered no penalties, but they did immediately go out and spend a lot of money getting it done officially.

Grumpy_Mike:
The loophole that srnet has failed to see, is that no offense is committed until a system is tested and found to be none complaint.

I have not failed to realise that, but would not decribe it as a loophole.

I see that in much the same way as any offense, i.e it has to be shown that an offense was commited before you are guilty.

I see that in much the same way as any offense,

Not so.

You commit an offense like say theft, it is an offense, whether it is proven or not.

With non complaint CE no offense has been committed until it is proven. Subtle point but true.

edugimeno:
Is it hard to get?

No but testing to prove compliance is very expensive.
You can self certify , until you get caught.

UL approval is slightly different related more related to safety rather than interference etc.

If sold as a kit or used in certain circumstances in house the requirement can be avoided.

Thing is that UL is not compulsory, where as CE is.

One significant difficulty is that in order to comply, you need to know which directives\standards you need to comply with and that may not always be obvious.

The standards are not cheap, so how much you would have to spend and read to work exactly what you need to comply with I dont know.

Of course this only applies to stuff placed onto the market in the EU and the Chinese just seem to ignore the rules anyway.