The EU and CE marking + RoHS - Can one partly solder something?

Hi there,
been reading a bit up on the EU and CE marking law. And if one sell a electronic product it need to follow both CE and RoHS. Any wifi-eabled device also need some testing if I understood it correct. Way to costfull for my time and expected sales of my hobby project.

Same concluion is fund here:

My understanding is it is ok to sell components and hence a Arduino-kit is then ok, but what about if I offer to pre-solder the soldering part of the project?

This would mean the user will have to add USB cable, put in box and hence basically warp it up?

Is this then a "product" or still a "kit"?
/Klaus

So the equivalent of what you are suggesting is that selling the working inards of a mobile phone classes as a kit, if you sell the case extra ....... sounds to easy a dodge, dont you think ?

RoHS applies to the smallest homogeneous parts - regardless if it's a kit or whatever. All your components have to be RoHS compliant. So make sure your suppliers sell you the correct products, and if you want to do some soldering yourself on it use lead-free solder. Nowadays pretty easy to be RoHS compliant, electric components that are not compliant are rare.

CE I'm not familiar with. Years ago manufacturers told me "as long as the logo is on it, it's fine". Can't be that easy.

wvmarle:
Nowadays pretty easy to be RoHS compliant, electric components that are not compliant are rare.

True, even lead free PCBs are not that expensive these days,

srnet:
So the equivalent of what you are suggesting is that selling the working inards of a mobile phone classes as a kit, if you sell the case extra ....... sounds to easy a dodge, dont you think ?

I guess so :slight_smile:
What I have in my build is a MPU6050, NodeMCU and DS18B20, so it only needs 7 solderings, so not a deal breaker for people to solder. I am working on a fermentation logger using vibration to detect bubbles:

So i just need to be RoHS complience and hence neeed to source this somewhere with written statements ensuring this part?
/klauss

This are really questions you will have to ask the customs&excise department of your local government, or a lawyer that is versed in the subject. You may also be able to find such details by browsing your local government's web site.

I am not a lawyer or even a knowledgeable amateur on this subject but my understanding is that CE only applies to finished products, not kits. So a kit of parts does not have to be CE marked. The argument then becomes what is a finished product? Is a display a finished product? I would say it is a component so no, others might argue differently.

How many people have been prosecuted under the CE rules? I suggest it is the same as the number of people who have died when they have gone swimming 59 minutes after eating a meal, but perhaps someone can correct me on this.

I seem to recall that somewhere deep inside the CE gumf there was the potential for a kit to be required to follow the CE process, but it seems unlikley that would ever be prosecuted, other wise you would have companies selling parts, such as Farnell\Element 14 being affected.

However there is a requirement for the CE process to be followed when an item is 'put into service' so whilst it may be OK to sell a kit of parts the person building the kit may be subject to CE requirements.

wvmarle:
This are really questions you will have to ask the customs&excise department of your local government, or a lawyer that is versed in the subject. You may also be able to find such details by browsing your local government's web site.

That is my view also.

I think most Governments have services to help small businesses with exactly this sort of question - cheaper than employing a specialist lawyer.

You should certainly NOT be relying on the advice of people you don't know on some internet forum. The judge won't be impressed if you tell him "Robin2 said it would be OK".

...R

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