CE marking of handmade products for sale

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dynax

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Does anyone do or have done CE testing for their products that they sell, i have a few ideas for future products that i want to sell, but some of them will have some electronics in them, i have searched online and as usual you need a degree in gobbledegook to understand any of it, does anyone know in proper english the requirements needed or have perhaps done (the hard work) finding out the process of doing the relevent testing and/or had their products tested by a third party for compliance of the necessary standards,
any help appreciated thanks,
 
When you say they have electronics in them - is that a single, bought in electronic part like a clock movement, something homebrew or something in between ? If the former, it might not be too difficult. If it's any sort of homemade electronics, or even the marrying together of more than one CE marked electronic part, you have my sympathy. RoHS, WEEE, possibly LVD (if over 50v), EMC (very expensive to show compliance) and god forbid, the new RED if it is a radio transmitting or receiving device. There is no way of explaining it simply, because it is not. The worst thing is that the applicable standards depend in illogical ways on what the item is and where it will be used - there are domestic, industrial, automotive, agriculture and forestry, etc, etc standards that could have been unified. Oh, and you have to pay loadsamoney just to get a copy of standards with which you must comply. Which will of course reference several other standards which, you guessed it, you also have to buy.
 
CE ....uuummmmm?

A very odd sort of standard depending on your viewpoint. That viewpoint may be from a small startup company to a large multinational giant corporation. Sheffield Tony's view appears to be from the larger company viewpoint and is very correct. Except:-

CE can be claimed by any company as a self awarded compliance scheme without all of the external testing implied by Sheffield Tony.

An example is the thread here on the small scale making of wooden toys. The issue is that you need to show compliance but can do this by getting documents from other suppliers for components eg Paint being child friendly..get datasheet per purchase. Keep records per purchase and record which batches these apply to....a small pain in the arris....for the completed wooden toy minimal testing by dropping from say 2 ft would suffice.

After all of the above records/tests the maker can then add a CE mark to his/her products.

Large companies in the US routinely ignore the EU standards, apply the UL marks and then just add the CE marks and ship out to the EU. Who is going to check all goods...no one.

So if your small and without the big company complexity (of preventing any legal attacks) you comply to all standards, test against all standards and have expensive experts to tell you what to do. Last time I was involved a small product test costs were of the order of £165,000 for inhouse tests and £285,000 for external tests...wow.

If you plan a sensible approach you will be OK to self mark as CE compliant.

I suggest you find and read the Wooden Toys thread as it is very informative for the small producer.

good luck
Al
 
I come from the point of view of a small company (3 !), but was specifically talking about the electronics aspect. I am hoping that the OP is just meaning to incorporate a bought in electronic device in his product, in which case he can probably not read on ...

If you think the directives relating to toys are challenging, try electronics. Thinks like RoHS you can rely on collecting component manufacturers compliance statements. WEEE is not insurmountable. But EMC in particular you can't demonstrate compliance without specialist test facilities and understanding of the standards themselves and testing methods. So to do it properly you need to use a test facility costing ~£1000 per day. And it is easy to make things that won't comply, the allowable level of radiated emissions is comparable to a distant AM radio station.

If it is just a single embedded electronic unit, like a clock mechanism which is itself CE marked, you are OK. But otherwise it can't even be taken for granted that two or more CE marked components connected together will necessarily make an EMC compliant system.

You might be tempted to ignore it all, and you'd almost certainly be not alone. Since it is all enforced by trading standards, you can estimate your chance of being caught out. You could do something similar to what some Chinese manufacturers do and apply a mark which means "China Export" but looks really rather like a "CE" mark. Of course I couldn't possibly recommend such a policy.
 
Thanks, Al and Tony, in short what i want to do is incorporate some led lighting into some projects, the power would be from a standard dc psu( plug in type), either 12 or 6v output, but the electronics bit would be inside to create different effects, ie, fading, flickering, etc, these units can be purchased as kits, but having some experience in electronics it's not difficult producing them from seperate components, and as the kits are in component form and need to be soldered and built up anyway there's no real difference, the only part that will already have the ce mark would be the psu, thanks,
 
Sheffield Tony":a5d3x3op said:
If it is just a single embedded electronic unit, like a clock mechanism which is itself CE marked, you are OK. But otherwise it can't even be taken for granted that two or more CE marked components connected together will necessarily make an EMC compliant system.

Indeed - the obvious case is a component which emits 80% of the maximum allowed.

A box containing 2 such components is clearly verboten.

(and that's an obvious "interaction"; many interactions are far from obvious)

BugBear
 
Electronics and compliance is something I am not an expert in so be ready to make your judgements.

The power supply should have a CE mark and a data sheet and include the power socket.....so tick.
The LED unit should be broken into at least two components the LEDs and the control unit. I do not knbow if LEDs emit any form of radiation but the datasheets should tell you. The control unit is possibly the main problem depending what it is made from. Again look for a separate datasheet and try to assess the total load of radiation from the unit.

I know looking for all these datasheets sounds easy but in practice it can be difficult as many distributors do not seem to have access to them or are ignorant of the purpose of these documents.

If the unit has a CE for its complete structure then whoooohoooo your good to go.

If you build it yourself then be prepared to defend yourself from compliance, legal attack, litigants actions for damages etc etc. Unless self built units can be tested you are wide open to damage claims be they real or imaginary.

Al
 
done some more research, and as far as i can tell i should be able to safely apply the mark through my own testing, having looked at various items around the house, nearly everything has got a CE mark, from electrical to handcreams, i have a sheet of ply in the hall and even that has one on the label, so does the kitchen clock, so it would seem that nearly everything made has to have the CE mark, so with regard to my future projects, i can see no problem in self certifying them as long as they meet the critera required, as an aside i'm hoping to be able to get my scroll saw in a couple of weeks, so i can get some prototypes made, thanks everyone for your input and any further advice would be welcome, thanks again,
 
Dynax,

Do look for the Wooden Toys thread as it has a good discussion.

You may be able to self certify but before you do I would read the regulations concerning toys on the uk.gov site. It will only take about an hour. Its always better to know and understand why you do something. Similarly with regards to electronics installations.

Al
 
Hi Al, i think i found the toys thread you mentioned, very informative, i would consider my products to fall outside of toy classification, but i can see your reasoning for suggesting it and have taken the info onboard, i will be doing further research, one thing which does spring to mind is how many people who make pens conform with the legislation, pens aren't necessarily classed as toys but how many parents would give an infant a pen to play with to keep them occupied, where would the responsibility lie if something happened to a toddler playing with a handmade pen or some other item that are handmade, things like a wooden bead necklace, or a wooden hair comb, all these could indirectly fall foul of being safe for children, it seems that there are a lot of crafters that could find themselves open for prosecution without realising their products could be dangerous, not just the size or shape but even the finishes used on them could inadvertantly be toxic, it does bring home how many items a child comes into contact with that wouldn't ordinarily be designed or produced for a child, i don't have kids, but i could probably find 100's of everyday stuff in the house that could be lethal to a child that doesn't have the child safe standards, it is certainly a grey area in many respects, so much for a simple life,
 
I suggest you consider something to make them (individually) unique, and classify them as artworks. If you're planning on making hundreds at a time, this may be tricky...

You could recommend a PSU, you might even sell one, but perhaps do so independently of the main item so that the CE mark retains its validity in context. Of course, you will have to source a decent quality PSU (if you sell one), but that keeps you fairly safe.

I'd also look on some "maker" forums too as I'd expect this is a popular topic in that sort of place.

As for testing and CE marking, don't go there if you can possibly avoid it. In the factory where I worked we had a full EMC and acoustic test lab, and access to all the technical standards (and indirectly the standards bodies themselves). That testing operation alone cost several million annually. In some areas even those who wrote the standards couldn't definitively say what they meant. Some of it was important, but a lot was about tilting the playing field to favour the big boys, over smaller businesses. For an artisan maker, that mountain is unclimbable.
 
Hi Eric, i was thinking of only doing limited edition runs of say 10-20 pieces, as far as i can see the product i make would be exempt from the lvd as it's power requirement is well under the minimum of the standard, and as the psu will have it's own compliance there should be no problems, but as always the goal posts can be moved on the whim of some beaurocrat when it suits them, what i will do is produce some samples first and test the waters for viability, at the end of the day i can always gift them or auction them off and give the proceeds to charity, i'm lucky in some respects and i'm not making them for profit, it's just something to make in my spare time and making use of surplus materials,
 
Its amazing how many people give inappropriate items to children. I used to knock out loads of wooden barrelled pens and I sold a fountain pen to a senior manager in a public sector organisation once. A couple of weeks later I had her on the phone ranting about how it wasnt fit for purpose and it had broken quite easily. After getting her to calm down a bit and asking a few questions, it turned out she had given it to her 16 year son who had then played darts with it and broken the nib. Naturally it wasnt going to work very well after that and she blamed me! There is no telling what a purchaser might do with a product, and after even using it for the wrong purpose, what they might do to complain. Everyone knows that any court in the land would laugh them out in my situation but if they took your product to trading standards, what might be the outcome then? Its unfortunate that this is the society we livwe in but cover your back as best you can and get public liabilty insurance and products liability insurance if you are selling anything.
 
dynax":3hetxb7j said:
Hi Eric, i was thinking of only doing limited edition runs of say 10-20 pieces, as far as i can see the product i make would be exempt from the lvd as it's power requirement is well under the minimum of the standard, and as the psu will have it's own compliance there should be no problems
AIUI, it's not quite like that: if you modify a CE marked item, or combine it with something else into a new item (as Sheffield Tony mentioned, I think) it becomes a new product in the eyes of the law, and thus requires a declaration of conformity in its own right.

So if you sell PSUs separately you can to an extent rely on any declaration they have, but if you sell them WITH something you have made, then the whole lot, TOGETHER, has to have a declaration. That's when a dodgy PSU would get you (in the main).

I guess that's reasonable. I can think of any number of items which independently are reasonably safe, but together are dangerous. Sugar (or burned toast) and weedkiller, for example.

For the consumer market, Trading Standards departments (at the local council) are responsible for prosecutions. Again AIUI, they'll only get involved if a trader is knowingly selling something that doesn't have a valid Declaration (or has false documents), or has deliberately turned a blind eye suspecting something might not comply.

If you bought a PSU in, in good faith, and had done diligence to establish it came from a reputable manufacturer, etc., you should be fine. Assuming it does work as stated... But if it is dangerous, or if you bundle it as one product, any misbehaviour it may have does become your responsibility.

The current topical disasters are really cheap mobile phone chargers and Christmas lights. Some of these things can electrocute, or start fires, and retailers can't hide behind documentation provided. And IMHO, that's entirely reasonable.

But Damien Hurst got away with selling animal carcases in tanks of formaldehyde, because it was "art" (the "F" is silent).

I'm not making them for profit, it's just something to make in my spare time and making use of surplus materials,
The profit element is sadly irrelevant. If you sell them you're trading.

But as I said, you can protect yourself by being careful with the quality of bought-in items you sell. You can also use circuits that are unlikely to be a problem. Make some, try them out, run them right next to an AM radio (or find someone with an RF spectrum analyser who might be persuaded to check).

If the circuits are all analogue, you're on much safer ground (speaking of which, pay attention to electrical safety, if that has relevance). Digits tend to cause problems where clock oscillators are involved or high speed data lines, but for low frequency oscillations the remedies are pretty well understood - ferrites and the like usually work well. That said, for years a well known retailer sold audio amplifier kits that, if carelessly assembled, would settle into oscillation around 100kHz, and I still own a rather nasty car booster amp that does the same.

The problem nowadays is the number of RF bands actually in use. In the old days things generally didn't oscillate much above a few MHz, and even then (a) it didn't get very far, (b) things had good metal cases (Faraday cages), and there was nothing in the domestic environment that might be upset (well, possibly the telly), Now we use every bit of the RF spectrum we safely can, so life is much harder. The EMC rules include susceptibility to interference as well as emissions for that reason.

Can you use batteries instead of mains? That makes your compliance much easier, probably.

E.
 
Hi Eric thanks for the detailed reply, i could make them to run off batteries, i could make them to be powered by both, the batteries would be it's primary power source, but could be powered by an auxiliary psu( not supplied) if desired, another option would be the ability of solar charging within the unit, but i suppose that would open up another can of worms regarding rechargable batteries and overcharging prevention,
 
dynax":3feye6fv said:
i could make them to be powered by both, the batteries would be it's primary power source, but could be powered by an auxiliary psu( not supplied) if desired
That sounds like a good plan. it certainly minimises your risk, and assuming it's lead-free paint, etc. and can't be easily swallowed whole by a toddler, and unless there's something really daft about the rest of the circuitry, you ought to be fine.

But don't forget: it's ART!
 
Eric The Viking":bmauopy0 said:
dynax":bmauopy0 said:
i could make them to be powered by both, the batteries would be it's primary power source, but could be powered by an auxiliary psu( not supplied) if desired
and can't be easily swallowed whole by a toddler,

But don't forget: it's ART!

maybe by a baby elephant, but how many people have one of them in their homes :lol:
 
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