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The Journey to CE Marking an IoT Product Part 3: Design Review

Andrew Back
Open source (hardware and software!) advocate, Treasurer and Director of the Free and Open Source Silicon Foundation, organiser of Wuthering Bytes technology festival and founder of the Open Source Hardware User Group.


March 19, 2019 07:28

Note that for Wireless products, such as this, one also needs to comply with the radio Directive, including (1) Radio, (2) Emc and (3) Electrical Safety testing. One may not build on the information given by the module manufacturer, as they often declare nothing on compliance, or declare that it is possible to build a complaint device with it only. To "dgoadby", the only reply can be that CE is a legal requirement, and he needs to adjust the price of its devices, change business model, or be less flexible, and produce larger batches. Hazards often are caused by small customizations, and so the risk hitting some is even larger for him as for larger companies. His clients also need to understand that custom based equipment cannot be sold for a handfull of coins.
I agree on the costs for purchasing documents, but for the moment these documents (mostly produced by CENELEC) are market driven/created, so someone needs to pay. It logical that the market pays. Since the Elliot case the Harmonized standards are equal to law, and since that trial he has a good case, in advocating for free standards.

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March 20, 2019 16:41

@cetest the sensor board is be to marketed as a sub-assembly that could be used with any one of a number of different MCU+radio modules, hence it will not be certified as an e.g. BLE, NB-IoT or LoRaWAN etc. device. A product developer or system integrator that combined this with a particular module, antenna, PSU and enclosure etc. would be required to certify this combination for the given environment. CE + CE does not necessarily equal CE, but suitably tested and within spec components/sub-assemblies should make this job easier.

March 18, 2019 13:15

Whilst CE testing and validation is a serious and necessary process the basic problem is that it doesn't scale. I am a very small company and I make low volume (1-5) items selling for around £2,000 each. Each batch is different so, theoretically, each batch needs full CE testing. I am usually quoted around £7,000 for a test (without wifi/bluetooth). Clearly each batch would be made at a loss if I used a testing house so I self certify. Large companies can easily absorb these costs - I can't. Even then, the costs of procuring the many (and constantly changing) CE documents that you need to read, to check which tests are required, is prohibitive to a very small company. Why are we charged for downloading pdf's of mandatory documents anyway?

At a technical level this series has been useful so far.

March 26, 2019 12:36

@dgoadby We are in a similar situation. @cetest . Easier said than done.

March 19, 2019 07:28

This is a really great article - more like this please !!!!

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