logoalt Hacker News

leoedinyesterday at 8:48 AM1 replyview on HN

In the EU (and UK with UKCA), CE certification is down to whoever makes the product available on the market. There's no get out for pre-certified modules. If you put a pre-certified module in a box and sell it, you have to be responsible for the CE mark.

You need evidence that the whole product complies with the EMC regulations. There's some judgement involved - if you put a certified circuit board in a plastic box, it won't change the EMC behaviour so you don't need to re-test. But if you solder a module onto a larger circuit board, you are almost certainly changing the EMC behaviour. You should definitely be re-testing something like that.

The pre-certified module does save you some time in the "intentional radiator" testing - assuming you use the same antenna it was tested with as a module, you can probably make the case that the behaviour is the same.

Will anyone ever notice or care for a few thousand niche devices? I doubt it. But to sell in the EU legally you do need to do that testing.


Replies

holowoodmanyesterday at 10:43 AM

No, you actually don't have to do the testing, except in some special circumstances (e.g. childrens' toys). Generally, the "CE" mark is a self-certification done by the manufacturer or importer that certifies that the product meets certain (category-specific) criteria. You can do the proper thing, test your product and then certify it. But it is also possible and usually legal to just issue the certificate based on a self-assessment and deal with the fallout later, if there ever is any. That's how basically all non-EU manufacturers and importers get their CE mark...

https://europa.eu/youreurope/business/product-rules-complian...

show 2 replies