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If you are producing a product that can help with this crisis and you’re in need of assistance with regulatory approvals, advice, guidance or testing, we are here and want to do our part to help the country during this time of need.

Please call us.
In the wake of the Coronavirus, COVID-19, pandemic, we want you to know we care about you and we hope that you, your colleagues, family members, and friends are healthy and safe. 

F2 Labs is taking all precautions to keep our employees and customers safe and we are open for business. We are fully committed to being here when our customers need us.

Our staff is continuing to focus on providing the highest level of customer service.
We can be contacted via this link. We can be reached by phone at 877-405-1580
and are here to help you.
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My product recharges or powers from a USB cable, do I need to comply with the Low Voltage Directive 2014/35/EU?

The question in the title of this blog article is frequently asked by our customers.

Let’s break it down.

See the LVD 2014/35/EU, Article 1, para 2:

The Low Voltage Directive 2014/35/EU applies to products with a power input of 50 to 1,000 VAC and to products with a power input of 75 to 1,500 VDC. So, a product with a port for a mini-USB or a USB cable runs or charges from a 5 VDC input. It is excluded, right?

Maybe. Maybe not.

There are some distinctions. Technically, if you supply your small toothpick dispenser (my favorite widget example) to the EU…

  • and it only has a port for USB and that port is labeled “5 VDC”…
  • and your manual says that it requires 5 VDC…
  • and there is no mention of any connection to AC mains power (plugging into the wall) then your product is excluded from the Low Voltage Directive 2014/35/EU.

The EU authorities can and will look at your marketing literature, the packaging, the manual, and your website. They can say that your product is AC mains powered (in the EU that would be 220-230 VAC) if they see anything that shows your product plugged into the wall.

Let’s face it: a USB port on your product means that someone will likely take that product and connect a USB cable to it and then to a USB wall charger. Like the kind that come with every iPhone. In that case it is AC mains powered.

Here are some rules of thumb:

  1. Supplying a charger or AC/DC power supply with your product makes it instantly in the scope of the Low Voltage Directive.
  2. Specifying a connection to an AC/DC power supply for use with your product makes it instantly in the scope of the Low Voltage Directive.
  3. A marketing picture showing this product connected to a wall charger makes it instantly in the scope of the Low Voltage Directive.

I often refer to the EU’s RAPEX weekly reports in this blog because it is a very useful tool to understand why products are stopped in customs and / or pulled from shelves. Below are some examples that illustrate the above. Clicking the pictures takes you to the individual alerts with more detail.

Below is a hover-board. Clearly not intended to operate while plugged in and charging.


.

Next up is a rechargeable electric razor.

Below is a rechargeable LED light for use while camping.

And below is a final example. Keep in mind that I searched “electric shock” as the risk on the RAPEX page and only for 2020 and 2019. There were more than 30 pages (with multiple entries per page) and I only went through the first few pages.

This final example is a solar powered light.

Notice that this light is supplied with a USB port and the authorities indicate non-compliance with the Low Voltage Directive and the following in the alert: A black and white rechargeable, portable table / wall LED lamp with a USB port, which can be operated directly from the mains, batteries or by the built-in solar module. The product is supplied with a charger and packed in a cardboard box.

The sales and engineering staff at F2 Labs study these issues every day. Call us. We can help you take an educated compliance path for your product.

We can be contacted via this link. We can be reached by phone at 877-405-1580
and are here to help you.

F2 Labs is here to help.

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RoHS 2011/65/EU + (EU)2015/863 and EU custom’s enforcement the week ending February 28, 2020

I get an email from RAPEX every Friday morning that details products stopped in customs in the EU for various issues. These are not all of the of the products stopped, just the most dangerous ones. RAPEX is an acronym for Rapid Alert System for dangerous non-food products.

Last Friday, February 28, 2020 I opened the email in the morning, which sent me to this link, and started scrolling like I do every week. I immediately noted that there appeared to be a larger than normal number of products stopped for non-compliance to RoHS 2011/65/EU.

This link is one example of a product stopped for RoHS non-conformity: Link.

The RAPEX email and alert is meant to tell everyone in receipt that the subject products are dangerous and should be removed from use immediately. Of course you do not want to end up in one of these alerts!

F2 labs offers RoHS evaluations for EU (CE marking) compliance. Usually we make these evaluations based on a study of your supplied BoM and no testing for RoHS is required in most cases.

We can be contacted via this link. We can be reached by phone at 877-405-1580
and are here to help you.

F2 Labs is here to help.

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Why selecting the right power supply is crucial to EMC Testing Results

Most of our customers must comply with the EMC Directive 2014/30/EU prior to application of a CE marking to their products. This is because the EMC Directive is applicable to almost everything with active electronics. Unlike North American EMC compliance (FCC and ICES) which requires emissions compliance only, EU compliance to the EMC Directive requires emissions and immunity testing.

Proving this in most cases means testing to one or a pair of harmonized EN standards for EMC. These harmonized standards indicate the required tests – which are usually contained in other standards we call “test standards”. The most frequently used EMC test standards are below.

  • EN 61000-4-2 – ESD Immunity
  • EN 610004-3 – Radiated Immunity
  • EN 61000-4-4 – EFT Immunity
  • EN 61000-4-5 – Surge Immunity
  • EN 61000-4-6 – Conducted Immunity
  • EN 61000-4-8 – Magnetic Fields Immunity
  • EN 61000-4-11 – Voltage Dips/Interrupts
  • EN 55011 – Radiated and Conducted Emissions
  • EN 61000-3-2 – Harmonic Current Emissions
  • EN 61000-3-3 Flicker/Voltage Fluctuations Emissions

Now we come to the purpose of this article: power supplies and the problems that can be created for your compliance project if you select one that is not suitably approved. We frequently see documentation for power supplies that does not prove compliance. These power supplies can be the source of EMC testing failures in our chamber because power supplies can cause emission issues. And non-compliant power supplies cause more issues than compliant power supplies.

The documentation for a power supply may look, on its face, like the product is compliant but a little investigative work often shows that it is not. Keep in mind that anyone can place a CE marking on a product. Actually complying with the requirements is different. Because of this we suggest asking for the test report or reports from the manufacturer.

We have seen many reports that were generated by a manufacturer internally. In the world of compliance these are not valid. Why? To be an actual test report the testing lab must have laboratory accreditation and the gear used to test the products must be continually calibrated. That gear and the calibration dates must be listed in the report. The testing standard must also be listed in the report.

Our sales department can discuss these issues with you. In fact, our salespeople look at these documents so frequently that we can often immediately tell you if a test report or declaration of conformity appears valid.

I hope this helps. Please contact us today with any questions or to discuss your project.

877-405-1580

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Brexit happened: Does CE still cover the UK?

Yes, for now. Notice that CE marking will be accepted until at least the end of 2020 and then the UKCA mark will be the replacement mark for products sent to the UK. The link to the UK page regarding this new information is here.

We can be contacted via this link. We can be reached by phone at
877-405-1580 and are here to help you.

F2 Labs is here to help.

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Fender Guitars and EU compliance, interesting read

In the interest of full disclosure, I own a Fender American Professional Telecaster, in butterscotch blonde of course, and a Fender Custom ’57 Champ Amp. I love Fender products. If it says “Fender” on it… I am usually considering the need to buy that product!

However, I found it very notable that the company has been fined in the UK for price fixing. This does not involve any sort of engineering compliance issue, but it does show the international reach of market surveillance authorities. These UK authorities determined that Fender employees intentionally did not write things down about this. Presumably (my assumption) is that these employees were concerned about subpoenas for emails.

The CMA (Competition for markets authority) uncovered this during the investigation. I find this worthy of posting to our blog because it is just as important – or maybe more important – to make sure your CE marking compliance issues are taken care of, correctly.

We are separated from the EU by an ocean but it is our continuing responsibility to ensure products placed on the market in the EU are compliant and safe.

We can be contacted via this link. We can be reached by phone at
877-405-1580 and are here to help you.

F2 Labs is here to help.

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Machinery Directive 2006/42/EC – The text and the harmonized EN standards

Complying with any EU CE marking Directive will require a trip to one of many European Commission websites that are set up to assist with the process. They are great sources of information, I have them bookmarked, and one or more are open on my computer usually during the day.

The Machinery Directive 2006/42/EC site is here: https://ec.europa.eu/growth/single-market/european-standards/harmonised-standards/machinery/

Clicking that link will take you to a lot of good information. I have been asked a few times in the past two weeks about this so now is the time to lay it out in a (hopefully) useful F2 Tech Notes blog article.

The first thing you will see on that page is this chart:

There are two very important links in that chart. The innocuous label “OL No L 157, 9 June 2006” is a link to the Machinery Directive 2006/42/EC. Open that link and you will see the text of the Directive but also this:

English is my first language, so I scroll over to the “EN” and then click the pdf symbol below it. That opens a pdf version of the Machinery Directive in English, here. It opens as displayed below.

Are you new to CE marking and the Machinery Directive? I tell every F2 Labs customer the following, “Skip the recitals and go straight to Article 1. It’s all in plain English.” See below.

Next, go to Article 2 to see that everything in Article 1 has an easy-to-read definition.

The second very useful item in the chart from the top of this article is this:

I highly suggest clicking the link for the Guide to application of the Machinery Directive 2006/42/EC and saving it somewhere that is easy to get to. Because if you make machinery and you export to the EU you may learn that it is an invaluable tool that can be constantly referenced and learned from.

Next (and last) on the overall Machinery Directive page are the links to the Official Journal of the EU lists of harmonized EN standards. These are very important because only harmonized standards offer the presumption of conformity for your machinery.

Side note: What does this mean? It means that if you are complying with the Machinery Directive and you use the appropriate and applicable harmonized EN standards (harmonized means the standard is officially “linked” to the corresponding Directive) to evaluate and test – and it passes – then your equipment has the presumption of conformity. The authorities or anyone else looking at the equipment should assume it complies with the reference legislation when reviewing your EU declaration of conformity if you used harmonized EN standards.

Now, we turn our attention back to the Machinery Directive page we began this article with. Please, see three long links:

Those links are all important but they are all different. Choose wisely!

The first, for (EU) 2019/863, lists a number of standards that are withdrawn as harmonized standards for the Machinery Directive. The associated dates next to each standard tell you when you can no longer indicate these standards on your declaration of conformity if they are applicable to your equipment. You will have to find a different set of standards to test/evaluate. This Commission Implementing Decision was published this month (November 2019) to address some ambiguities and mistakes made in the second link ((EU) 2019/436). One notable mistake is that (EU) 2019/436 calls for the withdrawal of EN ISO 12100:2010. We wrote about that, here, because it was a major development.

Another correction to (EU) 2019/436 is that it lists standards to be withdrawn but does not indicate the date at which they (the indicated, withdrawn standards) no longer confer a presumption of conformity (i.e., the date you can no longer use them to prove compliance to the Machinery Directive).

The second, for (EU) 2019/436, lists the following:

  • Annex I – applicable new or amended harmonized EN standards
  • Annex II – harmonized EN standards that now have restrictions
  • Annex III harmonized EN standards to be withdrawn (but no date for withdrawal, see (EU) 2019/863)

Finally, we arrive at the current “list” of harmonized EN standards for the Machinery Directive in the last link:

That link takes you to the current list that is published in the Official Journal of the EU, or “OJ” as it is often referred.

At this time, for any new projects, we suggest that (EU) all three links must be consulted if you are determining which EN standards are applicable to your equipment. Or, contact us at F2 Labs. We can help sort it out.

We can be contacted via this link. We can be reached by phone at 877-405-1580 and are here to help you.

F2 Labs is here to help.

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EN 60950-1 and EN 62368-1

We are starting to feel some more effects from the upcoming replacement of EN 60950-1 by EN 62368-1. This is causing some confusion in the compliance world as well and I wanted to share a recent example that we were contacted about.

The customer builds equipment that is a combination of three subassemblies that are themselves independently operational. These devices, when combined, create a new device which itself must carry a CE marking (remember, “CE + CE does not always = CE”).

This customer engaged F2 Labs after working with another lab and even had me come to his facility for a two-day training seminar this past summer.

He contacted me because the other lab refused to accept that one of the assemblies was tested to EN 60950-1. The lab indicated that the assembly must be tested to EN 62368-1 to be acceptable because EN 60950-1 is expired.

Upon reading the email from our customer I next opened the link to the Official Journal of the EU’s list of harmonized EN standards for the Low Voltage Directive 2014/35/EU, here. Next, I searched for EN 60950-1 and it appeared in the chart next to EN 62368-1. See below.

What does this mean? I have written about this topic, previously, here. There is another article on our blog that goes into this topic in much greater detail, here. EN 60950-1 is formally expiring on December 20, 2020 and at that time you will no longer be able to send equipment to Europe under EN 60950-1. You will need to submit the equipment for testing to EN 62368-1 so that you have a technical report, from an A2LA accredited lab, in your Technical File.

It’s also helpful to read the “Note 2.1” that is in the bottom of the grid square that lists EN 60950-1. See below.

So, our advice is that if you have a product to send now and it was tested to the current version of EN 60950-1 then you can do it. However, expect to be questioned about it (by your EU customer or maybe even in customs) and it is probably a good idea to schedule testing to EN 62368-1, soon. We expect a lot of last minute EN 62368-1 projects in Q3 and Q4 of 2020.

Have a question or a comment? We can be contacted via this link. We can be reached by phone at 877-405-1580 and are here to help you.

Don’t stress about any of this… call F2 Labs!

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RoHS 3 – (EU) 2015/863 – Some FAQ’s

Now that we have been under the ‘new’ EU RoHS for a few months I thought it would be a good time to write a brief article to cover some of the most commonly asked questions.

  • What changed? RoHS 2011/65/EU restricts six substances. (EU) 2015/863 adds four more substances to this list. The original six substances are four heavy metals (including lead, not just lead) and two flame retardants. (EU) 2015/863 is an amendment to 2011/65/EU which added restrictions on the use of four phthalates.
  • What are phthalates? Phthalates are also called ‘plasticizers’ These are chemicals used in plastics to make them more flexible.
  • Does everything have to be retested to prove compliance? Not necessarily. Parts that are made of metal, 100%, have no phthalates. Most manufacturers have known about this amendment since it was introduced, four years ago, so chances are your products need new documentation but not new testing.
  • Since (EU)2015/863 is an amendment to the RoHS Directive 2011/65/EU then isn’t a claim of compliance to RoHS 2011/65/EU also a claim of compliance to (EU)2015/863? That can be a question that is subjective, based on a few other “ifs”. For example, if the document claims compliance to RoHS 2011/65/EU and lists only the original six substances then we would not accept this (F2 Labs performs many EN 50581:2012 reviews for our customers). However, if the document indicates compliance to RoHS 2011/65/EU, while not indicating the list of restricted substances, and it is signed & dated past July 22, 2019 – we would probably accept it.

There are a few nuances to RoHS and we can help you with this.

We can be contacted via this link. We can be reached by phone at
877-405-1580 and are here to help you.

F2 Labs is here to help.

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Translations and CE marking

This is an often-asked question, “Do I need to translate the manual for the EU and what do I need to translate?”

The answer is everything that is needed top assemble, safely operate, maintain, and eventually dispose of the equipment must be translated.

The EU changed the requirements for translations with the 2008 New Legislative Framework  (also called the 2008 NLF or just NLF). Several new CE marking Directives resulted from this including the below, though not an exhaustive list:

With these new Directives came more precise definitions of some terms and an alignment of requirements between the Directives. Prior to the 2008 NLF it was common to see differing requirements for the same document from Directive to Directive. For example, the formats for the declarations of conformity differed from one Directive to the next. The EU attempted to change that with the NLF and in addition to streamlining, they also tightened-up definitions, including the definitions and responsibilities of three classes of economic operators:

  • Manufacturers
  • Importers
  • Distributors

This article focuses only on the translation requirements as concerns manufacturers. In plain English: if you are a manufacturer in the United States and you want to send a product to the EU then you will need to translate everything associated with it into the native language of every country you send it to.

Oftentimes I will break this down and document it for a customer who asks. Today I was asked again and decided to lift that information from the email and place it in a blog article here for future reference. In this case the customer has a product that is in the scope of the Radio Equipment Directive 2014/53/EU and asked how much material (instruction and operation manuals, maintenance manuals, quick start guides, etc.) needs to be translated.

Below is the response. Documented in the response is the requirement in the Radio Equipment Directive 2014/53/EU, the explanation of Article 10 (8) in the RED guide, and section 3.1.4. from EU Blue Guide to Product Rules, which is referenced in section 2.6 (j) from the RED guide.

See the RED 2014/53/EU, Article 10 (8.)  –

Article 10

Obligations of manufacturers

8. Manufacturers shall ensure that the radio equipment is accompanied by instructions and safety information in a language which can be easily understood by consumers and other end-users, as determined by the Member State concerned. Instructions shall include the information required to use radio equipment in accordance with its intended use. Such information shall include, where applicable, a description of accessories and components, including software, which allow the radio equipment to operate as intended. Such instructions and safety information, as well as any labelling, shall be clear, understandable and intelligible. The following information shall also be included in the case of radio equipment intentionally emitting radio waves:

(a) frequency band(s) in which the radio equipment operates;

(b) maximum radio-frequency power transmitted in the frequency band(s) in which the radio equipment operates.

Next see the RED guide (attached), section 2.6 (j) –

j) Instructions

Article 10.8 of the RED requires manufacturers to accompany the equipment by instructions and safety information in a language which could be easily understood by consumers and other end- users, as determined by the Member State concerned. Furthermore, they shall be clear, understandable and intelligible. The Blue Guide, in Chapter 3.1.4, provides more details on how the instructions and safety information need to be provided. These instructions shall also include information required to use the radio equipment in accordance with its intended use. In particular, this information shall include, where applicable, a description of accessories and components, including software:

(1) have an influence on the conformity of the radio equipment, and

(2) are intended to be installed or changed by the user without the control of the manufacturer.

Accessories example:

? If the radio equipment is delivered without an antenna, then the technical features of the antenna that may be used in conjunction with the radio equipment shall be provided to the user. The user is responsible to operate the radio equipment and the accessories as intended and according to the description provided by the manufacturer. These technical features of the accessories shall therefore be mentioned in the instruction manual in order to enable the user to operate the compliant radio equipment. This information could be the generic characteristics of a given antenna type or a reference to a specific antenna(s) available on the market.

Software example:

? If the radio equipment has software (such as firmware, PC controlling software) that can affect its compliance with the Directive and the manufacturer intends and offers the possibility to the user to freely change it or modify it, then the software should be named in the instruction manual so that it is possible for the user to put a compliant radio equipment into operation. The manufacturer can decide the format of the description of this software as long as it can be identified.

On the other hand, if the radio equipment has software that can affect its compliance with the Directive but the manufacturer does not intend to allow the possibility for the user to change it or modify it, then no information has to be provided in the instruction manual. This is often the case of “software updates over the air” where the new software is installed under the full control of the manufacturer with no access by the user. In these cases the manufacturer ensures the installation of new software for which compliance with the Directive has been already assessed and reflected in the Technical Documentation.

With the objective of supporting authorities on their market surveillance activities, Article 10.8 of the RED requires manufacturers to accompany radio equipment which intentionally emits radio waves with information on the frequency bands and maximum output power with which the equipment is able to operate in the EU.

Manufacturers have different alternatives to fulfil these requirements. For example, any of the following options could be added to the instructions:

? the nominal frequency and transmitted power (radiated and/or conducted) used by the radio equipment, as reflected in the Technical Documentation,

or

? for radio equipment using standardized technologies, e.g. GSM/3G/LTE, indication of the frequency band in the way they are commonly well known (such as GSM 900, 1800). Where different power levels are possible, the nominal maximum power would be stated.

Next see section 3.1.4 from the Blue Guide:

As a general rule, when placing a product on the market the manufacturer must take all measures necessary to ensure that the manufacturing process assures compliance of the products and in particular:

4.accompany the product with instructions and safety information as required by the applicable Union harmonisation legislation, in a language easily understood by consumers and other end-users, as determined by the Member State concerned. Unless otherwise specified in specific legislation, instructions and safety information need to be provided, whether the product is intended for consumers or other end-users. This should include all the necessary information for the safe use of the product, to enable the consumer to assemble, install, operate, store, maintain, and dispose of the product. Instructions for assembly or installation should include the inventory parts and special skills or tools. Instructions on operation should include information for restriction of use, need for personal protective equipment, maintenance and cleaning or repair. It is for the manufacturer to determine the relevant information which should be included in the instructions and safety information for a particular product. Manufacturers have to look beyond what they consider the intended use of a product and place themselves in the position of the average user of a particular product and envisage in what way they would reasonably consider to use the product. Furthermore, a tool designed and intended to be used by professionals only might also be used by non- professionals, the design and instructions accompanied must take this possibility into account;

Our guidance and advice, based on the above and other similar documentation for other CE marking Directives, is that the manufacturer must make a translation of everything.

We can be contacted via this link. We can be reached by phone at
877-405-1580 and are here to help you.

F2 Labs is here to help.

Posted in ATEX Directive 2014/34/EU, CE marking, Consulting, EMC Directive 2014/30/EU, Low Voltage Directive 2014/35/EU, Pressure Equipment Directive 2014/68/EU, Radio Equipment Directive 2014/53/EU | Tagged , | Leave a comment