As electric vehicle (EV) technology continues to evolve and grow and become more commonplace, the insertion of ethernet technology for data communication in those systems will also continue to evolve.
As with any electric function, but especially in the case of EVs, where the functions of the components/systems are critical to operation, ESD protection is extremely important. Two standards were published in 2016, 100BASE-T1 and 1000BASE-T1, which were adopted to serve specific automotive requirements as it pertains to electromagnetic compatibility (EMC).
IEEE 802.3bw and IEEE 802.3bp are also utilized to cover some of the ESD requirements, which include the robust +/- 15k V contact ESD discharge for unpowered devices with a minimum of 1000 discharges.
F2 Labs can assist with the ESD testing that is required for electric vehicle and more.
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As more and more electric vehicles (EVs) continue to be utilized both by the public and by government agencies to help reduce our carbon footprint and reduce greenhouse emissions, the infrastructure used to power these vehicles continues to grow.
An un-welcome side effect of this, is that Wireless Power Transfer Systems (which relies on switching frequencies that generate interference in the AM radio bands), can interrupt AM radio broadcasts in several frequency ranges.
EMI interference can be mitigated by using shieled cables, installing filters, and perhaps utilizing ferrite beads as required, however because of the nature of wireless charging technology (which transmits power through the air as a magnetic field), these mitigation efforts cannot be utilized.
If you are the manufacturer of equipment and need assistance with EMI/EMC testing for either wired or wireless platforms, reach out today. F2 Labs can assist with many compliance needs for FCC, Industry Canada, as well as CE Mark evaluations.
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On November 14, 2022 the UK announced that use of the UKCA Mark (for Great Britain) is to be postponed an additional two years until December 31, 2024. Previously, mandatory use of the mark and scheme was supposed to be active as of January 1, 2023.
Consequently, the CE Mark will continue to be accepted for most product categories, including product that fall under the UK Radio Equipment Regulations and UK EMC Regulations.
F2 Labs continues to be at the forefront of assisting clients worldwide gain acceptance and ensure proper conformity to applicable Directives, including Low Voltage Directive, Radio Equipment Directive, EMC Directive, Machinery Directive and ATEX Directive, amongst others.
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On May 31, 2022, a new version of KS C 9814-1 was issued and is applicable to products that fall in the category of household appliances, electric tools, and other similar apparatus. Examples of equipment that fall in this category include air conditioners, personal and beauty care devices, electric fences energizers, and products that utilize IPT Technology, or Inductive Power Transfer Technology (devices that make it possible to transfer power and digital data without mechanical or electrical contact).
KS C 9814:2022 is a modified version of CISPR 14-1:2020 and changes have been made to the previous edition, KS C 9814-1:2020(CISPR 14-1:2016). The changes mainly have to do with increased emission requirements that deviate from the CISPR standard.
Reach out to F2 Labs today if you have products that are entering South Korea and require EMC testing. We are well equipped and accredited to assist you in this marketplace.
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In the emerging technology field of Automated Driving Systems (ADS), the European Union Commission has recently published requirements and rules to help manufacturers of these systems ensure the overall safety of automated vehicles.
European Union Regulation 2022/1426 was published in early August and over the course of four specific Annexes, details regulations and specifications that need to be followed in order to gain type-approval in the EU.
These four Annexes detail:
The information needed to be supplied by ADS manufacturers in support of their type-approval request
Under various scenarios and conditions, the performance requirements and regulations specific to ADS are outlined
Expansive detail on the review process officials will use to assess and approve ADS for compliance, including scope of testing and reporting
Specific requirements that are to be followed in drafting supporting documentation and actual drafting of the type-approval certificate once compliant test data has been established
As this technology continues to emerge and take off, these regulations will most assuredly continue to evolve and test labs will continue to add to their capability to assist manufacturers of these products.
The regulation in it’s entirely can be found here.
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You can contact us at this link. Our phone number is 877-405-1580 and we are here to help you.
We evaluate your device and keep it on autopilot, painlessly.
The RoHS Directive 2011/65/EU+(EU)2015/863 started life in 2002 as the RoHS Directive 2002/95/EC. It has changed over the years, adding substances and exemptions, and all affect the compliance of your device. Likewise, manufacturers and suppliers often change both the components and materials that comprise the parts you buy from them. And they do this with no obligation to alert you.
The REACH Regulation (EC) No 1907/2006 changes every six months. ECHA always adds substances to the restricted list. They never remove substances from the list which can make it excruciating for you and your staff. Presently there are 224 substances of very high concern, also called SVHC’s. That list is here: ECHA SVHC List and it will change again in either December 2022 or January 2023. Testing for REACH and RoHS is very expensive and it can cost thousands of dollars per part, depending upon what it is and how many materials make up the part. For example, a part made with plastic and metal can easily cost $3,000 to test. Just for one part. Now, multiply that against the number of parts a manufacturer like Molex, Murata, Vishay, or TE Connectivity produces. It is easy to see that this is a monumental task for these companies that never ends. You can imagine that once they clear a “list” of SVHC’s… right around the corner another, new list is published and the testing starts all over again. Then, add in that these companies likely have their own supply challenges and it is apparent that the RoHS and REACH status of these parts changes constantly.
What happens if the composition of a part changes?
Manufacturers can change how they make their parts. Suppliers can change who they buy a part from. In both cases they are not obligated to indicate to you, the electronic device manufacturer, what changes they made. In a worst-case example a supplier can sell you a machine screw made of RoHS and REACH compliant steel and use a descriptor and part number for that screw that is unique to their system. Let’s call it, “10 mm screw, pn 123456”. You could make orders for that screw over the years, always ordering their part number 123456, without knowing if that supplier is still using the same screw that was originally evaluated for RoHS and REACH compliance.
I routinely see examples of parts that were compliant at one point in time and then are not-compliant the next time the part is used in a build under review, and vice-versa. When this happens I see the part used in the new build — but I also see that the part is used in a build by a customer that submitted the device for review in the past. Below is an example.
However, when this part was added to another assembly under review it was researched again in 2021 and we uncovered that TE Connectivity changed the build. As of May 27, 2021 the sole SVHC was eliminated from the build:
87224-2 is a popular part and crept into yet another build under review at F2 Labs this month. Reviewing the current data, we see that it has maintained its status as devoid of SVHC content:
Why is this important to you?
There is no one obligated at these companies to go through your past orders and tell you if a part you ordered a year ago now maintains the same RoHS and REACH status when you make a repeat order. You need to do this and it is your responsibility to alter your build(s) and or product documentation if there are restricted substances added into any of the parts used in your machine. No matter how insignificant. Even product labels made out of paper are in scope.
How can F2 Labs help you with this?
F2 Labs is a product safety and EMC test laboratory and we assist our clients with nearly all compliance requirements for global marketing and sales. We started offering RoHS services in 2014 and added REACH a few years later. We started these services because they are legal requirements and oftentimes our customers’ customer in the EU is unaware of these laws. We load your device in our system and can maintain the integrity of the build in an ongoing basis for products you make over and over. We can also perform a one-time RoHS and REACH evaluation for a custom product you are only making once.
Machinery, control panels, and medical devices are not excluded. RoHS and REACH apply to all equipment with electric function and that includes commercial, industrial, and medical equipment. REACH also applies to non-electric products. They are not restricted to consumer goods.
F2 Labs tracks down the EU RoHS and EU REACH (and we can do this for California Prop 65 and California RoHS also) status of each and every part, terminating with a report to you that indicates the compliance status. We can also tell you which of your suppliers responded and when, who ignored the request if that happens, and most importantly – the parts that are not compliant. The EU included teeth in these laws. They can fine you per device, make you pull it from the market, or even test it in the EU and then send the bill to you. You do not want to ignore these requirements, even if your customer in the EU did not mention them.
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A benefit of working at F2 Labs is that I get to see new and innovative products, straight from the bench of the inventor, and prior to general release. One of our customers, Seymour Duncan, submitted a device for us to work on and I completed the RoHS portion of the project.
I looked at the product offerings on their site during the project and immediately became interested in the after-market pickups they make for guitars. My favorite guitar is the Fender Telecaster because of… well, everything about it. The Telecaster uses a type of pickup that is very articulate but is made from one coil, called a single coil. The result is that it transmits a lot of external ‘noise’ from the surrounding area, called common-mode noise. Things like computers and lighting around the guitar can add unwanted sounds, like loud static and humming. Seymour Duncan makes a replacement set of pickups that are a type of humbucker. Humbuckers are pickups made of two coils (instead of one) which cancel a lot of that humming sound because they are wired together out of phase.
Seymour Duncan Vintage Stack Tele Pickups
Instead of aligning the two rows of coils side by side, these pickups are ‘stacked’ one on top of the other. Hence the name, “Vintage Stack Tele“. The order was placed and within a few days I received these in the mail. Since I work in sales and consulting and not engineering at F2 Labs this seemed like it would be a daunting task. After talking with the Seymour Duncan personnel during our project I learned that it is not hard to do this – and was offered help if I ran into any problems. It turned out to be as easy as he said and all I needed was a $15 soldering iron and some solder.
The Installation!
Next, I took the pick cover from my guitar and, following the included instructions, disassembled the Fender OEM pickups. No turning back now.
Ready for the new pickups.
New, installed Seymour Duncan Vintage Stacks!
Yes, it was as easy as described.
I finished the install and looked at it (and still do) with great satisfaction. Kevin at Seymour Duncan gave me the ‘nudge’ I needed to do this. Thank you Seymour Duncan.
CONTACT F2 LABS FOR HELP WITH YOUR PRODUCT.
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F2 Labs sent a notification to most of our customers regarding some new requirements pertaining to battery cells and battery packs in listed products.
What does this mean?
It means that there are more stringent rules regarding batteries and this will affect your listing if and when you need to revise that listing for any reason. Battery testing can be onerous and expensive. As a side-note, I googled the definition of ‘onerous’ before I used it in this article. See below.
Yes… this fits. We address battery requirements on a daily basis at F2 Labs. That word is an accurate one-word description of the battery testing you will be stuck with if you have planned to use an unapproved or not-suitably-approved battery cell or battery pack in your device. We have had some flexibility to accept batteries in products undergoing US and Canadian Listing Evaluations at F2 Labs in the past. Now OSHA is tightening the requirements, but we can still help you through the process.
Likewise, for CE marking projects, we have some flexibility to accept approved batteries. And we have seen everything from properly approved batteries with test reports to the appropriate standard from accredited labs, batteries with questionable test reports that look like they were drafted in a broom closet, to batteries with no testing whatsoever.
The best time to address this is during the design phase of your project. We call this, “before you start cutting steel,” but you get the idea. Did you know that F2 Labs can provide a design review that can catch potential problems like this prior to sending your device in for testing? We assign an experienced test engineer to review your complete build on paper prior to the build. This can put an end to costly delays to your project by alerting you to unapproved or not suitably approved components, like batteries, in your build before you start making the device.
CONTACT F2 LABS FOR HELP, THIS IS WHAT WE DO.
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You can contact us at this link. Our phone number is 877-405-1580 and we are here to help you.
MY SUGGESTIONS AFTER REVIEWING HUNDREDS OFPRODUCTS
F2 Labs assists our customers with compliance issues for many markets across the world. We test equipment in our labs for electrical and mechanical safety & EMC / radio compliance in our three US-based accredited laboratories. But, testing is only part of your compliance process. It means nothing if the rest of your obligations are not met. The minutia of a properly prepared EU declaration of conformity and a correct Technical File with the appropriate documentation are equally important. And RoHS.
If your product has any electric function then chances are that it is in scope of the RoHS Directive 2011/65/EU, including its most important amendment; (EU)2015/863 – commonly called “RoHS 3” or “RoHS 10”. RoHS means restriction of hazardous substances and limits the amount of four heavy metals, two flame retardants, and four phthalates allowed in electrical products.
WHAT RoHS, RoHS 2, RoHS 3, AND RoHS 10 MEAN?
First, let’s define the terminology. RoHS 2002/95/EC was the original RoHS Directive and covered the original six substances (four heavy metals and two flame retardants). RoHS 2002/95/EC was not a CE marking Directive. It was largely ignored and RoHS 2002/95/EC was commonly referred to as “RoHS“.
Next, RoHS 2011/65/EU became effective in 2013 and brought some significant changes. Namely – it was required for CE marking and that includes required reference on the EU declaration of conformity. However, it’s applicability was phased-in and since many types of industrial and medical equipment were part of the phase-in process… it was also largely ignored until about 2017. RoHS 2011/65/EU is commonly referred to as “RoHS 2“.
Finally, many amendments have been added to RoHS 2011/65/EU and most of those deal with specific exemptions to the substance level restrictions. For example, a brass part may contain up to 4% lead content. (EU)2015/863 is the most important amendment and added four additional substances, the phthalates. These are chemicals used in plastics to make the plastic more flexible and soft. They are also dangerous to the human body. The additional phthalate restrictions were enforced starting in July 2019 and, by product category, fully effective on July 22, 2021. RoHS 2011/65/EU combined with (EU)2015/863 is alternately referred to as “RoHS 3” and “RoHS 10“. RoHS 3 because it effectively became the 3rd RoHS and RoHS 10 because it restricts ten substances. However, technically, it is just an amendment to RoHS 2011/65/EU. Therefore a claim of RoHS compliance or even a claim to only RoHS 2011/65/EU is a claim of compliance to RoHS requirements, including all applicable amendments.
Equipment in scope of the RoHS Directive
RoHS COMPLIANCE – A LITTLE MORE DETAIL
We evaluate RoHS compliance for our customers’ products by researching every item on a specially prepared BOM (bill of materials). Every individual item must be included on the BOM and each of these parts are then evaluated for compliance. That includes non-electrical parts like bolts, screws, enclosure materials, plastic parts, labels, and even the paint or coating. This is because if your device is in scope of the RoHS Directive then each part in the build (except a few exceptions like packaging, non-electric consumables, and batteries) must individually comply with the substance level restrictions. Each piece individually.
For example, since lead (Pb) is restricted to 0.1% by weight then each individual piece of your device may not exceed 0.1%. It does not mean that you can use a piece of metal in your device that is 50% lead, but a tiny amount (less than 0.1% of the total weight of your device). For example – if you make a drill press that weighs 1,200 pounds and on the PCB you use a pin that weighs one gram comprised of 0.25% lead… you are not in compliance. 1 gram = 0.002205 pounds. 25% of 0.002205 pounds is 0.00055125. This equals 0.00046%, well below the 0.1% restriction level. But, the restriction level is part-by-part, not against the weight of the whole device. The logic for this is that if you have some substance in a part that is commonly touched, let’s say a button, not a pin buried in the machine on a board, there is a danger to the operator.
THE SUGGESTIONS FOR YOU
Now that we have set up the what and why let’s discuss the how. How do you make sure that by the time your BOM reaches my desk I will go through it and place a check mark next to each part and deliver a final, compliant Technical Report to EN 63000:2018 instead of a discrepancy report showing non-compliant parts?
Suggestion 1
Do not buy any electrical components that are not name-branded. Period. When I have to search for your fuse or cable on a site that also sells cheap socks, bird-food, and coffee filters – and delivers them in the same box – it is almost a certainty that there will be no RoHS compliance documentation, anywhere, for that part. That will stop your project cold.
Suggestion 2
Select for “RoHS compliance” when looking for parts on popular supplier sites like Digikey, Mouser, and Newark. We have no relationship or communication with these three companies.
Suggestion 3
No hardware manufacturer provides RoHS compliance information, that I have seen, like McMaster-Carr. The RoHS information must be collected individually but in my experience it is constantly updated on that company’s website. We have no relationship or communication with McMaster-Carr.
Suggestion 4
Using non-approved assemblies (like motors, power supplies, wireless modules, pumps, etc.) without suitable RoHS compliance will cost you, big. Think of this scenario… you pass all of the electrical and EMC/radio testing performed on your device but the motor in your product has no RoHS compliance information. At this point you are left with a few, equally terrible options:
Pick a new motor, and repeat (at substantial cost) most or all of the compliance testing you just passed.
Pay for a RoHS evaluation on the motor (which will be a completely new evaluation, with the same cost as an evaluation of your entire device… remember, a motor could have hundreds of parts).
Pay for laboratory RoHS testing of the motor. This is not really an option… that could cost $50,000 or $75,000, or more.
Consider this regarding a non-RoHS compliant part that you have tested: you will have to then buy enough parts from that same lot to finish your build because you probably have no control over the materials used in another manufacturer’s device.
Suggestion 5
Specify RoHS compliance, through your purchasing department, for all parts used in any EU build. Catch it on the front-end and you will reduce costly delays on the back-end.
Suggestion 6
We supply very specific instructions for the preparation and submission of your BOM. Please read and follow these instructions. Please call me, directly, with any questions. My direct line is (301)368-2582 and I always answer my phone during business hours unless I am at lunch or I am talking to someone else
CONTACT F2 LABS FOR HELP, THIS IS WHAT WE DO.
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A lot of our efforts at F2 labs are spent determining the applicability of different regulations to our customers’ products. We help you find out what is applicable and then we suggest the best, fastest, and most cost-effective way to claim compliance. This is a real-life example of how we do it.
Next, see the definition of ‘machinery’ in Article 1., (a). That definition is in Article 2, (a) –
Let’s focus in on Article 2, (a), (5th indent) –
This means that equipment can be in scope of the Machinery Directive if it has moving parts under human power, but only if the function is lifting. So, think of it this way — a bicycle is not in scope, but a hand-cranked hoist for lifting livestock is in scope.
The European Commission sends out a list, every Friday, to show some of the products that have either been stopped in customs or pulled from the market. There are many more products that are pulled, but these are the products categorized as extremely dangerous. I look at this report every week and I look at every mechanical and/or electronic device. I was very interested to read the details of Alert number A12/00729/22 from today.
This is a standard automobile jack that many of us have used. Notice that the alert references EN 1494. That link goes to the Estonian source for EN standards. This organization is highly recommended if you are looking to purchase EN standards. They are always in English and usually for the lowest cost. Yes, you can use EVS-EN 1494 to evaluate a jack for CE conformity to the Machinery Directive for all of the EU – not just for Estonia.
See the scope of EN 1494 below –
Further down in the EN 1494 scope section we see this –
Hmmm. I don’t know about you, but this jack looks exactly like the jack delivered with every vehicle I have owned. This means that if the jack is purpose built for a car manufacturer to deliver with their cars then it does not apply. But, that does not necessarily mean that the Machinery Directive is not applicable. It just means that you cannot use EN 1494 to show conformity with (compliance) to the Machinery Directive.
I would be willing to bet that jacks delivered with new vehicles are under a different regulation. That will not be investigated for this article. Confused? Here is another consideration – if Honda or BMW began buying these jacks for their new cars then those jacks would be excluded from EN 1494, but the very same jacks packaged and re-branded on a shelf in an auto-parts store would be in scope.
This jack manufacturer should have a Technical File that includes an evaluation to EN 1494 since this particular model is in a box and on a shelf, presumably. Also, the only CE marking Directive for this device is the Machinery Directive. RoHS is excluded because there is no electric function. The EU REACH requirement is also applicable, but it is not a CE marking Directive.
IF I HAD TO GUESS – THIS IS WHAT HAPPENED HERE…
Why did this product get flagged? Why are we seeing this alert? If I had to guess (and this is all it is, a guess based on years and years of experience): the jack failed and either property or a person was hurt. The authorities became involved and made a request of the Technical File. Then, (likely) it was discovered that the product was not compliant and there was/is no technical report to show compliance to the Machinery Directive 2006/42/EC, including no report to the applicable harmonized EN standard, EN 1494.
WE CAN HELP YOU TO DETERMINE THE SCOPE OF YOUR PRODUCTS
This is what we do. We can work through the use, application, and construction of your equipment to determine the appropriate compliance path.
Want to discuss your project with us?
We can be contacted via this link. We can be reached by phone at 877-405-1580 and are here to help you.
