So You Need a Field Evaluation?

So, you’ve just had the pleasure of hearing from an Authority Having Jurisdiction (AHJ) or an electrical inspector, and their message was something along the lines of: “You’ve failed your inspection!” or “Your equipment needs a ‘UL or CSA Certification!’” Or maybe they dropped the “UL/CSA Certified” or “UL/CSA Labeled” bomb on you. Don’t panic! We’ve got you covered. Whether it’s a UL or CSA sticker, a fancy certification, or just a quick “You’re good to go!” stamp, we’re here to make sure you can flip that switch, fire up the equipment, and move on to the next project without breaking a sweat.

Now, let’s break down what those “UL” and “CSA” terms actually mean. When someone drops “UL or CSA Certification” into a conversation, what they’re really asking is that your equipment undergoes a little makeover to meet those lovely government guidelines for installation and use. The AHJ or inspector isn’t specifically demanding Underwriters Laboratories (UL) or CSA Group (CSA) to do the honors, but they do want your gear to get a golden ticket from an OSHA-approved NRTL (National Recognized Testing Laboratory). That means you can choose from a smorgasbord of labs to get your equipment certified to meet UL and CSA standards. So, no need to get married to just UL or CSA — you’ve got options, my friend!

If your equipment is currently going through a mid-life crisis and has no label (aka the dreaded “unlabeled equipment” status), leaving you stuck in production limbo and unable to hand over your shiny new machine to your customer, fear not! F2 Labs is here to save the day. We’ll whip up a quick quote and send out our skilled engineers faster than you can say “Field Labeled.” We have three handy U.S. locations ready to deploy our Safety Engineers at lightning speed. And, because we’re pros, we’ll gather all the info we need from you beforehand, so we don’t waste time (or your money) with unnecessary second visits.

Bottom line: You handle the work, we’ll handle the certification. Let’s get that gear labeled and let you get back to the important stuff — like counting all the cash you’re going to make now that your equipment is up to code.

CONTACT F2 LABS FOR HELP, THIS IS WHAT WE DO.

Want to discuss your project with us?

You can contact us at this link. Our phone number is 877-405-1580 and we are here to help you.

Posted in CE marking | Comments Off on So You Need a Field Evaluation?

How to Navigate California Proposition 65

Almost anything being sold in California may require a Proposition 65 warning. Proposition 65 is a California law titled the Safe Drinking Water and Toxic Enforcement Act. The law was put in place to protect consumers and notify them if the product contains hazardous chemicals.

The Prop 65 list identifies 900+ risk categories, and the manufacturer must identify parts listed for male and female reproductive harm, cancer, and mutagenic (birth defects) risks. Prop 65 is only required for parts that can be touched by users or maintenance personnel.

Prop 65 applies to products sold or distributed in California. It does not matter where the product is manufactured – if it ends up in California, Prop 65 applies. Law firms can and do send staff down aisles at stores and wipe parts of a product that can be touched. This is called a “wipe test.” If they wipe something in the store and it comes up with Prop 65 substances in it, and it has no corresponding warning for the substance detected, they will send it out for testing. The manufacturer can be fined up to thousands daily, per occurrence, until the product has been removed from the market, or a warning label is placed.

Companies must warn users if their products contain any of these 900+ substance risks. If your product does not contain any such substances, there is no need to include a warning, but you must be sure. The warning label must be placed on the product. A warning may be placed on the packaging if the product is too small to carry a label.

F2 Labs can assist with a Prop 65 evaluation and in almost all cases we get through it without testing.

CONTACT F2 LABS FOR HELP, THIS IS WHAT WE DO.

Want to discuss your project with us?

You can contact us at this link. Our phone number is 877-405-1580 and we are here to help you.

Posted in CE marking, Prop 65 | Tagged , , | Comments Off on How to Navigate California Proposition 65

Breaking Down California’s New Proposition 65 Labeling Guidelines

The Office of Environmental Health Hazard Assessment published regulatory changes to the short-form warning label requirements in 2025. The changes will affect the short-form label requirements, including limitations on when they can be used, updates to the required language, and strict formatting guidelines.

Because of the stricter requirements, companies must investigate their supply chains to identify whether their products or components contain chemicals listed under Proposition 65.

Previously, short-form warning labels allowed a simplified format with a generic warning statement, “WARNING: Cancer, Developmental Toxicity, Male Reproductive Toxicity, & Female Reproductive Toxicity – www.P65Warnings.ca.gov.” The new short-form warning must include at least one chemical name associated with the risk being disclosed, “WARNING: This product can expose you to Lead, which is known to the State of California to cause Cancer, Developmental Toxicity, Male Reproductive Toxicity, & Female Reproductive Toxicity. For more information, visit www.P65Warnings.ca.gov.”

The new regulations became effective on January 1, 2025. There will be a three-year grace period, which ends on December 31, 2027. Products manufactured before January 1, 2025, may continue using the old warning labels if they meet the previous compliance standards. Businesses must demonstrate that the products were manufactured before January 1, 2025, and the warnings applied followed the prior regulations.

Starting January 1, 2028, full compliance with the new regulations will be mandatory, regardless of the manufacturing date. All products offered in California must display the updated short-form warnings and meet the revised content, format, and visibility standards.

Example below:

WARNING: Risk of developmental toxicity from exposure to Cycloheximide. See www.P65Warnings.ca.gov

CONTACT F2 LABS FOR HELP, THIS IS WHAT WE DO.

Want to discuss your project with us?

You can contact us at this link. Our phone number is 877-405-1580 and we are here to help you.

Posted in CE marking, Consulting, Prop 65 | Tagged , , , | Comments Off on Breaking Down California’s New Proposition 65 Labeling Guidelines

The Wacky World of Exempted Devices: What You Don’t Need to Worry About

Ever wonder what kind of electronic devices the government just lets off the hook? No, it’s not your phone, though that would be nice, right? The Federal Communications Commission (FCC) has a special list of devices that don’t need to follow all the usual radio-frequency rules. Here’s the rundown on the exempted devices from Section 15.103:

  1. Vehicles and Aircraft: If you’re cruising around in a car or flying high in a plane, any digital device you use while doing that is exempt. That means your in-car entertainment system? Free to roam. However, if you can take that digital device out of the vehicle or aircraft and use it elsewhere – Part 15 applies.
  2. Utility Control Devices: Public utilities get a pass too! Their power systems, typically found in buildings or huge industrial spaces, don’t have to worry about specific tech standards.
  3. Test Equipment: Got some specialized test gear for your job? Whether it’s industrial, commercial, or medical, as long as it’s for testing, you’re off the hook for Part 15 – but may need to consider Part 18 instead.
  4. Appliance Devices: Your microwave, dishwasher, or clothes dryer? FCC Part 15, subpart B does not apply – unless they contain a wireless transmitter (i.e., Wi-Fi, Bluetooth, BLE, etc.).
  5. Medical Devices: Certain specialized medical devices (as long as they’re being used properly and under a doctor’s supervision) that don’t use wireless transmitters are good to go, however there may be requirements under 60601-1-2 that need to be considered.
  6. Low Power: Any device using less than 6 nanowatts of power is too tiny to bother with.
  7. Simple Input Devices: Joysticks and mice that don’t involve wireless transmission? They’re just chillin’ on the exempt list, too.
  8. Digital Devices Operating under 1.705MHz: Devices that do not operate from AC Power – but guess what – if your device pulls power from a wall outlet, or another device (computer, AC/DC adaptor, etc.) that plugs into a wall outlet to power the device or charge it – Part 15 applies.

Don’t mess with anything that causes interference, or you’ll be asked to stop until it’s fixed, and fines can be hefty. But hey, no pressure!

Contact F2 Labs if you’re confused about the FCC Part 15 requirements.  We’ll be happy to provide you with guidance so you can make an informed decision.

Posted in CE marking | Comments Off on The Wacky World of Exempted Devices: What You Don’t Need to Worry About

Cracking the Code: Surviving the FDA’s AI-Enabled Medical Device Guidance (With Sanity Intact)

Buckle up, folks—our favorite regulatory sheriffs at the FDA have dropped another massive rulebook, this time titled “Artificial Intelligence-Enabled Device Software Functions: Lifecycle Management and Marketing Submission Recommendations.” If you’re still awake after reading that title, congratulations! This document is essentially a roadmap for manufacturers navigating the treacherous waters of AI-powered medical devices, ensuring these gadgets don’t turn into rogue robots making wild medical decisions.

The Big Idea: The Total Product Life Cycle (TPLC) Approach

The FDA is obsessed with this Total Product Life Cycle (TPLC) concept, which basically means manufacturers should keep an eye on their AI medical devices forever—from conception to post-market babysitting. This makes sense because AI has a mind of its own (almost), evolving over time like that one houseplant you keep forgetting to water. The guidance helps companies make sure their devices stay safe, effective, and don’t decide to randomly diagnose everyone with the plague.

The FDA’s Cheat Sheet for AI Device Manufacturers

Here’s what the FDA wants you to do (besides reading their 50-page document without crying):

Build a Quality Fortress 🏰

Document everything. No, seriously. The FDA wants meticulous records of your design, development, and maintenance phases so they can check if you’ve done your homework. Think of it as keeping receipts—because if something goes wrong, they will ask for them.

Describe Your Brainy Device 🤖

The FDA expects you to spell out exactly what your AI-powered marvel does, how it does it, and why. They’re not impressed with vague descriptions like “It just works.” So, be transparent about its purpose, the AI models it uses, and how it makes its life-changing (or mildly useful) decisions.

User-Friendly or Bust 🎛️

Ever used a product so confusing that you wanted to throw it out the window? The FDA doesn’t want that happening with life-saving devices. Clear labeling, intuitive design, and interfaces that don’t require a PhD to operate are a must.

Sniff Out the Risks 🚨

AI can be a bit of a wildcard, so manufacturers need to conduct risk assessments to ensure their devices aren’t accidentally introducing new hazards. Basically, figure out all the ways your AI could go rogue before it does.

Manage That Data Like a Pro 📊

AI feeds on data like a hungry teenager, but not all data is good data. The FDA insists on strong data management, ensuring that datasets are diverse, secure, and not riddled with errors that could make the device biased or ineffective.

Keep an Eye on It (Forever) 👀

Just because your device got FDA approval doesn’t mean you can ignore it. The agency wants manufacturers to set up post-market performance monitoring—because AI loves to learn and change, and sometimes, it learns the wrong things.

Bias Alert: AI’s Not-So-Secret Flaw

One of the biggest takeaways? AI can be super biased. If a device is trained on limited data, it might work great for some people and be completely useless (or even dangerous) for others. The FDA is nudging manufacturers to catch and fix these biases before their AI devices start playing favorites.

FDA’s Golden Advice: Talk to Us Early

Rather than surprising the FDA with an AI medical device they’ve never seen before (not recommended), manufacturers should chat with them early in the process. Think of it as showing your teacher a rough draft before turning in the final essay—this can help avoid unpleasant surprises later.

Final Verdict

The FDA’s latest guidance provides a structured game plan for AI-enabled medical devices, ensuring they’re safe, effective, and not just some high-tech gimmick. For manufacturers, following these rules is the key to getting their devices approved without unnecessary headaches.

Posted in CE marking | Comments Off on Cracking the Code: Surviving the FDA’s AI-Enabled Medical Device Guidance (With Sanity Intact)

CE Marking: Your Electrical Product’s Passport to Europe

If electrical products had passports, the CE mark would be their golden ticket to travel freely across Europe. But unlike that dusty old passport you forgot to renew, CE marking isn’t just a stamp—it’s a declaration of compliance with essential EU regulations.

So, whether you’re a manufacturer, importer, or someone who just really enjoys reading about regulatory compliance (we see you), let’s break down CE marking in an amusing, yet totally informative, way.

What Is CE Marking, and Why Should You Care?

CE marking is like a VIP badge for electrical products, proving that they meet the safety, health, and environmental protection standards set by the European Economic Area (EEA). Without it, your product is basically a tourist without a visa—good luck getting past customs!

If your electrical product isn’t properly marked, it can be:

🚨 Banned from being sold in Europe
⚖️ Subject to fines and legal action
🧐 Forcibly removed from the market (probably by a very stern regulatory officer)
💸 A costly mistake that could have been avoided

So, yeah, it’s a pretty big deal.

How Do You Get CE Marking? (A.K.A. The Compliance Treasure Hunt)

Earning CE marking isn’t as easy as slapping a sticker on your product and calling it a day. There’s a process—because, of course, there is. Here’s how it works:

1. Identify the Relevant Directives

The EU has a whole encyclopedia of directives and regulations, but for electrical products, the key players are usually:
Low Voltage Directive (LVD) – 2014/35/EU (for electrical safety)
📡 Electromagnetic Compatibility (EMC) Directive – 2014/30/EU (to avoid radio interference)

Radio Equipment Directive (RED) – 2014/53/EU – (for electrical/electronic products that intentionally emit and/or receives radio waves for purpose of radio communication)

 Machinery Directive (MD) – 2006/42/EC (for electrical and mechanical safety of machinery and partly completed machinery)
🌍 RoHS Directive – 2011/65/EU (to prevent harmful substances like lead and mercury)

You don’t need to memorize these (unless you really want to impress your compliance officer). Just know that your product must comply with the applicable ones.

2. Test Your Product Like a Mad Scientist

Once you know which rules apply, you need to prove that your product won’t explode, electrocute anyone, or cause mass WiFi disruption. This usually involves:

🔬 Lab testing to ensure electrical safety and electromagnetic compatibility
📜 Technical documentation (because the EU loves paperwork)
🏷 Labeling requirements (to make sure your CE mark is legit and not drawn in crayon)

3. Create a Technical File (A.k.a. Your Compliance Bible)

Think of this as your product’s “receipts” folder—it holds all the proof that your electrical product meets EU standards. It should include:

  • Test reports
  • Risk assessments
  • Design specifications
  • The EU Declaration of Conformity (basically a signed statement saying, “We promise this product won’t cause chaos”)

Pro tip: Keep this file for at least 10 years. You never know when a regulatory official might come knocking.

4. Affix the CE Mark Like a Pro

If your product passes all the necessary tests and audits, congratulations—you’ve earned the right to place that glorious CE mark on it! But beware:

It must be visible, legible, and permanent
It should follow the official proportions (don’t get creative with the font, please)
🚫 Fake or misleading CE marks can land you in legal hot water

Common CE Marking Myths (Busted!)

🤔 “CE marking means my product is approved by the EU.”
Nope! The EU doesn’t “approve” products. CE marking means you, the manufacturer, are declaring compliance.

🤔 “I can just put a CE sticker on my product and be done with it.”
Nice try! Without proper testing and documentation, that’s CE fraud, and trust us—you don’t want to be caught in that mess.

🤔 “CE marking is only for European companies.”
Not at all! If you sell electrical products in Europe—no matter where your company is based—you need CE marking.

Final Thoughts: CE Marking = Peace of Mind

Sure, compliance can feel like a bureaucratic nightmare, but CE marking isn’t just about ticking boxes—it’s about making sure your electrical products are safe, reliable, and legally marketable.

So, before you ship off that next batch of gadgets to Europe, take the time to get CE marking right. Your customers (and the EU regulators) will thank you.

Need help navigating the process? F2 Labsspecializes in compliance testing and certification—so you don’t have to lose sleep over it. Let’s get your products CE-ready!  Please contact us at sales@f2labs.com or by phone at 877-405-1580 to get started right away.

Posted in CE marking | Comments Off on CE Marking: Your Electrical Product’s Passport to Europe

ECHA Adds Five New Substances to SVHC List

The European Chemical Agency, ECHA, added five new substances to the list of Substances of Very High Concern (SVHC) overnight.

The EU’s SVHC list expanded from 242 to 247 today. These are potentially dangerous substances that carry EU reporting responsibilities if any individual part (or any part of any part) of your product contains > 0.1% of any of these substances.

This was expected and is the regular winter (December/January) REACH update. 2024 was interesting for REACH because there were three ECHA SVHC Updates. It increased to 240 in January, 241 in July, and 242 in November. Usually there are only two: one in the winter and one in the summer. The amount of susbtances can vary each time.

What does this mean for you?

You must prepare new SCIP dossiers within six months, every time the list updates, if you are continuing to build and ship equipment to the EU. Any SVHC content > 0.1% in any part of the build will require a submission to the SCIP database. REACH, along with the Waste Framework Directive, aka “WFD,” require reporting of these substances. But, these substances are not restricted from use.

F2 Labs can help you with this. We can take your bill of materials and put this on auto-pilot for you. Our REACH (and RoHS and Prop 65) compliance work and deliverable(s) free you and your colleagues from looking for full material declarations and then scouring that against the list of 247 substances for every part in your build. We format and load your BoM into our system and then we look for the documentation and we contact your suppliers directly on your behalf.

We deliver a formatted and correct I6Z data file, ready for you to deliver with your product to your customer in the EU.

CONTACT F2 LABS FOR HELP, THIS IS WHAT WE DO.

Want to discuss your project with us?

You can contact us at this link. Our phone number is 877-405-1580 and we are here to help you.

Posted in CE marking, Consulting, REACH, RoHS Directive 2011/65/EU | Comments Off on ECHA Adds Five New Substances to SVHC List

Does Customs Really Check For RoHS in The EU?

Yes.

I get an email every week from the European Commission’s Safety Gate that lists some of the most dangerous products that were recently pulled from the market. These alerts are for products stopped in customs before they enter the market as well as products that passed customs but were later found to be non-compliant with one or more EU regulations.

The email arrives at about 8 or 9 PM EST every Thursday evening. And this week’s list of alerts contains a few products stopped for RoHS non-compliance. Below are three examples.

First up is Alert no. SR/00202/25. This electric toothbrush was discovered to have DEHP phthalates (1.7%), lead (0.34%), SCCPs (1.6%), and lead in solder as high as 61%. These substances are restricted to 0.1% per homogeneuos material, so, every little piece, even the individual bristles must comply.

This product has now been removed from the market, see below.

Next is Alert no. SR/00191/25. This is for a 12 VDC power supply that was caught with too many substances for me to list. Below is a picture of the power supply and then the reasons they stopped it.

Third is Alert no. A12/03293/24. The product is a wireless Bluetooth speaker. It has an FCCID and they claim it can be used in a shower – so presumably it has had IP Testing as well. As a compliance professional, that tells me that this product probably had a lot of testing and evaluation. It is a shame that someone’s marketing plans are ruined because one of the least expensive parts of the compliance process was overlooked.

It is interesting to note that they stopped this product for having leaded solder. There are some exemptions for lead – namely 7(a) that allows for the use of 85% lead in high-temperature solders. This is information you can glean during the design phase of your project by working with a compliance lab, like F2 Labs.

This is the current page for that product on Amazon.

CONTACT F2 LABS FOR HELP, THIS IS WHAT WE DO.

Want to discuss your project with us?

You can contact us at this link. Our phone number is 877-405-1580 and we are here to help you.

Posted in ATEX Directive 2014/34/EU, CE marking, Consulting, EMC Directive 2014/30/EU, Low Voltage Directive 2014/35/EU, Machinery Directive 2006/42/EC, Machinery Regulation (EU)2023/1230, PPE Regulation (EU) 2016/425, Pressure Equipment Directive 2014/68/EU, Product Testing, Radio Equipment Directive 2014/53/EU, REACH, RoHS Directive 2011/65/EU | Comments Off on Does Customs Really Check For RoHS in The EU?

Embracing AI in Healthcare: The FDA’s Guidance on Good Machine Learning Practice

Embracing the Future: The FDA’s Guidance on AI in Medical Devices

As we enter an exciting era of technological advancement, the role of artificial intelligence (AI) in medical devices stands out as particularly transformative. The FDA’s recent guidance on “Good Machine Learning Practice” is a crucial milestone in steering this innovation, ensuring that the benefits of AI are realized alongside necessary safeguards.

Innovation Meets Responsibility

The potential of AI in healthcare is vast. We’re envisioning systems that can analyze medical images with remarkable speed and precision or predictive tools that flag patients at risk before any symptoms emerge. However, with such capabilities comes the need for careful oversight. The FDA’s guidance highlights the importance of solid scientific foundations in the creation of AI-based medical devices.

This guidance is more than a regulatory checklist; it encourages developers to engage in thorough design and rigorous evaluation. It prompts a consideration of the complexities inherent in healthcare environments, urging creators to reflect on how their AI technologies will function in practice and respond to diverse data inputs. The focus on “Good Machine Learning Practice” is a commitment to ensuring transparency, reliability, and accountability in these innovations.

Essential Principles

A central theme of the FDA’s guidance is the necessity for high-quality, diverse datasets. The success of AI tools hinges on the data they are trained with, meaning developers must prioritize representativeness to prevent bias—an increasingly important topic in discussions about ethical AI.

Additionally, the guidance underscores the significance of ongoing monitoring and adaptive learning. In a field where medical knowledge is constantly evolving, the ability of AI systems to update and improve over time is vital. This aspect can revolutionize patient care, allowing devices to learn from new information and enhance their effectiveness.

The Power of Collaboration

What stands out in the FDA’s approach is the emphasis on collaboration among all stakeholders—developers, healthcare professionals, and regulatory agencies. By working together, we can cultivate an environment that encourages innovation while prioritizing patient safety. This teamwork is essential in navigating the complexities associated with AI in medicine, ensuring we maximize the advantages of these technologies while mitigating potential risks.

Looking Forward

The FDA’s guidance on AI is more than a set of rules; it serves as a roadmap for the future of healthcare. As we harness the capabilities of machine learning, we must remain attentive to ethical considerations and patient outcomes.

As we anticipate the integration of AI into routine medical practices, let’s seize this chance to create a future where technology and healthcare collaborate seamlessly. While challenges will arise, a commitment to thoughtful regulation and high standards can help us navigate this exciting landscape together.

CONTACT F2 LABS FOR HELP, THIS IS WHAT WE DO.

Want to discuss your project with us?

You can contact us at this link. Our phone number is 877-405-1580 and we are here to help you.

Posted in CE marking | Comments Off on Embracing AI in Healthcare: The FDA’s Guidance on Good Machine Learning Practice

NRTL Field Evaluation and Labeling

If an Authority Having Jurisdiction (AHJ) or electrical inspector has ever informed you that you have failed your inspection or that you require a “UL or CSA Certification” or that your equipment must be “UL/CSA Certified” or “UL/CSA Labeled” we can help you. F2 Labs can provide the evaluation, testing, and label you need to turn the equipment on and turn it over to your customer – and move on to the next project. 

When someone says, “UL or CSA Certification” or that your equipment be “UL/CSA Certified” or “UL/CSA Labeled”, that means your product must be evaluated to meet the government guidelines for installation and use of the equipment at that location.  In these instances, the AHJ or inspector is asking for you to have your equipment “Field Labeled” by an OSHA approved NRTL (National Recognized Testing Laboratory) and is not asking you to specifically have Underwriters Laboratories (UL) or CSA Group (CSA) perform the evaluation.  There are many different labs that can certify products to the UL and CSA standards.  You have the freedom to use a different laboratory in almost all cases.

If you have a piece of equipment that is unlabeled and it is preventing you from starting production on your line or turning the equipment over to your customer at their site, F2 Labs can quickly quote and schedule our engineers to get you exactly what you need to get moving. We have three locations in the in the US from which to dispatch our experienced Safety Engineers to perform this testing quickly. Additionally, we collect information from you and review it prior to our visit to reduce inefficient and costly second visits.

CONTACT F2 LABS FOR HELP, THIS IS WHAT WE DO.

Want to discuss your project with us?

You can contact us at this link. Our phone number is 877-405-1580 and we are here to help you.

Posted in CE marking | Comments Off on NRTL Field Evaluation and Labeling