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Gary Nevison
Gary is the Head of Legislation at Premier Farnell and is heavily involved in the website content and press work for the company. He also maintains active blogs in the UK, US, India and China.
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May i know when you mean legal, does that include patent or just legislation question?
I have some questions regarding required certifications..
1.) If I am designing / constructing extremely low volume (less than 10, usually 1) kit for a client (this is usually a piece of specific test equipment they require) do I need to have these go through the full certification procedures ? (I understand that critical issues like the low voltage directive must be met - but I am wondering more about EMC compliance)
2.) What is the legal situation with regard to supply of self-assembly electronic kits? Presumably RoHS must be complied with (in terms of supplied components / PCB's etc) but what about other directives? I see kits for mains power supplies - those I have seen carry safety warnings - but is this sufficient? The supplier of the kit has no way of knowing if the constructor will assemble the kit correctly, or whether it will be a LVD failure and potentially dangerous.. Likewise EMC - Even if an assembled kit is tested and complies, the supplier has no way to ensure that the constructor will build the kit in a way which complies.
Despite being competent, all equipment I build uses an external certified PSU, so that I can be sure of meeting the LVD without having to incur the expense of certification for this - I also do my own crude testing for compliance with the other directives - I cannot be 100% sure of full compliance, but for a special single piece of kit I may sell for £1000 I cannot afford full certification.
Hi
I am not an expert on EMC or LVD and asked our consultant for his thoughts. See his comments below.
If you require a more comprehensive analysis of your situation then I am happy to put you on to him direct, but he may charge for advice.
"EMC - our recommendation is that one product, ideally a worst case as far as EMC is concerned, should be tested. Then any similar products should also comply and so do not need testing. It is also not necessary to test every design as EMC legislation requires self declaration. For kits, I would guess that the supplier can guarantee EMC compliance only if their customer follows their instructions exactly and compliance is the responsibility of the person who constructs the finished product.LVD - this only applies to a finished product but is also a self-declaration directive and third party testing is not a requirement. The product must comply of course and this is simplest by following one of the EN standards. This must be recorded in a technical file. Supplying kits though is not the same as supplying finished products"
Gary Nevison
Koh, thanks for your question - I believe any legislative question, but if you have patent questions you can post those also.
Hello Gary,
I am currently working in North America within the US Federal Government Sector, and this area being exempt from the RoHS legislation, do you see the day that they will no longer be exempt?
Thank you
Dan Olguin
Hi Dan
If you are referring to military then nothing is on the radar at present.
However, with three sets of EU RoHS proposals in less than 12 months there are many
changes likely.
The proposed category 11 will cover all EEE not in categories 1 to 10!!!
However, exemptions are moving very slowly at present so a less significant rate of change.
Gary
