Starting UK Electronics Business – Regulation

CE Marking

At present you may not need to CE mark your products, but this will change with RoHS2. The assumption was that nobody would buy products without a CE mark so you would have to use one, but the public don’t understand or care about it. If you do add a CE mark, your main requirement is to make sure your product is immune to electrical noise, and doesn’t emit electrical noise (EMC Directive).

There are labs to test your product if you need to, and plenty of advise on how to design your stuff to comply. There are also lots of exemptions, such as customer is going to modify it, training, part of a larger system etc. but you will need to include a statement explaining this with your product if you use an exemption and CE mark it.

If your product uses mains voltage, then you will have to CE mark it and comply with the Low Voltage Directive.

RoHS2
The bureaucrats decided that they needed more red tape, so they have conceived RoHS2, which doesn’t change the fundamentals (banning restricted substances) but adds layers of documentary proof that must be kept for up to 10 years, and puts more burdens on the producer (importer) to prove compliance. It also means that the CE mark will become effectively a RoHS compliance symbol, so you will have to add a CE mark by law.

When it comes into force depends on what category your products fall into, but the major change that could affect producers most is Trading Standards are getting in on the enforcement act. So, expect lots of competitors to shop each other! As you cannot look at a product and see if it is lead free, you will have to prove that it is, guilty until proven innocent.

In conclusion, these regulations are just like Health and Safety, not a problem until something goes wrong and the authorities jump on you. They also suffer from the same mindset of obscure jargon, constant references to other rules, laws and standards, and just nerdiness. The basics you should do are these:

  • Join a WEEE compliance scheme and check with them on batteries and B2C requirements, and add WEEE registation number to invoices
  • Make sure your own products are lead free and be able to prove it and get documentary proof from suppliers that their’s comply with RoHS
  • Add a system that converts sales into weight of product to simplify quarterly WEEE returns or just guess
  • CE mark, brand and add wheelie symbol to your products. This will mean that your product also has to comply with EMC directive!
  • File all RoHS proofs etc for 10 years

This is not an exhaustive list, and other regulations cover power supplies, wireless, food related or medical or military devices and exports to USA (FCC regulations).

Further Reading

A WEEE Compliance Scheme

And to really let you see how bureaucratic bureaucrats can be, here is the light version of RoHS2

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