Having started your electronics business by doing a bit of trading on Ebay, you now want to be legitimate. In the last post, we discussed raising finance and the aversion of the banks to startups, electronics and risk (except complex financial instruments they don’t understand of course). Having raised money somehow, what other obstacles will the UK government and its bureaucratic allies in Brussels put in your way?<\/p>\n
\nFirst there is the regulation that applies to all business, some EU inspired and some completely home grown. Regulation is necessary, to protect employees, the public and the environment, but governments seem really good at over-elaborating it. These are some of the most common that you should deal with.<\/p>\n
There are plenty more regulations in the government arsenal, including Distance Selling Regulations that cover Internet trading, or environmental protection that you might need to know about. If you are intending to make PCBs for example or use some other messy process, these could easily bite you.<\/p>\n
What about regulations that are specific to electronics companies?<\/p>\n
\nRegulations that are specific to electronics are mainly inspired by the EU, but the British interpretation of them has been as bureaucratic as possible. I am not an expert on these regulations, and the only people who are talk with a nasal whine and keep coloured pens neatly in their shirt pocket.<\/p>\n
The main ones at present are RoHS (Restriction of Hazardous Substances), WEEE (Waste Electrical and Electronic Equipment) and CE marking but RoHS is being revised as RoHS2 at the moment.<\/p>\n
RoHS<\/strong><\/p>\n These are often called the “lead free directive” and mean that restricted substances cannot be included in any product sold in EU, whether it is made here or not. It is easy to comply with and clearly states what is allowed. As a new producer (or importer) you should use lead free PCBs and solder and make sure all your component or product supplies come with a statement of conformity that they are RoHS free.<\/p>\n WEEE<\/strong> A “producer” can be an importer by the way. What they actually mean is that you must clearly label all your products with your brand and include a wheelie bin symbol on them. Then you register with a WEEE compliance scheme, pay them a fee that includes EA registration, and submit quarterly data on the amount of electronic equipment you placed on UK market in that period, to the nearest Kilo. <\/p>\n In return you get a WEE producer number that must appear on your invoices. There are no exemptions for small size, just a smaller fee, therefore all those people on Ebay who import a few electronic bits should register!<\/p>\n So far, so good but if you sell direct to consumers (B2C) you need to pay an extra fee as your share of costs of local recycling centres but your WEEE compliance scheme can advise you. And don’t forget the Battery Regulations if you supply more than 32Kg of batteries per year in your products or on their own, again ask your compliance scheme.<\/p>\n Finally, there are 10 categories of WEEE, with different rules for each category and you need to decide what category fits your products. I am still unclear about exports to the rest of the EU and have never got a clear answer. There is one school of thought, mostly bureaucrats, that says you should register in every country you supply, up to 27 fees, 27 data submissions and 27 WEEE numbers, but I go with the view that a UK registration number is all you need, and our EU customers seem happy with this.<\/p>\n 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). <\/p>\n 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.<\/p>\n If your product uses mains voltage, then you will have to CE mark it and comply with the Low Voltage Directive<\/a>.<\/p>\n RoHS2<\/strong> 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.<\/p>\n 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:<\/p>\n 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).<\/p>\n Further Reading<\/strong><\/p>\n A WEEE Compliance Scheme<\/a><\/p>\n And to really let you see how bureaucratic bureaucrats can be, here is the light version of RoHS2<\/a><\/p>\n","protected":false},"excerpt":{"rendered":" Having started your electronics business by doing a bit of trading on Ebay, you now want to be legitimate. In the last post, we discussed raising finance and the aversion of the banks to startups, electronics and risk (except complex financial instruments they don’t understand of course). Having raised money somehow, what other obstacles will … Continue reading Starting UK Electronics Business – Regulation<\/span>
\nThese regulations were a nightmare to understand, and were introduced before the Environment Agency (EA), who enforce them, had even worked out how they were going to interpret them – officialdom at its worst. <\/p>\n
\nCE Marking<\/strong><\/p>\n
\nThe 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. <\/p>\n\n