How to place EEE product on the market

I went deep in the rabbit hole in order to understand the implication of selling electronic devices in the EU. Here what matters, and links for future needs.

CE

CE symbol

The symbol above is required for some of the products sold in the EU, if the product category is in one listed on the harmonisation standards of europa.eu.

Placing CE on a product determines that the product complies with all the regulations on there. You shouldn't put redundant logo on a product, a CE product is ROHS compliant, so you should only put the CE. There are other labels that may be required depending on what you are doing such as hot, or high voltage, age. Or WEEE logo (see further).

These harmonisation standards are usually pretty long but contain the details to test and manufacture compliant devices. For a "normal" electrical device plugged to a DC supply source you may only be required to apply RoHS, and maybe the EMC (RF stuff) one. The LVD, Low Voltage is actually for device between 50V and 1000V, so already dangerous voltage, likely won't need this.

If you're plugged to mains (hopefully your device and not you).

Electrocution

You should also read the Power Supply one, mainly dictates the efficiencies required for conversion between mains AC to lower AC/DC.

RoHS

The RoHS directive, accompanied with the IMO more important module A of Annex II to Decision No 768/2008/EC, great name if you ask me, rolls on the tongue, describe the actual stuff you need to do.

Read chapter 7, that where the important information is, it's half a page long. Here is a description so I don't forget :

So if you are like me, this doesn't seem too complicated. Well now let's go in Module A, and see what actually is required.

Module A, Annex something something...

You need some simple things :

Ok, now that is alright. It's achievable. Maybe a few days of extra work. Sadly it's not finished, and the hard part is not to do it once, it is to maintain it.

Ok. Why is this the complicated part when developing EEE products? It's pretty simple, you can't trust non-EU manufacturer, as it is the importer that is responsible. So if you get your PCBs made in China, which if you are not, you can't be competitive. I like Euro Circuit, but it's 5x as expensive. So if your PCB (w/o BOM), is 50 cents, it will be a 2.5 at volume in the EU. Then you need to import ICs and other components, there are no FABS in the EU, and you can't trust your asian manufacturer to sell you what you asked, to be fair you can't trust EU manufacturer either, but it's about responsability. If you import from Asia, you are responsible for compliance, and if you buy from an EU the manufacturer, they are, it's a game of hot potato.

Any work around. Yes there is one. Trust but verify, ensure that what you get is what you paid for. This has a cost of course, verifying RoHS compliance through analysis of homogenous material. In the end, it's a risk reward calculation, how likely is will you receive bad quality from that manufacturer, who else uses them, how big are they, and how trustworthy.

Also add a batch number of the device. So in case something goes wrong, it's at least traceable. I don't think it's written on there, but it's good advice.

WEEE

Oh you thought it was finished, you're in for a treat.

WEEE

Have you seen this symbol before ? Probably. Probably never cared about it right ? Quite funny when you actually read the directive.

If your product has to be RoHS compliant, which for 99% of the case it has to be, it needs to have the WEEE symbol. Exception that could concern you are :

Now the annoying piece is that it gets very local, at least more local. And it will differ from country to country. So this will be more French focused here, but similar will apply in other places.

DEEE

It's called DEEE in French. And the agency responsible is the SYDEREP. I like the website, only HTML and JQuery, no overloaded REACT app, moving parts, freaking simple, and probably cheap to maintain.

But you are also required to recycle the items, and well if you have time between the admin, legal, cad / electrical / software / polymer engineering, accounting, project management, distribution, and production, you can also become a recycler.

The main thing is you have to pay an eco-tax. Fine with that frankly, it's not much usually, but you also have to report the number of items sold quarterly. Also you need a contract with a recycler so that you actually don't have to manage the recycling of the product, and they can manage it for you. Someone like ecosystem.eco or (Ecologic)[https://www.ecologic-france.com/]. Not much choice really, and I have no clue how much the fixed cost actually is.

Honestly I am not sure what it actually entails to recycle your parts. I don't know what the actual cost of doing business with those organizations, and when there is no price displayed, it usually means it is too expensive.

Symbol

When you've gone through all the requirements, you should now be able to place the symbol. Instead of the black bar, you can add the production date as ISO 8601 YYYY-MM-DD.

Polymers

I'm not sure about the regulation here, but I'm pretty sure you need to put the Resin identification code on your plastic things.

Packaging

The symbols I talked about, should be put on the product if possible, and if not should be put on the packaging. Don't forget the recycling symbols on it. You probably also need a barcode on it. I have to read more about this.

Closing notes

I was thinking of selling a few products, as it's easy to design and manufacture some products, but the difficulty is that the system is not made for small producers, these regulations work for big manufacturers selling 100 thousands items, not for individuals who want to sell 20 boards and iterate over ideas quickly.