Most categories of electrical products must bear a CE mark if you intend to sell them in the Europe. A CE mark and accompanying Declaration of Conformity is a contract between a manufacturer (producer) and the state that the product complies with the relevant regulations, such as the Low Voltage Directive (LVD), Machinery Directive and Electromagnetic Compatibility (EMC) Directive. CE compliance may simply be stated by following a self certification route, may be ascertained by using a notified body to carry out analysis and testing of a new product, or a combination of both. The Declaration of Conformity must be signed by a designated person in the manufacturer / producers company who is responsible for ensuring the product is compliant. Which route to take will be down to your individual requirements. The ‘best’ route is to submit a new product design to a notified body (a registered company that provides compliance testing) to ensure that you are fully complaint.  Alternatively you may decide that the cost of this is too high for a particular product, or the risk of non-compliance is low, and instead self certify the product.

There is no actual legal requirement for testing to be carried out for the CE mark, but you should be able to demonstrate compliance with the directives if ever required to.  In practice, outside of your distributors possibly requiring evidence of conformance for their own protection, the only other likely need to demonstrate compliance is if the health and safety executive, trading standards, etc authorities demanded it and this is actually only likely to happen if a problem has been discovered or occured.  The driving factor for many companies to ensure their products are CE compliant is down to the fact that these authorities can force you to recall your products if it is discovered they are not complaint.  They also have the power to fine and even imprison for serious cases.

There are 21+ different directives. Placing a CE mark states that your product complies with all directives that apply to the product.

To give you an idea of the costs involved, to use the BSI to provide CE marking services for a relatively typical electronic product (Low Voltage Directive and EMC compliance) would be likely to cost in the region of £8,000 to £10,000.  Bear in mind this just a rough estimate and costs will vary, sometimes significantly, based on specifics of your product.  Of this between £1,000 and £1,500 would typically be the cost to carry out the paperwork side of the work with the remainder being the costs to carry out the lab based testing.

For products that are battery powered the testing requirements are often reduced, especially if the product is targeted at industrial rather than consumer use.  A typical battery powered product will not require LVD electrical safety testing, reducing the requirement to just EMC testing for immunity (to interference) and emissions.  This can reduce the lab testing cost to around £1500 if the product passes first time and if the products application allows it to be tested to generic industrial standards (EN61000-6-2 for immunity in industrial environments and EN61000-6-4 for emissions in industrial environments) the only paperwork often required in addition to the tests is the CE declaration of conformity.  This can also often apply to products that are powered from the mains via a plug top power supply if a power supply is chosen with a valid declaration of conformity to the LVD and EMC directives from the manufacturer.  Strictly speaking the product should also be tested connected to the mains supply for electrical safety (LVD), but it is often justifiable to rely on the power supplies LVD compliance and remove this testing requirement.

If your product included wireless communications (e.g. bluetooth, DECT, WiFi etc) then it needs to comply with the Radio and Telecommunications Directive which can add a significant cost.


Waste Electrical and Electronic Equipment

2002/96/EC & 2003/108/EC

Originally listed 10 equipment categories

For apparatus within the schedule, the manufacturer must comply with the requirements.

EuP Energy Using Products 2005

Compliance mandatory in EU and applies if:

200,000 units per year (if less than then the directive doesn’t apply – product is exempt)

Significant environmental impact

Significant potential for improvement

RoSH becomes part of CE marking January 2013 (needs to be on document and in included in the technical documentation)

Restriction of Hazardous Substances

RoHS (2002/95/EC) Directive

Limits on six chemicals prevalent in EEE:- Lead (0.1%), Mercury (0.1%), Cadmium (0.01%), Hexavalent chromium (0.1%), Polybrominated biphenyls (PBB) (0.1%), Polybrominated diphenyl ethers (PBDE) (0.1%)

Limit is maximum concentration by weight of homogenous material

Basic Requirements

Put together a technical document which justifies why the product meets the essential requirements. Basic requirements:

General description – sufficient to uniquely identify the apparatus.

Evidence of compliance

An extended justification

Statement from notified body (optional)

Produce a declaration of conformity

Provide any user instructions required to use the product in a compliant way. E.g how to install the product

Declaration of Conformity

For example along the lines of “I the manufacturer of this product… Complies with these directives… Signed by someone…”  It’s a legal document stating your products compliance. You can have one document per directive, or combine them all into one document.

• Name and address of manufacturer

• Signed on behalf of manufacturer and signatory identified

• Date of issue

• Particulars of apparatus sufficient to identify it

• Numbers, titles and dates of standards by which conformity is declared (EMC, LVD)

• Certify that apparatus conforms with the protection requirements of 2004/108/EC & 2006/96/EC

Sending A Product For Testing

Before you send the product have you considered the following:

If the product includes software timers to automatically turn off, turn off the screen backlights etc do they need to be overridden?  Carrying out airborne immunity tests can take some time (over an hour) with the product in a sealed chamber.  If the product turns off the test will have to be halted while it is turned back on adding to the time and therefore cost.

How will the tester be able to identify if the product has failed during a airborne immunity test?  If the product includes a screen can this show internal data that will allow the tester to easily see if the product is being affected?  If it is affected will the data shown allow you to identify what is being affected to allow you to subsequently remedy the problem?  Bear in mind that the product will most likely be viewed via a single CCTV camera while it is being tested.

If the product does fail have you provided a list of things for the tester to report back to you to allow you to try and identify what is going wrong?

Have you included the complete setup of the product as it is normally used in a typical configuration?  Cable connections whilst not necessarily used during the test should still be present as cables act as a path for signals into the product and therefore still need to be connected.

Does the product have more than one typical setup?  Should one or more alternative setups also be tested?

If you are concerned about the product failing have you considered providing a 2nd product with possible fixes implemented so that if it fails the alternative can be quickly swapped out to see if the fixes have an effect?  Test chamber time is expensive and if a product fails the rest of the booked time can be wasted so is it possible use this time to look at possible solutions.  Have you considered using screening, BLM’s on signal connections etc?  Are you / your engineer able to attend while the product is being tested to see first hand problems if they occur?

Have you selected a test house that will provide help if your product fails?  Tests are carried out by engineers but are there engineers available who will be able to avise you of likely fixes from their experience should the product fail?  Engineers who only carry out testing may not have the knowledge or experience to actually help resolve an issue.

Tests carried out

Most electronic products will need to have an airborne immunity test whereby the product is subjected to radiated emissions from 80MHz up to 1GHz, increasing in 1% steps every 3 seconds.  A 3V/m test is typical or 10V/m for heavy industrial equipment.  If equipment fails this test it will often be affected over a range of frequencies rather than at just one specific frequency.  This test typically takes between 1 and 2 hours to complete.

Most electronic products will need to have an Electro Static Discharge (ESD) test whereby an ESD generator tip is run around all seams off the case and openings with the product expected to continue operating when subjected to 8kV ESD.  All metal parts will also be directly touched by an ESD generator set to 4kV with the product expected to continue operating.  It is often permissible for the ESD test to have an effect on the product if the product quickly recovers and continues normal operation.  This test is usually quite quick.

Most electronic products will need to have a chamber scan to ensure the products emissions are within permissible limits.  This test is usually quite quick (typically around 30 minutes).

Carrying Out ESD Tests Yourself

If a product is failing the EN61000-4-2 ESD test it can sometimes be beneficial to hire an ESD tester (e.g. a TESEQ NSG 435 ESD Simulator) to identify and fix the problem. To setup for the test you need a ground plane (e.g. a sheet of aluminium) connected to mains earth via a 470ohm resistor. Your product sits on top of this but insulated with 0.5mm of insulation. The ESD tester then connects to the Ground Plane. The following is for a typical test:

Air Discharge

Set the ESD simulator to 8kV and to repetative discharging.  Test using + and – voltage polarities.  The test is also carried out at 2kV and 4kV and the different votlages may produce differing results due to the discharge current taking a different route.


Set the ESD simulator to 4kV and to single discharging.  Test using + and – voltage polarities.  The test is also carried out at 1kV and 2kV and the different votlages may produce differing results due to the discharge current taking a different route.

For both tests periodically brush the product over with a conductive brush connected to the ground plane to stop it buiding up a charge.  This is especially important when changing polarity as if the product has built up a charge to say 4kV when you change polarity is could see an effective discharge of 8kV.

The real ESD test will often consist of 200 ESD discharges in total.

Test services we can recommend

British Standards Institution CE Marking Information
Offer most CE compliance certification services.
CE Marking Association
Well worth considering these guys. A not for profit consultancy who offer straightforward easy to understand advice and guidance.
Barclay Phelps CE Marking Consultants
Specialise in documentation only CE certification.
Offer most CE compliance certification services.
Technology International Ltd
Specialise in multi version products, electrical safety, EMC and radio testing, with a specialism in helping gain certification through documentation where issues arrise or where lab testing is borderline.
Hursley EMC Services
Test lab for EMC certification
York EMC Services
Test lab for EMC certification
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