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Topic Title: Cottage industry manufacturing
Topic Summary: What approval do I need to manufacture electrical goods
Created On: 02 December 2010 12:52 PM
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 02 December 2010 12:52 PM
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CBR

Posts: 14
Joined: 21 November 2010

HI all

I am considering quite seriously manufacturing an electrical product. Basically I will be buying in all the parts and simply putting them together to make a contactor controlled 24 hour time clock with a plug at one end. I will then PAT test, date the product and give it a unique serial number.

I'm not sure what I need as far as CE marks etc though, or even if I have to have anything like this at all. Nothing is ever simple though so I imagine that it will cost me thousands before I even sell one unit and at the scale I'm intending to operate at will not be viable.

Heres hoping though.

Regards
 02 December 2010 02:09 PM
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Avatar for dougflorence                                      .
dougflorence

Posts: 74
Joined: 25 July 2008

Primarily you need to ensure that the equipment that you will be selling is "safe". You would do that by checking conformity with the requirements of the EU Low Voltage Directive. The easy way to do that is to find an EN standard which applies to the equipment which you are manufacturing and make sure that your product complies with that.

If the equipment has active electronic components then the Electromagnetic Compatibility Directive may also apply. You can assess whether your product is in conformity with that or have some testing done if you are uncertain.

You can self declare conformity with these directives although you have the option of getting external certification from test houses or Notified Bodies. You show that the equipment is in conformity with all relevant EU directives by putting a CE marking on it.

If you PM or email me doug.florence@ccqs.co.uk with some details I can give you some more advice, but not too much because I am supposed to be doing this sort of thing professionally.
 02 December 2010 04:19 PM
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saridgway

Posts: 148
Joined: 07 May 2002

In addition to safety and EMC, you also need to look at ROHS and WEEE regulations. Until a few years ago, I did some subcontract design work for a one-man manufacturing concern (typically one-off, custom electronic/mechanical products for theatre lighting etc.). The introduction of WEEE on top of all the other stuff (and the associated cost of registration etc.) was the last straw in terms of continuing viability just to break even. ROHS had already taken a toll, in the sense that programmable devices we had been using were unavailable in ROHS versions, necessitating expenditure on new development and programming tools.

As for BSI, note that they are BSI Limited and (I assume) out to make a bob or two - standards cost a small fortune and are often superseded by new versions. I limited my purchases to couple of the relevant safety standards. Some libraries have on-line access to BSI standards (for viewing, but not printing). The EMC standards are not much use unless you are going to do your own EMC testing; if you think EMC is an issue, a book such as "EMC for Product Designers" by Tim Williams will tell you enough.

Good luck.

PS: It irks me somewhat that legislation made necessary by the activities of big business drives small players to the wall.

-------------------------
Steve Ridgway MIET

Edited: 02 December 2010 at 05:13 PM by saridgway
 02 December 2010 06:12 PM
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CBR

Posts: 14
Joined: 21 November 2010

Hi

Thanks for the replies. I have sent you an email dougflorence, outlining the general idea.

I don't think RoHS aplies in my case as there are no hazardous substabces and I'll just be using parts off the shelf which have already been tested for compliance.

As for WEEE, I'm a bit confused. Is buying materials from a wholesalers then knocking them together to sell on at a profit not the same principle as say buying a fluorescebt lamp from a wholesalers and then selling it on to an end user? I'm a sparky and do this daily. All I'll be doing is putting a couple of parts in a box and then sticking my logo to it. I'll put a sticker on with a bin on it and a cross through to remind people not to dispose of in the bin, but I don't think I'll be paying for the priviledge.

The thing with WEEE is that it costs me extra when purchasing EEE items from a wholesalers yet they won't dispose of the WEEE items which have been replaced. Unless I pay. I don't understand why I have to pay twice. I think that what usually happens is that the WEEE items end up in a bin or a skip. Fat lot of good that directive is then eh?

It irks me also that there are so many standards and regulations to pay for. I don't have unlimited resources, I just want to earn some money so that I can put food on my table. I'm confident that it'll be safe and tested etc and would be prepared to take it on the chin should one of them be faulty, which is what I'd have to do regardless of how many safety tests, standards and directives I had applied and paid for, as I'm sure that none of them are get out of jail cards.
 03 December 2010 09:27 AM
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amillar

Posts: 1918
Joined: 28 May 2002

Originally posted by: CBR
It irks me also that there are so many standards and regulations to pay for. I don't have unlimited resources, I just want to earn some money so that I can put food on my table. I'm confident that it'll be safe and tested etc and would be prepared to take it on the chin should one of them be faulty, which is what I'd have to do regardless of how many safety tests, standards and directives I had applied and paid for, as I'm sure that none of them are get out of jail cards.

The trouble is, "taking it on the chin" can cost you millions if there's an accident, particularly if you can not show that you have taken reasonable precautions. If you look at H&S prosecutions they are not just because someone made a mistake, but also because they did nothing to try and stop that mistake happening in the first place. That's where if you can show you have complied with standards that you have at least done the best you can. If you have complied with the standards (and any other 'good practice'), and something still goes wrong, you may get a rap on the knuckles but that's it (as long as you stop it happening again).
Incidentally, have you looked at product liability insurance?

You definitely need to look at this from the other side - if you bought a bit of equipment, and it went wrong and (god forbid) killed a member of your family, and the supplier could show no evidence that they had tried to keep it safe, what would you do? I think most of us would want to a) sue the backside off them and b) see them in jail. It only needs to happen once.


On the bright side, as you say, none of this is actually that difficult to deal with. Regarding WEEE I would suggest talking to your local Business Link who may well have free advice (or contacts with free advice) on how to handle this. In fact, you should be talkign to them anyway for general financial and legal advice. There are a lot of people out there employed to help small businesses start up.

-------------------------
Andy Millar CEng MIET CMgr MCMI

http://www.linkedin.com/in/millarandy

"The aim of argument, or of discussion, should not be victory, but progress." Joseph Joubert
 04 December 2010 11:32 AM
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saridgway

Posts: 148
Joined: 07 May 2002

For what it's worth, there is Business Link info on WEEE here.

Also, just out of interest, see this document.
So things may improve - though we shouldn't hold our breath, I guess.

To my mind, the WEEE directive should have a "de minimus" exemption like the EuP directive. Small wonder we don't make much in this part of the world these days.

Incidentally, I put details of a hypothetical "cottage industry" into the form on the business link site to see what list of potentially applicable legislation would come up. The list was huge and (in my view) ludicrous!

Feet back on the ground, though, I wouldn't get too disheartened. Safety is clearly paramount, but - if you can resolve the WEEE issue - I see no reason why any of the stuff identified in the above posts should cost you anything other than a bit of time justifying and documenting your approach.

-------------------------
Steve Ridgway MIET

Edited: 04 December 2010 at 11:50 AM by saridgway
 04 December 2010 02:45 PM
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saridgway

Posts: 148
Joined: 07 May 2002

Originally posted by: g3xoi

There should be nothing in the regulations thAt you wouldn't want to do as a conciencious engineer who wants to sleep at night!


And I suppose, with regard to WEEE, that should include paying towards environmentally friendly disposal of whatever it is you are making. I just had a quick look at some of the compliance scheme web sites; there seems to have been significant progress since I last looked at this a few years ago. There appears to be a wide range of pricing, some of which may even be reasonable! I know nothing about the companies involved, but see, for example this or this.

-------------------------
Steve Ridgway MIET

Edited: 05 December 2010 at 02:26 PM by saridgway
 07 December 2010 03:24 PM
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CBR

Posts: 14
Joined: 21 November 2010

Thank you all very much for your replies to this thread. And thanks also for the links. I haven't had the time to read through them all yet, but I'm sure that I'll get the chance between now and the New Year.

Many thanks
 31 January 2011 06:33 PM
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jencam

Posts: 608
Joined: 06 May 2007

Does anybody have any information and advice about insurance for cottage industry manufacturers?
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