[Max-q]

The pre certified module do not exempt the product from testing. It only means that you don’t have to do the conducted testing and that it’s a higher probability for passing the other tests. There are still lots of chances to fuck up and a full radiated test of the product is required.

[Suppafly]

>and a full radiated test of the product is required

legally?

[leoedin]

In the EU (and UK with UKCA), CE certification is down to whoever makes the product available on the market. There's no get out for pre-certified modules. If you put a pre-certified module in a box and sell it, you have to be responsible for the CE mark.

You need evidence that the whole product complies with the EMC regulations. There's some judgement involved - if you put a certified circuit board in a plastic box, it won't change the EMC behaviour so you don't need to re-test. But if you solder a module onto a larger circuit board, you are almost certainly changing the EMC behaviour. You should definitely be re-testing something like that.

The pre-certified module does save you some time in the "intentional radiator" testing - assuming you use the same antenna it was tested with as a module, you can probably make the case that the behaviour is the same.

Will anyone ever notice or care for a few thousand niche devices? I doubt it. But to sell in the EU legally you do need to do that testing.

[holowoodman]

No, you actually don't have to do the testing, except in some special circumstances (e.g. childrens' toys). Generally, the "CE" mark is a self-certification done by the manufacturer or importer that certifies that the product meets certain (category-specific) criteria. You can do the proper thing, test your product and then certify it. But it is also possible and usually legal to just issue the certificate based on a self-assessment and deal with the fallout later, if there ever is any. That's how basically all non-EU manufacturers and importers get their CE mark...

https://europa.eu/youreurope/business/product-rules-complian...

[leoedin]

I think there's 2 separate things at play.

Most products don't require testing by a notified body. That means anyone can do the testing - or even you could do it at home. The CE mark is self-assessed - you don't have to get a lab to issue it to you.

But electronics does have to conform with various electromagnetic compatibility rules. There's effectively no way to prove that without doing EMC testing. Most non-EU manufacturers will still do EMC testing in a lab, perhaps in China. That test report becomes part of the product's technical file.

My point is that if you take a module from a 3rd party and integrate it into a larger electronic product, it no longer has the same behaviour from an EMC point of view. You have no evidence that it meets the harmonised standards for electromagnetic compatibility. Realistically, probably nobody will ever notice. But if they do, you don't have evidence that your product complies with the standard.

[Max-q]

Products for children, medical equipment and all things with a radio (nfc, Bluetooth, mobile radios, WiFi +++) requires an external accredited lab.

You can test electronics without a radio yourself, but it requires a very extensive lab. Few companies can do this. But you can save money by using a non accredited lab.

[sabas123]

> except in some special circumstances (e.g. childrens' toys)

Don't nearly all electronics fall under it too, this is the second item after children toys in the link you posted.

> Here is a non-exhaustive list of products that are included in EU laws about CE marking:

> Toys, drones, electrical and electronic equipment, pyrotechnic products, recreational crafts and watercraft

[holowoodman]

>> except in some special circumstances (e.g. childrens' toys)

> Don't nearly all electronics fall under it too, this is the second item after children toys in the link you posted.

No. That page just says: There are tons of EU laws about everything, including electronics. By putting a CE mark in your product, you certify that your product complies with all applicable EU laws.

In most cases, this certification can be a self-assessment, meaning that you can just assign the CE mark by whatever internal process you deem sufficient. I.e. you are allowed to rubber-stamp, but of course you are fully responsible for all consequences.

In some cases, for example childrens' toys, but only for some electronic components (electronic toys, medical stuff, high-voltage components, components that emit EM radiation above a certain threshold, ...), self-assessment isn't enough. In those cases, you need to obtain a certification from a notified body, which is an external organisation doing some design review and testing, as required by the respective laws.

It's all laid out further below under "How to obtain CE marking" and "Do you need an independent assessment?"

[jynsnsns]

Depends on the legislation, but for most markets yes