CE Standard Certification for RepRaps

Hi all

My friend and I are considering selling on our jointly built RepRap to fund the purchase of two kits; one each. Does this then make us manufactures? Are we then obliged to fill in the paper work for CE Standard Certification? Or are the kits already covered? I started to read through the legislation, but thought that some-one may have already done this. Has anyone? Does anyone deal with this professionally who can advise?

If no-one knows about this. I am happy to look in to it. This could be my contribution to the community. :-).

Best Regards

James

Link to the reference for the legislation.

CEN Technical Body: Industrial thermoprocessing - Safety

I guess the one that covers RepRaps is;

Plastics and rubber machines - Extruders and extrusion lines - Part 1: Safety requirements for extruders

James

Kits can't be CE marked as they are just a collection of parts. Complete machines would count as electrical appliances and so would need EMC, safetly, ROHS, WEEE, etc to be sold in the EU and UL FCC, etc in the US. I don't think any Reprap designs would pass the necessary tests to be certified and it would be far too expensive to consider for two.

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Thanks for replying nophead.

Mmm, that’s bad news for us. Is there are demand within the community to find out what is required and alter the most common designs so they do comply? I was thinking Prusa Mendel, Huxley, RepRapPro Huxley & Mendel etc. This will need to be done at some point if the “revolution” happens and they become commonplace.

James

It's fine as long as they remain DIY kits, which is the whole point of RepRap. If somebody wants to sell complete machines they will have to spend thousands of pounds to get them certified and they would need mods to pass safety and EMC regs, which would make them more expensive.

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[www.hydraraptor.blogspot.com]

Curious though, many reprap makers and companies like Ultimaker offer pre-built, running machines as an option. You mean to tell me that they all have sought out certification?

Edited 1 time(s). Last edit at 02/06/2013 12:22PM by xclusive585.

xclusive585 Wrote:
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> Curious though, many reprap makers and companies
> like Ultimaker offer pre-built, running machines
> as an option. You mean to tell me that they all
> have sought out certification?

I've just sent them an e-mail asking them. I wonder if I will get a reply. They have probably sold enough of them to afford it.

James

nophead Wrote:
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> It's fine as long as they remain DIY kits, which
> is the whole point of RepRap. If somebody wants to
> sell complete machines they will have to spend
> thousands of pounds to get them certified and they
> would need mods to pass safety and EMC regs, which
> would make them more expensive.

nophead

Sorry for my naivety here, I am new to this, as you can see from registration. By looking at your registered date you have been here from the start, and done much for the community. I am impressed by the Mendel90 by the way. My following question is not meant to be disrespectful but in an effort to understand the community.

I thought the point of the RepRap movement was to make nearly self replicating machines that needed us in a symbiotic way to help them build themselves. In return for this help they make us plastic parts etc. In my mind I have extended this analogy, so like domesticated cattle / crops we can have farms of them so we don't just sell their produce; milk, grain (plastic parts) but we could sell them as well. By this I don't just mean the kits, but fully working machines (breading stock). I am sorry if I have got carried away with the analogy but it is this idea that has intrigued me. (As well as printing things in my study out of plastic!). My understanding of this is based on Adrian Bowyer's video on the RepRap.org front page. I am interested to know if things have moved on from there.

Best Regards

James

The problem is that trading laws make it impractical for individuals to make and sell electrical appliances to the public. I assume that most if not all small companies that are selling complete machines are breaking the law.

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[www.hydraraptor.blogspot.com]

The CE directives talk about "products offered for sale" and "manufacturers" but I can't find a formal definition of "product" or "manufacturer". The widest interpretation might include any private build and sale, but I believe the directives are intended to be applied to products sold by commercial entities, e.g. public and limited companies, self employed traders. Trading standards in the UK use the phrase "in the course of business", which would exclude things built by hobbyists. There is a gray area where a large hobby becomes a small business, the distinction is decided by a judge, if you are unfortunate to get that far. I guess the same applies for tax purposes, if it generates even "side income" that you need to declare, it could also be classed as business (trading) activity.

So I think one-off private sales would be excluded. As for the directives themselves, probably Low voltage, Machinery and EMC directives apply. You might get away without LVD by offering a machine with no PSU if it operates below 50V. If you provide even a CE marked PSU, you probably need to re-certify the whole system.

CE is self-certified, so in theory if you perform the proper compliance tests yourself you can affix the CE mark, but you better have all the paperwork done to demonstrate how you have done the tests.

I've looked into the certification part a while ago... it looks like a headache to be honest, looking at what i can find on it, it seems to be more about formal declarations in paperwork that come with your product than it is actually defining things like wiring standards and margins of safety for things like fuses and thermal overloads ... etc

something I've noticed recently is that the CE mark is a new feature on the up! ... and the wiring on that is very very questionable ....... among other serious safety issues

most pre assembled repraps seems to be wired up pretty good and with proper gauge wire thicknesses much safer power supplies than a lot of other electrical products entering the EU from china, apparently the authorities in most countries are currently focusing a lot of concern on a lot of chinese products eg tv dvd/blueray players, and smaller mass produced items like powerboards and powertools, as a good percentage of them really "ride" the limits of their own power supplies and produce quite a bit of heat, and over stressed components ... all thanks to this planned obsolescence idea

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I don't think there is any grey area. If you make something and sell it to the public you are a business. You are at the least a self employed sole trader and have to pay tax and NI.

Unless you have an anechoic RF chamber, signal generator, antenna, spectrum analyser, mains harmonic analyser, ESD generator, etc. you can't produce the evidence to self certify EMC compliance without going to an independent test house.

And for ROHS you need a mountain of paperwork to show every single part is compliant. I.e. certification for every little nut and bolt.

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[www.hydraraptor.blogspot.com]

lol ROHS - classic example of the"create a standard, create a job" mentality

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Thanks for you thoughts bobc. I obviously need to think about what I am going to do. I have e-mailed the company I bought the kit from just to check that it isn't certified. I would be happy to do the paperwork if that is all it is required and to share this with the company and community. From what Nophead has said I suspect design mods and independent testing is required. I checked the cost of the British Standards, at £150 a piece the price is prohibitive.

Regards

James

You can't certify a kit. Whether it was safe and its EMC would depend on it being build correctly.

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[www.hydraraptor.blogspot.com]

But what constitutes a kit?
If I could produce a reprap kit with only, say, 4 parts to assemble, where would that sit with the certification issue?

thejollygrimreaper Wrote:
-------------------------------------------------------
> I've looked into the certification part a while
> ago... it looks like a headache to be honest,
> looking at what i can find on it, it seems to be
> more about formal declarations in paperwork that
> come with your product than it is actually
> defining things like wiring standards and margins
> of safety for things like fuses and thermal
> overloads ... etc

When power supplies are certified to EN60950 the test house will run them at maximum load and measure the temperature of the wound components. If they are run too hot for the insulation spec plus a margin plus measurement uncertainty they fail it. This is why I believe most PC power supplies have fake approvals.

>
> something I've noticed recently is that the CE
> mark is a new feature on the up! ... and the
> wiring on that is very very questionable .......
> among other serious safety issues

Goods cant' be CE marked outside Europe. Anything imported has to be certified by the European importer. The reason being that if anything goes wrong the authorities here can't prosecute people in China.

>
> most pre assembled repraps seems to be wired up
> pretty good and with proper gauge wire thicknesses
> much safer power supplies than a lot of other
> electrical products entering the EU from china,
> apparently the authorities in most countries are
> currently focusing a lot of concern on a lot of
> chinese products eg tv dvd/blueray players, and
> smaller mass produced items like powerboards and
> powertools, as a good percentage of them really
> "ride" the limits of their own power supplies and
> produce quite a bit of heat, and over stressed
> components ... all thanks to this planned
> obsolescence idea

Well should fail EN60950 if any safetly critical components are stressed outside their limits.

Edited 1 time(s). Last edit at 02/07/2013 06:41AM by nophead.

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[www.hydraraptor.blogspot.com]

waitaki Wrote:
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> But what constitutes a kit?
> If I could produce a reprap kit with only, say, 4
> parts to assemble, where would that sit with the
> certification issue?

I don't know. I expect things that simply come in a few parts that bolt together and have plugs and sockets to make the connections would not count as a kit.

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[www.hydraraptor.blogspot.com]

Nophead: somthing that would be interesting would be to do the same kind of testing on unsuspecting power supplies

looking closer at the up! the ce mark is on the printer itself, but not on the powersupply, which is actually just a hp laser printer powersupply.

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I have done that many times in my career. Most PC PSUs fail when loaded to the ratings on the label. They rely on the fact that motherboards specs are worst case and never happen. But I think motherboard manufacturers realise PSU manufacturers under rate their PSU so there is spec inflation.

And the UP itself would need to comply with EN60950 for safety as well and that would require correct wire gauges, etc.

Edited 1 time(s). Last edit at 02/07/2013 07:40AM by nophead.

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[www.hydraraptor.blogspot.com]

nophead Wrote:
-------------------------------------------------------
> I have done that many times in my career. Most PC
> PSUs fail when loaded to the ratings on the label.
> They rely on the fact that motherboards specs are
> worst case and never happen. But I think
> motherboard manufacturers realise PSU
> manufacturers under rate their PSU so there is
> spec inflation.
>
> And the UP itself would need to comply with
> EN60950 for safety as well and that would require
> correct wire gauges, etc.

what about wire type?, the one big annoyance is the type of wire they have used for the heater cartridge and thermisters on both the extruders and the heated bed, it's this 24guage (0.54mm) very stiff wire which will break if flexed too much,
the insulation is from what i can measure very very thin at somewhere in the 0.25mm thickness range, however when the wire on the inside fails it just rips straight through the insulation and you get arcing between the strands, which btw doesn't seem to cause anything to shutdown even though that is pretty much a dead short, even the fuses on the main board don't blow ,

looking at the extruder it has a 24volt 80watt cartridge according to the power supply is 19v so assuming they crank the pwm right up to full there should be about 2.6 amps / 2 so 1.3amps per strand ( two strands) correct me if i'm wrong but i thought that 24guage wire was only meant to take 500mA and 22 guage 900mA for power transmission purposes ,granted that would only be during a warm up, when the extruder is hot id expect it to function just like any other pid loop, and it wouldn't be so bad, i'd like to think i'm somewhat wrong with the current limits above

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I think, power transmission current limits are for liming the power loss over long distances rather than safety. I always go with the chassis wiring limits in this sort of application.

Using thick wires that need to bend is dangerous though. Even with thick insulation, like mains cable they can break one strand at a time until the strands that are left get hot enough to burn the insulation. I have had 12V bed wiring catch fire this way. Also mains bed wiring can arc across the break and burn the insulation that way.

That is why I use ribbon cable plus a polypropylene guide strip to enforce a minimum bend radius. I haven't had any failures with this system in several machine years of continuous use.

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[www.hydraraptor.blogspot.com]

fair enough, the worst part with the cable on the y axis in the up! is that because the bending radius is so tight when 1 strand fails it changes the radius in that spot so a second one will fail in the same spot, the worst part is that when one fails it can scratch away at the thin insulation on another bit of wire so far we've been lucky that it hasn't done it to the thermister wiring that runs next to it, otherwise there goes a $1400 control board, if it ever happens we'll put a smoothie board or a 4pi in there and re wire the whole printer, as it is we're already putting a smoothieboard in another up! due to some really stupid problems pp3dp cannot seem to fix and has left one printer bricked,

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If components can't be used outside their spec, then that would force the use of heat cartridges rather than resistor powered hotends, because we run the resistors at well above their current rating.

Greg Frost Wrote:
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> If components can't be used outside their spec,
> then that would force the use of heat cartridges
> rather than resistor powered hotends, because we
> run the resistors at well above their current
> rating.


very true, however we aren't slapping the CE mark and various other compliance indicating marks on our repraps ...

cartridge heaters aren't much different from the resistors anyway just a different packaging and wire bonding , i personally favour heater cartridges simple because of the packaging it's just convenient for my hotends,

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We are effectively changing the spec of the resistor by attaching a heatsink to it that keeps its surface temperature within spec. But yes it might be difficult to get safety approval on an unconventional use of a resistor as a heater.

To be considered safe though a hot end must self limit to a temperature that does not cause a problem or have a thermal trip since a single fault like a shorted MOSFET should not lead to a dangerous state.

And just because a device has safety approval doesn't necessarily mean it is safe. Test houses are fallible. I simulated a single fault on a PSU that was certified to EN60742 by shorting one leg of its bridge rectifier because the fuse came after it. The test house said that this was OK because a short on the secondary would blow the mains fuse. I didn't believe them because there were multiple secondaries, so I tried it (outside in the company car park). The result was spectacular: smoke, flames and explosion. The supplier had to rewire a whole container load in a hurry to have the fuses before the rectifiers even though they had a test certificate to say it had passed safety approval.

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[www.hydraraptor.blogspot.com]

Quote

$1400 control board

I thought the whole printer was only $1500.

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[www.hydraraptor.blogspot.com]

nophead Wrote:
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> $1400 control board
>
> I thought the whole printer was only $1500.


rip off eh?

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Yes, you might as well just buy another complete printer for an extra $100 and have a complete set of spares.

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nophead Wrote:
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> Yes, you might as well just buy another complete
> printer for an extra $100 and have a complete set
> of spares.

i think thats the idea, problem is it really doesn't solve the problems, you still end up with the another printer with just as many of the same problems, the way i'm going with it is putting a smoothie board in there, then i'll have full control over everything, given the kind of print quality i get on my prusa variant with replicatorg and slic3r i'm going to be very chuffed with what i'll get given a much more rigid cartesian platform, after the smoothie board is in there the extruder will be replaced with a variant of my direct drive extruder, maybe even a ABP so i can run 24hrs a day 7 days a week,

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