ROHS, CE, UL... questions

[4yrs1]

I am planning to build some pedals and sell them. I have already read here in the forum that everything must be ROHS certified if I am to sell them in California and Europe. I have also heard and read about other certifications such as UL and CE.

Questions:
1. Are there any other places that require ROHS compliance other than the EU and California? (I would imagine Japan also requires this, can anyone confirm and add to the list of confirmed places?)
2. If I didn't check if my parts are ROHS compliant when purchasing them, how can I find out now if my pedals are ROHS compliant?
3. What are CE and UL certifications and how do I know if my pedals are compliant to those certifications?

Any help is greatly appreciated!

[radio]

I can just reply to 2)

You just can't ,it's assumed you took the responsibility to check

before buying,but most bigger shops have marked their goods .

It's especially annoying if you are not used to solder lead-free,

you have to solder at higher temperatures.

[.Mike]

In the politest way possible...

DIYers generally aren't concerned whether their pedals are RoHS or have safety certifications.

If you are concerned about RoHS or safety certifications, you certainly should avoid relying on the advice of Internet strangers to make sure your enterprise is above board.

This seems like one of those situations where your primary options are independent research, or hiring and paying a consultant who knows the definitive answers to your questions.



Mike

[R.G.]

As .Mike did, I'll  try to be polite. Although it gets used that way, this forum is not called "howtogointobusinesssellingyourpedals.com".

If you are planning to build and sell pedals as a business, you need to remember that the business details will completely overwhelm any pedal-related items. People run successful businesses buying premanufactured [whatevers] and selling them. No content related to the [whatever] at all. But lots and lots of dealing with governments, taxation, regulations, and money flow.

1. Are there any other places that require ROHS compliance other than the EU and California? (I would imagine Japan also requires this, can anyone confirm and add to the list of confirmed places?)

First, good for you wanting to know the law and follow it.
RoHS is Europe. The People's Republik of Kalifornia may demand that as a subset, but it also has its own quirky laws as well. San Francisco, for instance, has local laws saying you cannot force someone to work for pay or sell items which have not been certified by UL, or equivalent, which is a set of safety standards, not environmental standards. PRK is in the habit of passing its own environmental legislation in hopes of extorting manufacturers everywhere to follow by business necessity, so it may well had different and more extensive regulations. One example is that if your product contains materials "known by the State of California to cause reproductive harm..." and on and on, you must so label  your product. This is why that phrase is on so many containers of materials in Home Depot.

The real answer is - you're going to have to exercise google and find out. It changes all the time as countries, counties, and/or cities "pile on" to look like they're working for their citizens without really having to do anything about the real issues.

2. If I didn't check if my parts are ROHS compliant when purchasing them, how can I find out now if my pedals are ROHS compliant?

Unless you're a research chemist with a stocked lab, you can't. RoHS is essentially a process of collecting certifications of product contents and keeping those forever. The original producers certify and you rely on it. Unless you can do things like going into the back room and testing every part you use for things like hexavalent chromium, lead (down to PPM!), dioxins, furans, ... . Most people don't have such a well-equipped workroom, so they must rely on the producers' certification, and keep records.

You can lie, and hope you don't get caught. At low volumes for cheap stuff, it's possible, maybe likely, that no one will look. If you get caught, say by a competitor tipping off the officials, there are various penalties per polity. Those vary by place I imagine.

3. What are CE and UL certifications and how do I know if my pedals are compliant to those certifications?

I'll again be as polite as possible. If you don't know what CE and UL certifications are, you have a lot more work to do before you go into business selling anywhere outside the USA. You're going to have to either ignore them and hope you don't get caught violating them, or go learn about them, or pay someone to do the work for you.

I design stuff that has to meet CE and other safety regulations professionally, and have done so for a long time, including before CE existed as a law. I have many textbooks I refer to when I do a new design which has to be certified. Knowing what has to be certified and not is not a trivial task. Pedals which are powered only by low voltage batteries or already-certified DC power supplies are a special case where the safety problems are elsewhere; the battery maker and maker of the wall wart have had to comply, and the pedal is under the radar.

I think. The law changes all the time. In the USA, there are something like 250,000 new laws passed per year, many of which carry criminal penalties, as the process of overcriminalization continues unabated. That's in the USA. Want to legally sell elsewhere? There's more research to be done.

But back at the real question. CE marking requires the maker to have tested or caused to be tested their products for certain safety regulations, notably IEC60065 for pedal-ish stuff, mark the stuff before sale, and be responsible for the continued conformance of the product as well as keeping records of the conformance certification process for - hmmm, as I memember, five years after the sale of the unit stops.

UL is a private, non-governmental safety testing setup that started in the USA when insurance companies wanted to know how to price their insurance products, and give discounts to companies which sold "safe" products. They test to standards that UL originally wrote, but which have now been "harmonized" to the evolving set of international standards for product and electrical safety.

If you want to see the standards, you have a couple of problems. One is that there are many standards, even many electrical standards, so picking the right one is non trivial. Another is that you cannot get the standards for free. They're on the order of $200 - $800 per copy, and the organizations which sell these are legally aggressive about keeping it that way, so "free" internet copies are generally not available.

Again, kudos for wanting to know and do the right thing. There's a little work involved. By the way, you should assume that **NOTHING** you read on the internet is accurate or complete. Even what I just wrote, although I tried.

[4yrs1]

I can just reply to 2)

You just can't ,it's assumed you took the responsibility to check

before buying,but most bigger shops have marked their goods .

It's especially annoying if you are not used to solder lead-free,

you have to solder at higher temperatures.

Thanks for your reply.

[4yrs1]

In the politest way possible...

DIYers generally aren't concerned whether their pedals are RoHS or have safety certifications.

If you are concerned about RoHS or safety certifications, you certainly should avoid relying on the advice of Internet strangers to make sure your enterprise is above board.

This seems like one of those situations where your primary options are independent research, or hiring and paying a consultant who knows the definitive answers to your questions.



Mike

Thanks for your reply and advice. It's very difficult to find the appropriate/specific info and to know in which direction to go so I appreciate any help as I continue my online research about these things.

[4yrs1]

As .Mike did, I'll  try to be polite. Although it gets used that way, this forum is not called "howtogointobusinesssellingyourpedals.com".

If you are planning to build and sell pedals as a business, you need to remember that the business details will completely overwhelm any pedal-related items. People run successful businesses buying premanufactured [whatevers] and selling them. No content related to the [whatever] at all. But lots and lots of dealing with governments, taxation, regulations, and money flow.

1. Are there any other places that require ROHS compliance other than the EU and California? (I would imagine Japan also requires this, can anyone confirm and add to the list of confirmed places?)

First, good for you wanting to know the law and follow it.
RoHS is Europe. The People's Republik of Kalifornia may demand that as a subset, but it also has its own quirky laws as well. San Francisco, for instance, has local laws saying you cannot force someone to work for pay or sell items which have not been certified by UL, or equivalent, which is a set of safety standards, not environmental standards. PRK is in the habit of passing its own environmental legislation in hopes of extorting manufacturers everywhere to follow by business necessity, so it may well had different and more extensive regulations. One example is that if your product contains materials "known by the State of California to cause reproductive harm..." and on and on, you must so label  your product. This is why that phrase is on so many containers of materials in Home Depot.

The real answer is - you're going to have to exercise google and find out. It changes all the time as countries, counties, and/or cities "pile on" to look like they're working for their citizens without really having to do anything about the real issues.

2. If I didn't check if my parts are ROHS compliant when purchasing them, how can I find out now if my pedals are ROHS compliant?

Unless you're a research chemist with a stocked lab, you can't. RoHS is essentially a process of collecting certifications of product contents and keeping those forever. The original producers certify and you rely on it. Unless you can do things like going into the back room and testing every part you use for things like hexavalent chromium, lead (down to PPM!), dioxins, furans, ... . Most people don't have such a well-equipped workroom, so they must rely on the producers' certification, and keep records.

You can lie, and hope you don't get caught. At low volumes for cheap stuff, it's possible, maybe likely, that no one will look. If you get caught, say by a competitor tipping off the officials, there are various penalties per polity. Those vary by place I imagine.

3. What are CE and UL certifications and how do I know if my pedals are compliant to those certifications?

I'll again be as polite as possible. If you don't know what CE and UL certifications are, you have a lot more work to do before you go into business selling anywhere outside the USA. You're going to have to either ignore them and hope you don't get caught violating them, or go learn about them, or pay someone to do the work for you.

I design stuff that has to meet CE and other safety regulations professionally, and have done so for a long time, including before CE existed as a law. I have many textbooks I refer to when I do a new design which has to be certified. Knowing what has to be certified and not is not a trivial task. Pedals which are powered only by low voltage batteries or already-certified DC power supplies are a special case where the safety problems are elsewhere; the battery maker and maker of the wall wart have had to comply, and the pedal is under the radar.

I think. The law changes all the time. In the USA, there are something like 250,000 new laws passed per year, many of which carry criminal penalties, as the process of overcriminalization continues unabated. That's in the USA. Want to legally sell elsewhere? There's more research to be done.

But back at the real question. CE marking requires the maker to have tested or caused to be tested their products for certain safety regulations, notably IEC60065 for pedal-ish stuff, mark the stuff before sale, and be responsible for the continued conformance of the product as well as keeping records of the conformance certification process for - hmmm, as I memember, five years after the sale of the unit stops.

UL is a private, non-governmental safety testing setup that started in the USA when insurance companies wanted to know how to price their insurance products, and give discounts to companies which sold "safe" products. They test to standards that UL originally wrote, but which have now been "harmonized" to the evolving set of international standards for product and electrical safety.

If you want to see the standards, you have a couple of problems. One is that there are many standards, even many electrical standards, so picking the right one is non trivial. Another is that you cannot get the standards for free. They're on the order of $200 - $800 per copy, and the organizations which sell these are legally aggressive about keeping it that way, so "free" internet copies are generally not available.

Again, kudos for wanting to know and do the right thing. There's a little work involved. By the way, you should assume that **NOTHING** you read on the internet is accurate or complete. Even what I just wrote, although I tried.

Many thanks, R.G., this helps very much.

[puretube]

"Dic hospes Chinae nos te hic vidisse iacentes,
dum sanctis patriae legibus obsequimur."

&

"...be Sure to Wear some Flowers in your Hair"

got something in common...


BUT: China-RoHS is much more stringent !!!