Consumer electronics certification

I was reading this excellent article by the founder of Framework: What “Hardware is Hard” Really Means | eclecticc and came to the conclusion that pre-orders is the logical way forward for Converting Framework 13 to a FrankenPad

After a consultation with a 3d printing company a topic arose. The one about safety regulation and certification when you release a product.
After some research I found this:

The questions that come up are:

  1. For which components does this regulation apply?
  2. Does it apply for laptop cases?
  3. How do you fund that when pre-orders are only to fund materials, production and inventory take-off?

Anything else relevant, chime in!

Before even considering anything regarding how to sell something, you really should be evaluating how many you estimate you will sell, do you think you will sell just 10, or do you think you will sell 1000 units, this will quite heavily influence your decision. If you estimate you will sell less than 100 units, don’t even think about doing pre-orders as it’s quite honestly a waste. Also, certification is quite expensive for low volume, around 1k USD for basic CE certification, and probably 3-5k for ROHS or higher level certs. To answer your third question, you will have to gamble on your money as most start-ups will have investors, which can fund pre-production costs like certification, validation and other parts that go into selling a product. Also, you probably can’t use off-the-shelf modules like the parts for the FrankenPad unless the manufacturer explicitly says, you can commercially use this

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Doesn’t that hinder the whole 3rd party development secondary market by having a pretty steep entry fee?

The money that you do ‘gamble’ you might get back if you do produce around the number of units that people want. Any product release is a gamble no matter what

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I hope Framework creates a detailed guide about this so people know the procedures when trying that path. Thanks for elaborating.

Now that I think about it. It’s not a biggie with 100+ preorders. It’s something like 50-60$ surcharge for certification and regulation per unit.

I am OK with “gambling” money for a single prototype but the rest is basically on the user if it gets commercial.

By the way are DIY kits also subject to certification and regulation?
In the case of top, bottom and input cover there is no production unit rather a body kit additional to the Framework one.

Found the answer here:

CE certification apply mainly to electronics connected to mains power (note generalization!), and it is always applied to the whole completed product as it is used, including case etc. meaning it doesn’t apply to a bare PCB or otherwise ‘component’ of something.

Since I’m assuming what you plan to sell is a part of a product or a kit, you have no need for any certifications, as it would be the responsibility of the end user to either certify the finished product (unlikely), or treat it as a hobby item, ie user beware, used at your own risk where its possible your homeowners insurance or similar would not cover what you are doing if you are found negligible in using whatever contraption you did when causing the issue.

And obviously the rules for all of this vary from country to country, so the responsibility falls on the buyer/user to follow the rules/laws in his/her location. What you need to make clear though, is that what you are selling is a kit, or similar. That it does in fact require the user to finish the product. Then you cannot be held liable under any law.

Short version, yes its legal and you do not need to certify what you are selling as long as its not meant for mains power, then the rules become a lot more complicated.

In my case it’s not even electronics at all since it’s a body kit. Of course it will be ESD safe.

We’re not lawyers and certainly don’t want to attempt to provide legal advice. I agree that this is a pretty confusing area and something that restricts small-scale makers. For purely mechanical products, you probably do not need certifications. For any active electronic assembly that you are selling, you probably do.


Just a nitpick: as I found out recently, nowadays CE certification also includes all RoHS requirements, and the only allowed label to show compliance is CE (cannot be “RoHS” label anymore).

That’s why on the FW13 mainboards you can see only a “CE” label, but the board is still RoHS compliant.