legally?
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.
https://europa.eu/youreurope/business/product-rules-complian...
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.
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
> 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?"
Just because you use a certified module doesn't give you a free pass.
To be fair, it's unintentional radiator testing that's required, rather than everything the module had to go through as an intentional radiator. So, it is a "free pass" for nearly all of it, and a much cheaper one, since you don't have to use a costly FCC accredited lab.
It is completely left up to you how you are going to demonstrate this if they ever come asking for the paperwork proving this. This can be a certification by an independent testing lab, documentation from in-house tests, or perhaps even documentation proving that it is compliant by design.
And, well -- that's certainly good.
But the FCC rules cover more than just Wifi and BT, and the whole rest of the widget also needs to comply with them. Of particular interest is FCC Part 15 Subpart B, which covers unintentional radiators. The device would need to comply with Part 15 Subpart B even if it had nothing to do with Wifi or BT.
Putting one part that is certified for one issue into a device doesn't extend a magical blanket of compliance to everything else that the whole of the widget contains.
Does the SPI or I2C bus (or anything else) leak RF beyond allowable limits? Eh, who knows. I certainly don't know. It's easy to say words like "it should be fine," but without testing then nobody actually knows.
The CE mark, meanwhile: That mark means exactly nothing in the US, where the author is located and the devices are sold from. The United States has zero regulatory recognition of any of the processes and/or tests that CE may cover. People often confuse this issue, wherein: They don't think it be like it is, but it do.
1. https://www.europarl.europa.eu/doceo/document/P-6-2007-5938-...
I don't disagree. It's important for us to recognize that we stand on the shoulders of giants, but I also think it's a little silly of a critique of someone happy about it being easier than he expected. It's true that hardware would be much harder if you had to do it all yourself, but is that meaningful? The wonders if the modern supply chain is that you don't need to do it all yourself.