Selling Eurorack Modules & Complying to Directives

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Chris Willocks
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Selling Eurorack Modules & Complying to Directives

Post by Chris Willocks » Mon Mar 30, 2020 4:48 pm

Hi everyone,

I'm sure this may have been asked before, however I was unable to find any sufficient information. So I'll fire away.

I have about 14 Eurorack modules that I have designed, built and tested over the past nine months or so. I'm selling a few of them on eBay at the moment to see how they perform i.e. just taking it slowly and not getting ahead of myself. However, assuming people like the modules, I will likely try and offer them via a dedicated online store that I have in the works.

To cut a long story short; For the past week or so, I've been researching the regulations and directives that the modules, their individual components and the product packaging would need to meet e.g. RoHS/REACH, WEEE etc.

I just wanted to ask if anyone has any experience with this sort of thing, as I'm still a little unsure, even after researching it extensively. Things are never that straightforward.

From my own understanding, the modules would certainly have to comply with the following. These are a given:

- RoHS
- REACH
- WEEE

However, I'm not sure whether they would have to comply with:

- EMC Directive (I wouldn't have thought so, as all of my modules are analogue and therefore do not produce high-frequency signals i.e. above 100KHz or so)
- Low Voltage Directive (all of the modules are DC below 75V, with no mains power).
- CE Marking (no idea about this? All the modules I have seen for sale do not have one).

Hopefully this makes sense. Your advice would be much appreciated.

Thanks,
Chris

ricko
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Re: Selling Eurorack Modules & Complying to Directives

Post by ricko » Mon Mar 30, 2020 10:38 pm

For Europe and UK, I always print out a copy of the certificate of the PCB fabricator (ROHS in the past) and put it in the package where it is eady to find for inspectors. It will be on their website. I also print a note for Customs, giving the EU code for this kind of thing (electronic musical instrument parts.) I have not had any trouble. (I dont have any CL etc marks on my boards either.)

I also colour code my PCBs, so that different colours are different generations of prototype (yellow for 0, red for 1, etc), and ROHS are always blue. That gives me confidence I am not sending the wrong kind of board.)

Another wrinkle is to not pay unnecessary UK VAT or customs impost. The UK has a rule that foreign automated electronic orders attract tax. So I value the boards at almost cost price to avoid any Customs thresholds, and so the main thing the user purchases when getting a Fricko panel/pcb/schematic combination is the schematic, which I email by hand: because of not using automation for fulfillment, the transaction does not get border VAT applied: this is a concession the UK government has allowed to reduce red tape and encourage small fish.

Regards, and Best Wishes!
Rick
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KSS
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Re: Selling Eurorack Modules & Complying to Directives

Post by KSS » Tue Mar 31, 2020 12:13 am

:popcorn:

Chris Willocks
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Re: Selling Eurorack Modules & Complying to Directives

Post by Chris Willocks » Tue Mar 31, 2020 9:33 am

Thanks for the reply.

So am I correct in saying that you attach the PCB RoHS certificate on the outside of the box, when sending it to a customer?

What do you do about WEEE and REACH compliance also? Are you registered in every EU country you ship to for WEEE?

Regarding the CE marking; am I correct in saying that analogue modules do not require them, as the low voltage and EMC directives are not applicable to them?

Lastly, this seems a bit pedantic, but do you know if packaging i.e. the cardboard box, bubble wrap, tape etc. needs to comply to REACH or any other directives, as I've searched extensively but couldn't find any information on it?

Thanks,
Chris

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guest
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Re: Selling Eurorack Modules & Complying to Directives

Post by guest » Tue Mar 31, 2020 10:22 am

this was the last thread on the topic i remember, and it didnt seem to go anywhere. you could try pinging the author of the thread to see what they decided on:

https://muffwiggler.com/forum/viewtopic ... 7&t=221174
openmusiclabs.com

KSS
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Re: Selling Eurorack Modules & Complying to Directives

Post by KSS » Tue Mar 31, 2020 12:04 pm

On their website, Mutable Instruments-and a few others- list the directives their modules meet. You can start there.
As you've noticced, not everyone follows all the rules. There's quite a bit of look the other way in the Eurorack world with regard to directives and rules.
It's admirable you're trying to do the right thing. CE marking is easily looked up and understood. That doesn't mean the answer you need is easy or easily understood.

It also depends on where you plan to sell your wares. There is no set of universal marketplace standards. Rather a combination of different sets which together reach the univesality a worldwide product requires. What you can get away with in the USA is not the same as what you have to do in other markets.

Flying 'under the radar' works for many in this industry. Whether that will work for you is both a technical and ethical decision. Hence the :popcorn: in my 1st reply.
Look at your competitors for clues as you make your decision. You may notice some of the hgiher end and sometimes higher cost module makers have more information of the type you're looking for. This is both a clue and a nod to the reality of meeting some of the standards.

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Lux A Turner
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Re: Selling Eurorack Modules & Complying to Directives

Post by Lux A Turner » Tue Mar 31, 2020 12:25 pm

If you are selling to Germany, then you will need to comply with the German Packaging Act, which involves registration and the payment of an annual fee. There is no threshold and it doesn't matter how 'small' you are - you are required to register before you send so much as a single package, even if you are a private seller on Ebay, Etsy or Reverb.

Check out: https://www.gruener-punkt.de/en/packagi ... g-act.html for some further info.

e2a: Info re VAT & duty on imports to the UK & EU - https://www.gov.uk/government/publicati ... post-users
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Chris Willocks
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Re: Selling Eurorack Modules & Complying to Directives

Post by Chris Willocks » Tue Mar 31, 2020 3:46 pm

Thanks everyone for the advice. I definitely want to do things properly and by the book. There's no point in risking it really.

I've looked at the websites/manuals of various modular companies as KSS suggested, like Mutable and Intellijel. They seem to have a strong focus on EMC and Low Voltage compliance, as well as CE marking in their documentation. These are the grey areas for me at the moment.

I'm pretty confident regarding RoHS and REACH requirements. I'm only using components in my modules (i.e. the front panel, PCB, resistors, capacitors, knobs, standoffs, screws etc.) from Farnell that are RoHS compliant and have no SVHC in them. Plus, all of the necessary compliance documents for each component can be downloaded from Farnell's website, which is useful. I'm not sure though if the whole module needs to be tested again for RoHS/REACH compliance as a whole unit rather, than the individual components, once it's complete, as the thread above suggests?

I've sent an email to the CE Marking Association also, to see if they can shed any light on this convoluted topic.

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Re: Selling Eurorack Modules & Complying to Directives

Post by ricko » Wed Apr 01, 2020 10:29 am

@Chris. I gave been using PCBway. At their site they give some certificates. https://www.pcbway.com/blog/News/PCBWay ... icate.html

For EU RoHS I print out a certificate. I dont ship in boxes, I ship PCBs in stiff sleeves in bags. The ROHS sheet goes in the bag, so that if Customs open it, it is what they will find.

For EU Reach, I believe it is an obligation to report if over a level of harmful substances. So if not over that level, no action is required.

For EU WEEE, I dont believe I am selling "equipment" by selling a board or panel. So no action. (If you are selling built modules, that might be different.)

For US UL, I would copy the certificate if a customer was concerned, but I have not heard it is an issue as hobbyist volumes, enough to warrant doing it automatically.

Chris Willocks
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Re: Selling Eurorack Modules & Complying to Directives

Post by Chris Willocks » Wed Apr 01, 2020 5:52 pm

Thanks for the info. I feel a little more confident now with what is required.

If sending DIY kits abroad i.e. the PCB, panel and components, would you put RoHS certificates in the package for every component, or is that superfluous?

What do you do regarding Low Voltage and EMC requirements? I'm guessing they're irrelevant for PCB & panel or DIY kits, as they're not one complete unit? But maybe applicable to built modules?

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Alfrede
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Re: Selling Eurorack Modules & Complying to Directives

Post by Alfrede » Fri Apr 03, 2020 12:02 am

Is there a ebay link ?

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sutekina bipu-on
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Re: Selling Eurorack Modules & Complying to Directives

Post by sutekina bipu-on » Fri Apr 03, 2020 12:23 am

Lux A Turner wrote:
Tue Mar 31, 2020 12:25 pm
If you are selling to Germany, then you will need to comply with the German Packaging Act, which involves registration and the payment of an annual fee. There is no threshold and it doesn't matter how 'small' you are - you are required to register before you send so much as a single package, even if you are a private seller on Ebay, Etsy or Reverb.

Check out: https://www.gruener-punkt.de/en/packagi ... g-act.html for some further info.

e2a: Info re VAT & duty on imports to the UK & EU - https://www.gov.uk/government/publicati ... post-users
I have never heard of this and never done it. I also won't unless the post office here makes me. (I know that's the American attitude you guys know and love)

I've been selling both used and new self-made items to Germany for like 10 years now and i have never had a single problem.

Back then, a German customer asked me to put two copies of the invoice in the box and one in an external envelope otherwise they'd have to spend all day at the customs office.

Ever since then I always send items to Germany exactly like that and they all get delivered very quickly , without issue, and nobody's once bitched at me that i haven't complied with some act that doesn't even apply within the borders of my country lol.

Also LOL if anyone in Germany thinks I, in the USA, am going to pay a cent to anyone in the EU, solely because i'm still pissed you guys are responsible for those annoying cookie notices on every website.

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Lux A Turner
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Re: Selling Eurorack Modules & Complying to Directives

Post by Lux A Turner » Fri Apr 03, 2020 4:04 am

sutekina bipu-on wrote:
Fri Apr 03, 2020 12:23 am
Lux A Turner wrote:
Tue Mar 31, 2020 12:25 pm
If you are selling to Germany, then you will need to comply with the German Packaging Act, which involves registration and the payment of an annual fee. There is no threshold and it doesn't matter how 'small' you are - you are required to register before you send so much as a single package, even if you are a private seller on Ebay, Etsy or Reverb.

Check out: https://www.gruener-punkt.de/en/packagi ... g-act.html for some further info.

e2a: Info re VAT & duty on imports to the UK & EU - https://www.gov.uk/government/publicati ... post-users
I have never heard of this and never done it. I also won't unless the post office here makes me. (I know that's the American attitude you guys know and love)...
I only heard about it because I have a small Etsy shop and read about it in the forums there. It doesn't just affect the USA, either - it applies to all countries, even other EU member states and - for that reason - I no longer ship to Germany. I am not the only one to take this view, by any means.

You are - of course - free to run your business as you choose and if 'flying under the radar' (as mentioned above) works for you, then fine. I'm not the Police, I'm not a whistleblower and I'm not going to stand in your way. Just bear in mind that - if your package to Germany does get intercepted - then it will neither be delivered nor returned; it will simply disappear and may end up being destroyed, with no notification to either the buyer or seller and you will technically be liable for a heavy fine. Your customer will be left without their item and will - in all probability - file an INR claim with their CC company, PayPal or other payment processor.

FWIW it cuts both ways. A number of US states have recently introduced local import taxes, which the customer has to pay. Etsy collects these taxes at the checkout when a sale is made and will soon be doing the same for Norway, which has just passed laws allowing the collection / remittance of VAT / duty at the point of purchase.
It may stop, but it never ends.

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Chris Willocks
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Re: Selling Eurorack Modules & Complying to Directives

Post by Chris Willocks » Fri Apr 03, 2020 6:06 am

Alfrede wrote:
Fri Apr 03, 2020 12:02 am
Is there a ebay link ?
I have had a few of the modules on eBay in the past week or so, just to test the water, so to speak. The feedback has been good so far. There aren't any on there at the moment, but I plan to have a dedicated site up and running in the near future.

Regarding these rules and regulations; I contacted the CE Marking Association and told them what I plan to sell. This is what they replied with:

If you are only “Placing on the Market” the modules, and NOT the assembly with a PSU, then based on your comments that the device is purely Analog, with no Digital Electronics, no Radio Devices, no Batteries, and is powered only from a 12VDC supply not part of the module then the Directives that will apply are;

The CE Marking Directives:

- The Restriction of Hazardous Substances in Electrical and Electronic Equipment (RoHS) Directive 2011/65/EU
                          
Non CE Marking Directives that will apply:

- The General Products Safety Directive (GPSD) 2001/95/EC – If a Consumer Product

- The WEEE Directive 2012/19/EU

They also said that REACH applies to manufacturers when processing products and that it isn't a product regulation exactly.

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