UK specific laws regarding the sale of self made electrical goods?

[ChristianB]

Hey all.
I plan on making my own lighting to sell on the high street in the southwest of England. But was looking for advice upon the laws regarding this.
As an example, there are plenty of kitchen cupboard spotlight kits, or Christmas LED lights, that could be added to a sculpture, or set in resin. Not ideal obviously, but better than the low voltage battery powered chinesium rubbish options available. Do you have to get CE testing or other test for something like that before selling the finished sculpture?
Keeping it simple, you can buy a bulb holder, flex and mains plug as a pre-made kit. If I mounted that to a block of wood, are there legal requirements I have to meet before I could sell it as a finished product?
If i purchased the bulb holder, flex and plug as three separate items, connected and mounted them to a block of wood, does that have different legal requirements?

Basically, I want to make large lighted resin and wood composite sculptures. I accept that self CE testing is a given requirement. Is PAT testing a necessary requirement? Is there something else I need to consider or allow budget for?

I cant even begin to plan the finished products until I have this settled.If my only cost effective option is to use Christmas tree lights, I probably wont even bother lol.

 

[Bluejets]

connected and mounted them to a block of wood,

As already explained, this is where you need the certification.
You are effectively producing an item for public consumption, without any recognised electrical training, without any certification to say the product has been deemed safe to use on any mains grid.
These days with so many just looking for the least possible opportunity to sue your ass, I'd be making some queries in relevant government circles rather than here.
Just my 2 pennies worth mind.......

 

[kellys_eye]

You'd need Public Liability Insurance to do this anyway and good luck finding a company willing to give you that on the basis of what you're doing......

 

[ChristianB]

As already explained, this is where you need the certification.
You are effectively producing an item for public consumption, without any recognised electrical training, without any certification to say the product has been deemed safe to use on any mains grid.

Exactly! I want to do this properly. My apologies if that wasn't clear.
I already produce sculptures from various materials, mostly glass, wood and resin. The next logical step is to introduce lighting to them to have functional as well as decorative items. It obviously couldn't take a degree in electrical engineering in order to produce a simple desk lamp, but if some kind of formal training is required, then I am prepared to undertake it.
Someone mentioned in my welcome thread (my apologies I forget the name) about using pre approved ELV power supplies for LED lighting. That sounded like a pretty good place to start. I am looking for the path of least resistance, to add lighting to my work and have it absolutely safe and legal for sale in the UK. While avoiding battery or USB powered options.
I'm not trying to reinvent the wheel here. So if there are already products on the market I can incorporate into my work to avoid legal red tape then i would happily be open to suggestions.
Public liability insurance isn't a legal requirement. But you would be a fool not to have it. I didn't realise I would have any difficulty finding cover, I will have to look into that as well, thanks for the tip.

 

[Alec_t]

Regarding the legal side, perhaps an online Legal forum might be the best place to look for advice?

 

[Arouse1973]

Unfortunately you can't really avoid the red tape unless you are producing a kit where the public build it themselves, then it's a little easier. As a minimum you would need EMC testing, ESD, LVD and possibly IP testing and environmental testing. The last two are to prove reliability of the product, not really necessary but worth doing.

Unfortunately a lot of people think CE+CE=CE is does not. Even if you are using a CE certified product in your product you still need to get it tested to prove you haven't effected the CE marking of that equipment and to prove yours is safe to use.

Thanks
Adam

 

[Harald Kapp]

Someone mentioned in my welcome thread ... about using pre approved ELV power supplies for LED lighting.

I think that's your best option.

you still need to get it tested to prove you haven't effected the CE marking of that equipment and to prove yours is safe to use.

The CE-label (and the accompanying CE declaration) are issued by the manufacturer. This is a declaration made by the manufacturer himself.
There is afaik no legal need to obtain this certification by a recognized institution. The manufacturer 'only' has to ensure that his product complies with the requirements (acc. to CE) that are applicable to his product (which are different for different products).
BUT to close the circle: You are abviously not in a situation to ensure compliance without extensive testing. Here's where the testing labs come into play which will test your product and (hopefully) issue a certificate of compliance. This is going to set you back a few thousand pound and is probably prohibitively expensive.
If you use pre-certified lighting products to illuminate your work, you will probably not need all that testing, provided you installed the lighting according to the manufacturer's instructions. Also there is a (in your case I assume small and tolerable) risk that the pre-certified components can show effects that are not conform with Ce requirements (e.g. if using multiple lighting products they generate radio interference through unwanted interaction).


By the way: If you market your products there is more to CE certification than just the electronic side. CE requires a lot more, e.g. you need to provide a manual in the language of the country where you market your product, you need to ensure that all components used are safe, that includes (besides the obvious lighting discussed above) use of save varnish, avoidance of any sharp edges where one could cut one's skin etc. etc.

 

[Arouse1973]

If you install a CE marked product into your product and you "Bring to Market" another product which contains a CE marked product you still have to have the testing done.
Adam

 

[ChristianB]

Very true Alec, that may be worth a look.
Adam, you are a legend!
Those few acronyms alone have lead me on a very enlightening route for study. Admittedly the focus of my research is on finding exemptions to EMC testing which seems to be the biggest hurdle, as many thousands of pounds worth of testing for a one of a kind desk lamp does sound a little extreme. Effectively preventing anyone other than larger businesses selling their own work.
"Identify whether an independent conformity assessment (by a notified body) is necessary."
Is the pertinent part in my investigation. I shall make some enquiries with trading standards as they are the chaps enforcing these regulations.
Fingers crossed, in three to five working days, i will have all of the answers i seek.

 

[ChristianB]

Thank you Harald, that's very informative.
Apart from the lighting side of it, the products would conform with CE testing requirements.
I have a lot of research to do, just have to wait for a response from trading standards to confirm some finer points.
Many thanks.

 

[Arouse1973]

Very true Alec, that may be worth a look.
Adam, you are a legend!
Those few acronyms alone have lead me on a very enlightening route for study. Admittedly the focus of my research is on finding exemptions to EMC testing which seems to be the biggest hurdle, as many thousands of pounds worth of testing for a one of a kind desk lamp does sound a little extreme. Effectively preventing anyone other than larger businesses selling their own work.
"Identify whether an independent conformity assessment (by a notified body) is necessary."
Is the pertinent part in my investigation. I shall make some enquiries with trading standards as they are the chaps enforcing these regulations.
Fingers crossed, in three to five working days, i will have all of the answers i seek.

It is paramount that your product is safe to use. Please don't skimp on testing. I can't express how very important it is. I have been involved in EMC product testing for 20 years and you will surprised what people try and get away with. Remember CE marking is the bare minimum you need. I have tested products to far beyond the requirement.
Adam