Certifying IoT products

A couple of weeks ago, IoTBLR — a community of startups and professionals working on IoT, had organized an excellent session on certifications. Two experienced professionals — Mr. Kannan Dhamodharan, Director of Tejas Networks, and Mr. Kalyan Verma, VP of TUV Rheinland were kind enough to spare some time to share their knowledge with a crowd of about 30–50 enthusiasts.

Here are some highlights from their talks.

Why certify?

The need for certification could be due to regulatory requirements [laws of the land], or could be due to the the sensitivity of the environment in which the product is to be used — for example, the automotive industry demands stringent certifications for electronic products that go in to cars. The focus of this session was largely on regulatory requirements for certification.

India Regulations

In India, the TEC (Telecommunications Engineering Center) has a mandate to regulate and approve products in the telecom sector. The BIS (Bureau of Indian Standards) mandates registration of electronic and IT goods under ‘compulsory registration’ scheme — however, only some 30-odd products, mostly IT related are regulated by the BIS. Go to the section titled ‘ List of Electronics and IT Goods under ‘Compulsory Registration Scheme’ in the web page below for the complete list: http://www.bis.org.in/cert/ProdUnManCert.asp.

For IoT, here’s the key thing: there is apparently another organisation named WPC (Wireless Planning and Co-ordination Wing) that has the mandate to regulate and certify products that use wireless communication in general. Any IoT product that has a wireless transceiver would eventually need to be registered with the WPC, before being legally able to sell in the domestic market! Here is the web page of the WPC in case you want to find out more: http://www.wpc.dot.gov.in/

One other point to be aware of here, is recent regulation on Lithium-ion and Lithium-polymer batteries. These batteries have recently been added to the list of products regulated by the BIS, and hence when selecting a battery vendor, make sure that they have appropriate BIS certification.

EU Regulations

It is mandatory to have CE marking for products sold in the EU. A CE marking indicates:

1. Conformity with EU Directives with regards to safety, health, environment and consumer protection.
2. License to sell the product throughout the ~30 countries within the European Economic Area (EEA).

Steps to CE Marking

1. Identify the applicable directives and standards.
2. Perform Compliance Testing
3. Check if NB [Notified Body, a government regulator — similar to the FDA in US] certification is required. This is usually required for medical devices.
4. Made a Declaration of Compliance (DoC).
5. Affix CE marking on product.

EU Directives

There are some 21+ Directives which list out broad categories of requirements. Some are generic while some are product specific. The directives are published by the Official Journal of EU (OJEU).

Link to EU Directives: http://ec.europa.eu/growth/single-market/ce-marking/manufacturers/directives/index_en.htm

USA Regulations

In the USA, the FCC regulates radio, television and spectrum. The OSHA (Occupational Safety and Health Administration) dictates safety requirements.

OSHA Requirements

The OSHA mandates certification for safe use of electrical and electronic equipment. THe certification needs to be done at an NTRL (Nationally Recognized Testing Laboratory) — which is an independent lab recognized by OSHA to test and certify products for safety. Factory inspection is part of NTRL safety certification to ensure that the manufacturing process would ensure compliance.

FCC Requirements

This is a whole topic in itself but these are some points I noted down.

EMC

EMC (Electro Magnetic Compliance) is the ability of an electronic equipment to tolerate a specified degree of electromagnetic interference and to not generate more than a specified amount of electromagnetic interference itself. Mr. Kannan gave the useful example of a drilling machine causing interference in older CRT televisions — due to electromagnetic interference. In practice, the practical impact can be minor annoyance to lethal.

EMC Testing

EMC Testing comprises of the following

1. Electromagnetic interference which could be due to radiated emission or due to conducted emission.
2. RF disturbance: radiated and conducted.
3. Surge and Fast Transient [for example, due to lightning or inductive loads].
4. ESD (Electrostatic Discharge) — from charged objects nearby including humans.
5. Voltage dips and short interruptions in supply.

Mr. Kannan Dhamodharan walking the audience through an EMC failure.

CB Scheme

The CB (Certification Body) is an initiative of the IEC (International Electrotechnical Commission) and seeks to provide a single testing framework, mainly for safety requirements globally. Currently, the CB certificate is accepted by over 43 countries including India, USA, Germany and China. Within each country, an NCB (National Certification Body) issues certificates based on testing reports from CB accredited laboratories.

CB requirements

This is a vast topic, but some aspects that might be important to keep in mind at the onset of designing an IoT product might be:

1. Safety from Electrical Hazard — thinking about insulation material, earthing, etc.
2. Safety from Fire Hazard — thinking about over-current protection, using fire retardant parts, designing enclosures to prevent spread of fire, etc.
3. Safety from Heat Hazard — provisioning for markings to warn users in case portion of a product expected to heat up. Selecting good parts.
4. Environmental Safety — it is important to be aware of RoHS (Restriction of Hazardous Substances) regulation for CE mark, under which 6 substances, including Lead (Pb) are restricted. There are also REACH regulations for CE mark — under which some 1000 substances hazardous to human health or environment are restricted. Lastly, there is the WEEE (Waste Electrical and Electronic Equipment) regulation — again for CE mark, under which manufacturers are required to finance collection, treatment and safe disposal of electronic products.

Putting it all together

Mr. Kannan and Mr. Verma shared a framework for pulling in regulatory requirements in to the initial R&D phase of products. Here are some of my key takeaways.

1. Capture the certification requirements as part of the product requirements document itself. The certification requirements depend on the type of product and target market countries. Once you have a clear picture of this, speak with a reputed testing tab — such as TUV Rheinland (they have a facility in Bangalore) for certifications that would be required for your product and for an approximate testing time and cost estimate.
2. Allocate time and budget right at the start! This is important as in the initial phases of development, most startups would tend to ignore regulatory requirements, but in my opinion based on this session, it might be better spending some extra time and money thinking about this at the start, rather than spending more time and money later, on fixing stuff.
3. Use approved/certified components in safety critical portions of your design. For example, use a certified power module if readily available. Use certified fuses, batteries, etc.
4. For wireless modules (and this should be important in most IoT applications) — use FCC/CE certified modules. This dramatically reduces cost of testing [in my estimate, this would reduce cost from INR 5L to 50K, although this is my own estimate — not from the speakers]. There would still be some testing involved because product level testing for spurious emissions, etc., would still need to be carried out on the whole product.
5. Collect and review RoHS CoC (Certificate of Compliance) from component manufacturers.
6. Get help on best PCB layout practices to pre-empt any EMC issues later on.
7. After your prototype is built and passes through EMC, Safety and Radio testing [depending on your target certifications/markets], compile a ‘Technical Construction File’ which should contain all the functional block diagrams, schematics, layouts, product photographs, the compliance test reports and finally your DoC (Declaration of Compliance).
8. After you file your DoC, your products can be marked with the “CE”, or “FCC” (or “BIS”) approved marks and you should be ready to sell!

That’s it folks

I am grateful to Mr. Dhamodharan and Mr. Verma for sharing their insights with the IoTBLR community. Nihal — the convenor of IoTBLR has shared their complete presentations online at this link: https://drive.google.com/drive/folders/0B2sEn9zYMmdCT0dTNGJBUTJYbWs

Bottom-line

include regulatory requirements in your product requirements document. Use certified RF modules where you can. And allocate time and budget for certification testing.

Good luck. If you have any comments or suggestions, please do get in touch! Together, we can be #AheadOfWhatsPossible