Depressing

[XxionxX]

Thank you kindly for the info ED. That particular point was something of a thorn in my side.

 

[spaceballs3000]

ED you pretty much just confirmed what I feared most regarding CE certification when you said

... CE test is way cheaper (as it is a self-certification and you don't need to pay for any approval, just for the test). ...

That caused me to re-read some of your old CE posts that I might have missed, as CE isn't that much cheaper than FCC, in regards to an uncertified radio device, as your required to use "Telecommunications Terminal Equipment (R&TTE) Directive of 2000." And don't say it doesn't apply the Pandora as it does.

And I did found one I missed from you, where you say

Look, I told the certified (certified by the authorities in Germany!) lab multiple times it has WiFi.
And they confirmed me multiple times that CE doesn't care about WiFi. ...

The CE testing authorities would only not care if the WiFi module was CE certified, but it is not (which I have confirmed.)
Sounds like Pandora team did not communicate properly with the CE testing authorities, as the Pandora contains a unlicensed 2.4 GHz device.

I'm sorry to say but the CE certification for the Pandora is 100% invalid at this time, see this thread and is illegal to sell even in EU in it's current state (Wifi enabled.)

As a recommendation, I suggest disabling all radios via software if you plan to sell more without proper CE certification. *But* I would confirm with CE certification testing group that this would properly get you around the unlicensed 2.4 GHz device issue.

---
Note everything above is just my personal opinion of the situation as I see it.

 

[Pickle]

No one within USA who received the Pandora had any problems receiving the unit yet.

I have....I cant stop using it.

 

[Mjlink]

No one within USA who received the Pandora had any problems receiving the unit yet.

I have....I cant stop using it.

+1

 

[EvilDragon]

The CE testing authorities would only not care if the WiFi module was CE certified, but it is not (which I have confirmed.)

So, how come I got the FCC and CE testing report from the manufacturer which has been confirmed to be valid?

Sounds like Pandora team did not communicate properly with the CE testing authorities, as the Pandora contains a unlicensed 2.4 GHz device.
I'm sorry to say but the CE certification for the Pandora is 100% invalid at this time, see this thread and is illegal to sell even in EU in it's current state (Wifi enabled.)

Sorry to tell you it is not.
I talked to the TUEV and the Bundesnetzagentur (they handle the CE conformity testings in Germany) later. Yes, wireless test was necessary later, it has been added a while ago. When we did the first test, it was not necessary. But as that changed, I wanted to do it anyways, as it was a quick test and not too expensive, as the module is precertificated (yes, guess what, the testing report I mentioned above which you confirmed to not exist was valid according to the authorities).
However, FCC does cost applying for the documents, whereas CE only is a self-certification and therefore no expensive applying needed.

Yes, just to apply for FCC does cost about 8000 EUR in Germany. And as the tests are slightly different than the CE tests, you need to redo them again, which costs another few thousand EUR.

As a recommendation, I suggest disabling all radios via software if you plan to sell more without proper CE certification. *But* I would confirm with CE certification testing group that this would properly get you around the unlicensed 2.4 GHz device issue.

Well, if I were you, I would confirm things before writing them down.
It would still interest how you confirmed that the module is not certified and pretested, when I have a full 123 pages testing report for that module?

If everything you confirmed is as reliable as that...

 

[sold]

ED you pretty much just confirmed what I feared most regarding CE certification when you said

... CE test is way cheaper (as it is a self-certification and you don't need to pay for any approval, just for the test). ...

That caused me to re-read some of your old CE posts that I might have missed, as CE isn't that much cheaper than FCC, in regards to an uncertified radio device, as your required to use "Telecommunications Terminal Equipment (R&TTE) Directive of 2000." And don't say it doesn't apply the Pandora as it does.

And I did found one I missed from you, where you say

Look, I told the certified (certified by the authorities in Germany!) lab multiple times it has WiFi.
And they confirmed me multiple times that CE doesn't care about WiFi. ...

The CE testing authorities would only not care if the WiFi module was CE certified, but it is not (which I have confirmed.)
Sounds like Pandora team did not communicate properly with the CE testing authorities, as the Pandora contains a unlicensed 2.4 GHz device.

I'm sorry to say but the CE certification for the Pandora is 100% invalid at this time, see this thread and is illegal to sell even in EU in it's current state (Wifi enabled.)

As a recommendation, I suggest disabling all radios via software if you plan to sell more without proper CE certification. *But* I would confirm with CE certification testing group that this would properly get you around the unlicensed 2.4 GHz device issue.

---
Note everything above is just my personal opinion of the situation as I see it.

If you added that little afterthought at the bottom of your post stating everything above is your personal opinion (and is hence subjective), why are you trying to pass it off as irrefutable fact earlier in your post? You emphasize your point in bold and then you go and say its just your opinion? Or are you trying to say that your "opinions" are actually facts, making everybody else "wrong"?

Also, you say you work for a company that manufactures hardware. I am guessing they aren't hobbyists who started a community oriented "open" project from scratch and had to piece it all together basically on the fly. I'm also guessing the company you work for has more capital and well established business relationships with other companies. And I bet they can afford to pick and choose who they work with (another luxury that can only be afforded if there exists enough working capital) whereas the Pandora team could not.

My point is, it takes money and know-how to make ANYTHING work well. The more of both you have, the better your end result will be. Throw experience and good connections into the mix and you can be fairly confident of guaranteed results. I think the OP dudes have learned the hard way and the fact that they are still going should be applauded. Sure it is taking a while. But I think they are gonna succeed and when they succeed, it will just go to show how hard they have worked and how much they have learned.

In regard to the CE testing, isn't it doubtful that the people conducting the test would mess it up that bad that they would let non compliant hardware pass? Wouldn't that make them liable for any damages or costs caused by their error in the long run? I don't know much about CE or FCC testing, just wondering...

 

[spaceballs3000]

It would still interest how you confirmed that the module is not certified and pretested, when I have a full 123 pages testing report for that module? ...

I too have this 123 pages PDF from the manufacture also, I bet the PDF is named "WG7210 WLAN+BT TX SM FCC CE Test Report" guess what it's about, it's the "pre-scan on EMI test report" it would only help in getting full CE compliance (for Wifi) tests go faster, but doesn't make it all that much cheaper in the end due to paperwork involved.

Btw this was discussed earlier here in this thread where you even posted in it.

... But as that changed, I wanted to do it anyways, as it was a quick test and not too expensive, as the module is precertificated (yes, guess what, the testing report I mentioned above which you confirmed to not exist was valid according to the authorities). ...

Someone is lying when they said "was valid according to the authorities", as the "WG7210 WLAN+BT TX SM FCC CE Test Report.pdf" doesn't automatically make module CE (or FCC) precertificated, especially with a module that requires you to add in your own antennas.

If you have any other reports, feel free to PM them to me.

---
Note everything above is just my personal opinion of the situation as I see it.

 

[spaceballs3000]

...
If you added that little afterthought at the bottom of your post stating everything above is your personal opinion ...

It's there in case my advice about disabling radios still doesn't protect about uncertified radio device being in the pandora is wrong. As that's more of a question for as the right body to ask.

Also, you say you work for a company that manufactures hardware. ...

No I'm the owner of the company.

 

[Twiitcher]

Personally whenever I see the poster tag = spaceballs3000 I just totally disregard any text contained therein as inaccurate, inflammatory and basically not worth my time to bother reading.

Just sayin.

Twiitcher

 

[EvilDragon]

It would still interest how you confirmed that the module is not certified and pretested, when I have a full 123 pages testing report for that module? ...

I too have this 123 pages PDF from the manufacture also, I bet the PDF is named "WG7210 WLAN+BT TX SM FCC CE Test Report" guess what it's about, it's the "pre-scan on EMI test report" it would only help in getting full CE compliance (for Wifi) tests go faster, but doesn't make it all that much cheaper in the end due to paperwork involved.

As said, you're talking about FCC here. I'm talking about CE. As I said, we did not apply for FCC certification, we just basically tested that it should be fine as well.
CE doesn't need any paperwork. You can check the official page about it.

Are all CE marked products tested and approved by authorities?

No. In fact, the assessment of the conformity of the products with the legislative requirements applying to them is the sole responsibility of the manufacturer. The manufacturer affixes the CE marking and drafts the EC Declaration of Conformity. Only products which are regarded as presenting a high risk to the public interest, e.g. pressure vessels, lifts and certain machine tools, require conformity assessment by a third party, i.e. a notified body.

Can I, as a manufacturer, affix my products with the CE marking myself?

Yes, the CE marking is always affixed by the manufacturer himself/herself or his/her authorised representative after the necessary conformity assessment procedure has been performed. This means that, before being affixed with the CE marking and being placed on the market, the product must be subject to the conformity assessment procedure provided for in one or more of the applicable directives. The directives establish whether the conformity assessment may be performed by the manufacturer himself or if the intervention of a third party (the notified body) is needed.

In the case of the Pandora, the testing can be done by the manufacturer himself.
As I don't have the tools nor knowledge to do myself, I let that do from a testing lab.

]

... But as that changed, I wanted to do it anyways, as it was a quick test and not too expensive, as the module is precertificated (yes, guess what, the testing report I mentioned above which you confirmed to not exist was valid according to the authorities). ...

Someone is lying when they said "was valid according to the authorities", as the "WG7210 WLAN+BT TX SM FCC CE Test Report.pdf" doesn't automatically make module CE (or FCC) precertificated, especially with a module that requires you to add in your own antennas.

That's exactly was PREcertified means.
You ALWAYS need to test it within your device. But if it was not precertified, you would have to test the MODULE alone first and after that, test it within the unit again.

Maybe precertified is the wrong terms and I should say pretested.
That doesn't change anything for CE, as the manufacturer does the certification itself.

It might make a difference with FCC (where I said multiple times that we didn't apply for it as we don't need it), however, I'm not sure that a WiFi module manufacturer needs to apply for an FCC certification as it wouldn't make sense (the final device manufacturer has to test and apply for it).

However, the pretesting is an important factor when it comes to the final test.
Without the pretest report, you need to test the module and after that, the module within the device. That costs twice as much money.

Are you confusing CE with FCC?

For FCC, you need to apply for the certification from the authorities, with CE, you simply have to provide a Declaration of Conformity (after making sure your device conforms, of course).

So the certification costs a lot of money for FCC and NOTHING for CE.
The FCC test itself costs about the same as the CE test. But as the FCC certification itself costs money, you pay double (for test and certification).

 

[spaceballs3000]

... In the case of the Pandora, the testing can be done by the manufacturer himself.
As I don't have the tools nor knowledge to do myself, I let that do from a testing lab.

From your own link.

... The directives establish whether the conformity assessment may be performed by the manufacturer himself or if the intervention of a third party (the notified body) is needed.

Well happens that the Radio and Telecommunication Terminal Equipment (R&TTE) directive will require the radio transmitter in the Pandora will make it mandatory that you use a third party (the notified body) for approval, but hey why take my word for it
From rfi-global

CE marking for end host products with integrated radio modules is achieved by demonstrating compliance with the Radio and Telecommunication Terminal Equipment (R&TTE) directive. In the majority of cases for end host products, the R&TTE directive will place the following requirements, known as “articles”, on the manufacturer:
- Safety, including RF Exposure – as defined in Article 3.1a.
- EMC – as defined by Article 3.1b.
- Radio and Telecommunication Terminal Equipment (R&TTE) - as defined by Article 3.2.

or from this page beide-productservice

Radio & Telecommunications Terminal Equipment
(R&TTE) Directive
With the exception of a few categories of equipment, the R&TTE Directive applies to all equipment that uses the radio frequency spectrum.

... to ensure that their products are compliant with the Directive and carry a valid CE Marking in order for them to be placed on the open market or into service within Europe.

In Summary for a valid CE mark, you need Declaration of Conformity because since you have a RF radio in the Pandora. This requires you getting an approval from a Notified Body for the New Approach Directives, i.e. "99/5/EC Radio and telecommunications terminal equipment". So the Notified Body can issue a Certificate of Conformity in order to verify performance of the product.

...That's exactly was PREcertified means.
You ALWAYS need to test it within your device. But if it was not precertified, you would have to test the MODULE alone first and after that, test it within the unit again.

Maybe precertified is the wrong terms and I should say pretested.
That doesn't change anything for CE, as the manufacturer does the certification itself.

I don't think you understand what I was saying, I actually called and talked to the WiFi modular manufacture (I was thinking about using their module at one time), in their words they said the device it *Not* CE (or FCC) precertified, or certified, etc... And yes they did give me with the same document showing that the module could pass CE testing (i.e. the Radio and Telecommunication Terminal Equipment (R&TTE) directive within CE.)

So the certification costs a lot of money for FCC and NOTHING for CE. ....

If you go and talk to "TUEV and the Bundesnetzagentur" and let them know your 802.11 WiFi radio is not even pre-certified, and requires Radio and Telecommunication Terminal Equipment (R&TTE) testing work to be done (on the module and the Pandora), I bet CE costs will be a lot more then you realize.

 

[XxionxX]

The name of this thread says it all. I hope to read better news in the morning. This is the worst thread ever, no offense ED or spaceballs3000 but this is some intense information. I am off to consume more alcohol because this thread makes me feel shitty.

 

[Sugar_Kane]

Well ed looked into it, as he says, and did the required tests already so that's good enough for me. You can put your own hardware through as many tests as you like, perhaps with the agreement of people that actually care that you have a company?

 

[andyB911]

No I'm the owner of the company.

Interesting. Please tell us which company and what you make.

 

[Twiitcher]

Threat Level

Twiitcher

 

[sold]

That Barbie thing linked above freaked me out and then I read some of the comments which freaked me out even more. Why the fuck would anyone think it appropriate to put a camera in a Barbie doll? I mean, little girls who play with Barbies are gonna break it in like five minutes flat. So that just leaves pedophiles. And the comments were so lame, trying to say that the FBI putting the frankenbarbie on their list of things to check in raids on pedophiles is unnecessary kinda pissed me off. I always thought there was something wrong with the whole Barbie thing.

Back on topic (kinda): I wonder if every component in that barbie was properly CE tested... (J/K).

Why would the manufacturer of the wifi module be selling it without it being certified? Wouldn't that be kinda stupid?

EDIT: And isn't the FCC an American thing anyway? And if yes, why would it be required for the rest of the world? And if someone from America chose to import a Pandora for personal use, is it even necessary?

 

[skeezix]

Friend or Family, when any significant amount of money is involved a contact is your friend when things hit the fan.

You have said one thing in your entire time here that I have fully agreed with, and this is it. It goes further though: not just when things go bad, but when things are going good, too. Nothing can tear apart a friendship faster than a couple million dollars and no one remembering how they agreed to divide it.
For good reasons and bad, friend or not, a properly written contract is a very good thing.

Of course, the other side of the coin -- we all know contracts mean crap 3/4 of the time as well; I've had big 'respectible' companies totally step on my contracts or screw me around simply because they can. (And don't go thinking this is rare .. your Walmarts, Canadian Tires, Home Depots etc all make a living by squeezing the hell out of their suppliers and playing fast and loose). If you're not large enough to defend a contract, it has no real value I coudl go lay some pain on some billion dollar companies, but I would *lose* Small guys in other crountries too -- you want to pay lawyers in two countries to go get them? Contracts are a good form of documentation, and sometimes even helpful, and you should always have them.. but in the end, they usually don't mean all that much .. you want decent respectible companies first, referrels etc. (And oddly enough, the companies OPT works with have been referred .. go figure)

jeff

 

[skeezix]

Question here is .. whats the point of spaceballs posting here in this thread? just trolling or trying to get himself some hate?

If you're trying to be helpful in some odd fashion, then this isn't the place to do it .. its throwing salt in the wounds.

But if you're trolling, well, good job, carry on. *shrug*

jeff

 

[geise69]

Question here is .. whats the point of spaceballs posting here in this thread? just trolling or trying to get himself some hate?

If you're trying to be helpful in some odd fashion, then this isn't the place to do it .. its throwing salt in the wounds.

But if you're trolling, well, good job, carry on. *shrug*

jeff

If he wants to continue with his FCC debacle with ED then he can do it through PM. There's no real need for it here at all. If he continues to PM ED, then maybe he is trying to be helpful. If not, then he's just trolling along. Then again there is an ignore button.

 

[XxionxX]

I am not commenting on this thread any more. I don't want to contribute to this mess. I refuse to provoke any more ugliness.