Compliance Update: We Will Boycott the UKCA (and You Should Too!)
The EMC compliance saga seems to be never-ending. The certification house is still picking over the verbiage in our user manuals (apparently, we need to explicitly inform EU users that it’s safe to hold a Precursor to your head), and we’re revising our labeling to fall in line with what they say are the minimum requirements. I guess if you’re an Apple or Samsung you can get away with simply “Apple / Cupertino, CA” or “Samsung / Seoul, Korea” as your “address”; but for a small player like us, apparently we need to include the entire postal address of our factory from the street number down to the postal code on the outside of the product. I’m not sure exactly what that’s supposed to accomplish, but when you flip over your Precursor, you’ll be greeted by a wall of text silkcreened on the radome, just in case you need to physically mail a letter to the contract manufacturer to inquire about compliance issues.
Also, to our current and potential users in the UK: apparently, as part of Brexit, your illustrious lawmakers have decided it’d be a great idea to refuse the EU’s CE certification, so in order to import products to the UK they must also get the “
UKCA” mark. This was originally slated to go into effect on Jan 1, 2022, and I was preparing to inform all of you that I was simply going to cancel your shipments and refund your money. Fortunately for the early backers, that deadline was just extended to Jan 1, 2023, so you’ll be able to import a Precursor with the CE certifications that, with great effort and cost, we’ve managed to procure.
That being said, we plan to disallow new sales of Precursor into the UK starting in the fourth quarter of 2022, because it simply is not worth it for us to seek a separate regulatory marking for the UK. Although the UKCA has a 1:1 mapping to the CE today, there’s no guarantee it will stay that way. Furthermore, it is still a separate marking, which costs real money to process; and our manuals, boxes, and case parts would have to be scrapped or reworked to bear the mark. This is both wasteful and unsustainable, as the endpoint of this road is our products bearing the unique regulatory marks of hundreds of territories and regions with no substantive benefit to the consumer or the producer; it’s already silly that we even have to have to bear
both FCC and CE markings.
Thus, I also want to send an unambiguous message that this return to pre-industrial mercantilism and rent-seeking behavior by the certification bodies
will not be tolerated. I ask that other makers of hardware join me in boycotting the UKCA. The global certification regime is already fractured and frankly a bit silly, and we need to make it clear that there are real costs that we the manufacturers shall not bear when trade barriers are raised for the sake of political theater. If manufacturers keep on eating escalating tariffs and compliance costs, then there is virtually no pressure on politicians to reign in these kinds of trade policies: they are a cheap & visible political win, with no local economic cost.
Instead of creating fresh regulatory barriers for the sake of having barriers, we should be moving toward harmonizing the world around a single common compliance and safety data reporting standard. At the end of the day, the laws of physics are the same whether you’re in the EU, USA, China, or even the UK. We should be promulgating traceable, accessible calibration standards while lowering barriers to the submission and access of raw compliance data: let the data speak for itself, leave the geopolitics out of it!
Happy hacking,
- bunnie & Xobs