5 ms·

> "actual regulations...emissions" yeah, and looking at their board I see they use one of "ESP32-WROOM" modules, which has the wifi & blutooth & antennae (pre-

> "actual regulations...emissions" yeah, and looking at their board I see they use one of "ESP32-WROOM" modules, which has the wifi & blutooth & antennae (pre-certified by Espressif for FCC, CE so itself doesn't need testing) & flash & processor (which even has its own RC oscillator), which takes care of a whole ton of difficult stuff so all the designer needs to do is plop that module down and power it up and wire some SPI/I2C peripherals which I'm guessing don't need super fast clocks or electrical constraints. Without something like those ESP32 modules, this would be much more difficult.

delusional 3mo ago
> Without something like those ESP32 modules, this would be much more difficult. I don't disagree. It's important for us to recognize that we stand on the shoulders of giants, but I also think it's a little silly of a critique of someone happy about it being easier than he expected. It's true that hardware would be much harder if you had to do it all yourself, but is that meaningful? The wonders if the modern supply chain is that you don't need to do it all yourself.
- em3rgent0rdr 3mo ago
  Well the title and premise is a bit silly. If you're designing easy hardware by wiring parts together that already do all the hard stuff, then "hardware is not so hard" is something you might conclude, but that only applies for designing easy hardware like this. But if you are doing anything that pushes the limits or involves analog signals and having to worry about signal integrity and EMI and impedances and Laplace transfer functions all that other stuff that requires degrees, then "hardware is hard".
ssl-3 3mo ago
The ESP32-S3-WROOM1 module is FCC certified for its own Wifi and Bluetooth emissions when used by itself. And, well -- that's certainly good. But the FCC rules cover more than just Wifi and BT, and the whole rest of the widget also needs to comply with them. Of particular interest is FCC Part 15 Subpart B, which covers unintentional radiators. The device would need to comply with Part 15 Subpart B even if it had nothing to do with Wifi or BT. Putting one part that is certified for one issue into a device doesn't extend a magical blanket of compliance to everything else that the whole of the widget contains. Does the SPI or I2C bus (or anything else) leak RF beyond allowable limits? Eh, who knows. I certainly don't know. It's easy to say words like "it should be fine," but without testing then nobody actually knows. The CE mark, meanwhile: That mark means exactly nothing in the US, where the author is located and the devices are sold from. The United States has zero regulatory recognition of any of the processes and/or tests that CE may cover. People often confuse this issue, wherein: They don't think it be like it is, but it do.
- tough 3mo ago
  A fun fact of the CE mark, is that it's also used to signal "Chinese Export" deceptively, with the marks being almost identical beyond spacing.
  - stephen_g 3mo ago
    Of course there’s no actual official ‘china export’ mark and that is just what some Chinese factories were claiming when they were caught slapping a (accidentally mis-spaced) CE conformance mark on their products! The EC made a statement on this back in 2008 [1] so everyone knows what game they are playing. 1. https://www.europarl.europa.eu/doceo/document/P-6-2007-5938-ASW_EN.html?redirect https://www.europarl.europa.eu/doceo/document/P-6-2007-5938-...
    - crote 3mo ago
      Notably, that link does not repeat that "some Chinese factories were claiming...". It just states that some people put it on noncompliant products. It is unclear whether any Chinese factories ever made that claim.
      - tough 3mo ago
        we really should have trademarked that one or something https://www.eleconomista.es/retail-consumo/noticias/12360919/07/23/china-export-dos-decadas-enganando-a-los-consumidores-europeos-.html https://www.eleconomista.es/retail-consumo/noticias/12360919...
ost-ing 3mo ago
Im not an expert in emissions testing but pretty sure it still needs CE certification testing. The module shouldnt cause any problems providing that the firmware for the transmitter is configured properly, and is placed sanely in the enclosure, but the entire product must still undergo the relevant testing for 2.4GHz emitters. Just because you use a certified module doesn't give you a free pass.
- deleted 3mo ago
  [deleted]
- sieabahlpark 3mo ago
  [dead]
- nomel 3mo ago
  > but the entire product must still undergo the relevant testing for 2.4GHz emitters. To be fair, it's unintentional radiator testing that's required, rather than everything the module had to go through as an intentional radiator. So, it is a "free pass" for nearly all of it, and a much cheaper one, since you don't have to use a costly FCC accredited lab.
  - negative_zero 3mo ago
    Modular Approval is an FCC thing only. CE doesn't have it.
- pclmulqdq 3mo ago
  It does still need CE certification and emissions testing. I’m guessing they didn’t do that and it will be fine because they only sold 2,500 units.
  - crote 3mo ago
    Technically it doesn't - it just needs to be compliant. It is completely left up to you how you are going to demonstrate this if they ever come asking for the paperwork proving this. This can be a certification by an independent testing lab, documentation from in-house tests, or perhaps even documentation proving that it is compliant by design.
Max-q 3mo ago
The pre certified module do not exempt the product from testing. It only means that you don’t have to do the conducted testing and that it’s a higher probability for passing the other tests. There are still lots of chances to fuck up and a full radiated test of the product is required.
- Suppafly 3mo ago
  >and a full radiated test of the product is required legally?
  - jynsnsns 3mo ago
    Depends on the legislation, but for most markets yes
  - leoedin 3mo ago
    In the EU (and UK with UKCA), CE certification is down to whoever makes the product available on the market. There's no get out for pre-certified modules. If you put a pre-certified module in a box and sell it, you have to be responsible for the CE mark. You need evidence that the whole product complies with the EMC regulations. There's some judgement involved - if you put a certified circuit board in a plastic box, it won't change the EMC behaviour so you don't need to re-test. But if you solder a module onto a larger circuit board, you are almost certainly changing the EMC behaviour. You should definitely be re-testing something like that. The pre-certified module does save you some time in the "intentional radiator" testing - assuming you use the same antenna it was tested with as a module, you can probably make the case that the behaviour is the same. Will anyone ever notice or care for a few thousand niche devices? I doubt it. But to sell in the EU legally you do need to do that testing.
    - holowoodman 3mo ago
      No, you actually don't have to do the testing, except in some special circumstances (e.g. childrens' toys). Generally, the "CE" mark is a self-certification done by the manufacturer or importer that certifies that the product meets certain (category-specific) criteria. You can do the proper thing, test your product and then certify it. But it is also possible and usually legal to just issue the certificate based on a self-assessment and deal with the fallout later, if there ever is any. That's how basically all non-EU manufacturers and importers get their CE mark... https://europa.eu/youreurope/business/product-rules-compliance/general-product-compliance/ce-marking/index_en.htm https://europa.eu/youreurope/business/product-rules-complian...

delusional 3mo ago

> Without something like those ESP32 modules, this would be much more difficult. I don't disagree. It's important for us to recognize that we stand on the shoulders of giants, but I also think it's a little silly of a critique of someone happy about it being easier than he expected. It's true that hardware would be much harder if you had to do it all yourself, but is that meaningful? The wonders if the modern supply chain is that you don't need to do it all yourself.

em3rgent0rdr 3mo ago
Well the title and premise is a bit silly. If you're designing easy hardware by wiring parts together that already do all the hard stuff, then "hardware is not so hard" is something you might conclude, but that only applies for designing easy hardware like this. But if you are doing anything that pushes the limits or involves analog signals and having to worry about signal integrity and EMI and impedances and Laplace transfer functions all that other stuff that requires degrees, then "hardware is hard".

ssl-3 3mo ago

The ESP32-S3-WROOM1 module is FCC certified for its own Wifi and Bluetooth emissions when used by itself. And, well -- that's certainly good. But the FCC rules cover more than just Wifi and BT, and the whole rest of the widget also needs to comply with them. Of particular interest is FCC Part 15 Subpart B, which covers unintentional radiators. The device would need to comply with Part 15 Subpart B even if it had nothing to do with Wifi or BT. Putting one part that is certified for one issue into a device doesn't extend a magical blanket of compliance to everything else that the whole of the widget contains. Does the SPI or I2C bus (or anything else) leak RF beyond allowable limits? Eh, who knows. I certainly don't know. It's easy to say words like "it should be fine," but without testing then nobody actually knows. The CE mark, meanwhile: That mark means exactly nothing in the US, where the author is located and the devices are sold from. The United States has zero regulatory recognition of any of the processes and/or tests that CE may cover. People often confuse this issue, wherein: They don't think it be like it is, but it do.

tough 3mo ago
A fun fact of the CE mark, is that it's also used to signal "Chinese Export" deceptively, with the marks being almost identical beyond spacing.
- stephen_g 3mo ago
  Of course there’s no actual official ‘china export’ mark and that is just what some Chinese factories were claiming when they were caught slapping a (accidentally mis-spaced) CE conformance mark on their products! The EC made a statement on this back in 2008 [1] so everyone knows what game they are playing. 1. https://www.europarl.europa.eu/doceo/document/P-6-2007-5938-ASW_EN.html?redirect https://www.europarl.europa.eu/doceo/document/P-6-2007-5938-...
  - crote 3mo ago
    Notably, that link does not repeat that "some Chinese factories were claiming...". It just states that some people put it on noncompliant products. It is unclear whether any Chinese factories ever made that claim.
    - tough 3mo ago
      we really should have trademarked that one or something https://www.eleconomista.es/retail-consumo/noticias/12360919/07/23/china-export-dos-decadas-enganando-a-los-consumidores-europeos-.html https://www.eleconomista.es/retail-consumo/noticias/12360919...

ost-ing 3mo ago

Im not an expert in emissions testing but pretty sure it still needs CE certification testing. The module shouldnt cause any problems providing that the firmware for the transmitter is configured properly, and is placed sanely in the enclosure, but the entire product must still undergo the relevant testing for 2.4GHz emitters. Just because you use a certified module doesn't give you a free pass.

deleted 3mo ago
[deleted]
sieabahlpark 3mo ago
[dead]
nomel 3mo ago
> but the entire product must still undergo the relevant testing for 2.4GHz emitters. To be fair, it's unintentional radiator testing that's required, rather than everything the module had to go through as an intentional radiator. So, it is a "free pass" for nearly all of it, and a much cheaper one, since you don't have to use a costly FCC accredited lab.
- negative_zero 3mo ago
  Modular Approval is an FCC thing only. CE doesn't have it.
pclmulqdq 3mo ago
It does still need CE certification and emissions testing. I’m guessing they didn’t do that and it will be fine because they only sold 2,500 units.
- crote 3mo ago
  Technically it doesn't - it just needs to be compliant. It is completely left up to you how you are going to demonstrate this if they ever come asking for the paperwork proving this. This can be a certification by an independent testing lab, documentation from in-house tests, or perhaps even documentation proving that it is compliant by design.

Max-q 3mo ago

The pre certified module do not exempt the product from testing. It only means that you don’t have to do the conducted testing and that it’s a higher probability for passing the other tests. There are still lots of chances to fuck up and a full radiated test of the product is required.

Suppafly 3mo ago
>and a full radiated test of the product is required legally?
- jynsnsns 3mo ago
  Depends on the legislation, but for most markets yes
- leoedin 3mo ago
  In the EU (and UK with UKCA), CE certification is down to whoever makes the product available on the market. There's no get out for pre-certified modules. If you put a pre-certified module in a box and sell it, you have to be responsible for the CE mark. You need evidence that the whole product complies with the EMC regulations. There's some judgement involved - if you put a certified circuit board in a plastic box, it won't change the EMC behaviour so you don't need to re-test. But if you solder a module onto a larger circuit board, you are almost certainly changing the EMC behaviour. You should definitely be re-testing something like that. The pre-certified module does save you some time in the "intentional radiator" testing - assuming you use the same antenna it was tested with as a module, you can probably make the case that the behaviour is the same. Will anyone ever notice or care for a few thousand niche devices? I doubt it. But to sell in the EU legally you do need to do that testing.
  - holowoodman 3mo ago
    No, you actually don't have to do the testing, except in some special circumstances (e.g. childrens' toys). Generally, the "CE" mark is a self-certification done by the manufacturer or importer that certifies that the product meets certain (category-specific) criteria. You can do the proper thing, test your product and then certify it. But it is also possible and usually legal to just issue the certificate based on a self-assessment and deal with the fallout later, if there ever is any. That's how basically all non-EU manufacturers and importers get their CE mark... https://europa.eu/youreurope/business/product-rules-compliance/general-product-compliance/ce-marking/index_en.htm https://europa.eu/youreurope/business/product-rules-complian...