CE compliance | Raspberry Pi

Easter picture post

Jimmy’s sent over a some pictures taken during the setup for a couple of last week’s tests. I know a lot of you were interested in seeing what the inside of an anechoic testing chamber looks like. When you’re done geeking out, scroll down to the bottom for a bonus picture from a pub toilet. (Nothing to do with our EMC testing, but it has a bearing on CE marks of more than one kind.)

Radiative immunity test - the Raspberry Pi is at the front right corner of the table. The video camera at the left is for monitoring output while we run the test.

Setup for testing radiative emissions. The device standing against the wall at the left is a microwave horn for receiving frequencies above 1GHz.

So: the pub toilet thing. In the last week or so, we’ve all been hyperaware of any CE marks in our immediate environment because of all the work we’ve been doing to make sure we are allowed to use one. CE stands for Conformité Européenne, meaning “European Conformity”; it’s a mark which shows that the product it’s on conforms to whatever European directives govern the product type.

We’ve been particularly interested to observe all kinds of things, electronic and otherwise, which carry a mark which looks a lot like the CE mark, but which doesn’t mean Conformité Européenne. The other mark means China Export – you can see the difference between the two marks in this picture. It’s a sneaky-clever way some people try to get around the regulations.

Image from Wikimedia Commons

So I was really creeped out when I spotted the machine below in the ladies’ loo in a Norwich pub this lunchtime. Compare the symbol reading “CE” at the bottom to the ones above. (Yes, that is my glowing face reflected next to the lime. I do not actually have a unibrow; it’s lighting.)

Eugh.

Don’t rely on banana-flavour condoms.

Testing’s done!

Good news! We just received confirmation that the Raspberry Pi has passed EMC testing without requiring any hardware modifications.

As you may know, we’ve had periods booked in a testing chamber at Panasonic’s facility in South Wales for the whole week. Jimmy, Craig and Gareth from Gainspeed, our EMC consultants (with assistance from Phil the EMC lab manager, occasional assistance/hampering from Eben and the aid of many Asda sausage sandwiches), have been working into the evenings, and lost their Good Friday holiday to get all the testing finished. There is still a mountain of paperwork for us to sign, and that then has to be looked over by RS Components and element14/Premier Farnell; but that’s a piece of cake compared to what we’ve been doing all week. Given that we’ve had the chamber for the whole week, we’ve used the time to make sure that alongside the CE requirements, the Raspberry Pi also complies with FCC regulations (USA) as well as CTick (Australia) and what we’ve been calling “that Canadian thing”.

The Raspberry Pi had to pass radiated and conducted emissions and immunity tests in a variety of configurations (a single run can take hours), and was subjected to electrostatic discharge (ESD) testing to establish its robustness to being rubbed on a cat. It’s a long process, involving a scary padded room full of blue cones, turntables that rise and fall on demand, and a thing that looks a lot like a television aerial crossed with Cthulhu.

A cute story. Radiated immunity testing involves hitting the Raspberry Pi hard with narrow-band EM radiation, while checking (amongst many other things) that the device is still able to send Ethernet frames to a hub. The first time the team did this, the light on the hub stopped blinking: no frames were making it through. They did it again: still nothing. Finally, they discovered that the hub (which, I should point out, gave every appearance of being CE marked, so it should have been able to get through these tests itself) was being knocked out every time somebody pressed the button. Jimmy used a longer cable, put the hub outside the field, and found that the Raspberry Pi got through its immunity tests with no problems at all.

Finally, there’s small change to the legal gubbins. I know some of you felt like I did about the paragraph in our trademark rules which said that in products and websites, the words “Raspberry Pi” should only be used as an adjective to avoid genericisation – namely that it was a bloody stupid idea. This thing’s called a Raspberry Pi, not a Raspberry Pi computer. We at the Foundation call the computer a Raspberry Pi in conversation. So does everybody we’ve spoken to about it. We don’t abbreviate it to Raspicomp, but to Raspi or RP; none of the mountains of press coverage we’ve had have used Raspberry Pi adjectivally. So we had a chat about it; reminded ourselves that advice we get from our legal team is just that: advice, not binding instruction; and we’ve removed the paragraph from the trademark rules.

An update on CE compliance

Update 23.45pm Mar 30: minor changes to the article to reflect the fact that recent versions of the BeagleBoard-xM appear to have acquired a CE mark.

Update, 8.40pm Mar 28: element14 have put out a new update to their FAQ, enlarging on what’s happening with CE compliance. It’s well worth a read – head on over!

Update, 6pm Mar 28: we have spoken with BIS this morning, and they have confirmed that, given the volumes involved and the demographic mix of likely users, any development board exemption is not applicable to us; as a result, even the first uncased developer units of Raspberry Pi will require a CE mark prior to sale in the EU. As we mention below, we are working with RS Components and element14/Premier Farnell to bring Raspberry Pi into a compliant state as soon as is humanly possible.

Following on from last week’s discussions, both RS Components and element14/Premier Farnell have now informed us that they are not able to distribute the Raspberry Pi until it has received the CE mark. While this differs from our historical view (as we’ve said before, we believed that the uncased Raspberry Pi was not a “finished end product”, and could be distributed on the same terms as earlier versions of the BeagleBoard and other non-CE-marked platforms), we respect their right to make that decision.

The good news is that our first 2,000 boards arrived in the UK on Monday and that we are working to get them CE marked as soon as is humanly possible, in parallel with bringing the remainder of our initial batch into the country. Pete and Eben have been burning the midnight oil – literally; I only exchanged about three words with Eben yesterday, and those were when he got back in from a long day’s hacking at two in the morning. On the basis of preliminary measurements, we expect emissions from the uncased product to meet category A requirements comfortably without modification, and possibly to meet the more stringent category B requirements which we had originally expected would require a metalised case.

We’re also talking to the Department for Business, Innovation and Skills (BIS), to better understand the terms under which other non-CE-marked platforms are permitted to ship to domestic end users in the UK, and to obtain a definitive statement as to whether we can distribute on the same terms. We should say the UK Government in general, and BIS in particular, have been incredibly supportive of the project so far; they are looking into this as a matter of urgency, so hopefully we should have another update for you soon. With graphs in. We know you guys love graphs.

All this means that we’re waiting on one of two things – the results of further EMC tests, and whatever BIS comes back to us with – before RS and element 14/Premier Farnell can give you any firm delivery dates. We’ll let you know as soon as we do.

Finally, here, as promised, are some pictures from the factory (taken by one of the observers RS sent in – both RS and element14 have people onsite to oversee production) of the boards that the Foundation now has.

Raspberry pis in the factory

Each board spends a short while at the test bench. These are functionality tests which are performed in China, not the compliance tests we're doing later this week in the UK.

Once a board has passed, it's ready to be put in an anti-static bag and sent out.

Compliance testing

Some people have been in touch to ask about an email they’ve received from RS Components, talking about compliance testing and Raspberry Pi.

The compliance testing referred to here relates to assessing the device’s electromagnetic compatibility (EMC), and in particular the extent to which it generates unacceptable levels of electromagnetic noise. EMC testing is a necessary prerequisite to obtaining various consumer-protection certifications including (in the European Union) CE marking. It is common practice for development hardware to be sold without such certification, with the proviso that it should not be considered to be a “finished end product”; for example the BeagleBoard System Reference Manual contains the following disclaimer:

This evaluation board/kit is intended for use for ENGINEERING DEVELOPMENT, DEMONSTRATION, OR EVALUATION PURPOSES ONLY and is not considered by BeagleBoard.org to be a finished end-product fit for general consumer use. Persons handling the product(s) must have electronics training and observe good engineering practice standards. As such, the goods being provided are not intended to be complete in terms of required design-, marketing-, and/or manufacturing-related protective considerations, including product safety and environmental measures typically found in end products that incorporate such semiconductor components or circuit boards. This evaluation board/kit does not fall within the scope of the European Union directives regarding electromagnetic compatibility, restricted substances (RoHS), recycling (WEEE), FCC, CE or UL, and therefore may not meet the technical requirements of these directives or other related directives.

While we had intended to defer compliance testing of Raspberry Pi until the cased educational release later in the year, demand for the uncased version (and the level of interest from outside the engineering community) has been so high that both RS Components and Premier Farnell have asked us to bring this forward. We did a first trial run in a test chamber this week, and will have a detailed technical update for you in the next few days.