I want to design a computer vision device that will act as a "driving assistant". The device will improve driving safety by acoustically or visually alerting the driver of certain hazardous situations (lane crossing, safe braking distance etc.) but will not be directly connected to any car controls. My question is: how to design my device so that it complies with regulations if I want to sell it as a "car accessory" in aftermarket in the US and EU?

By aftermarket I mean that the device will not be mounted into a vehicle by car manufacturer but by the end user/customer. The mounting should be as simple as placing a camera on the windscreen (out of the driver's field of view), connecting it to the "processing unit" by a cable, placing that unit somewhere (under dashboard, seat etc.) and plugging the unit into the 12V outlet (or rather wiring directly to 12V).

I am a software developer and I have already a prototype running on a x86 platform. The prototype consists of a common mini-ITX board, an USB camera and a picoPSU power source. All these have an "FCC Class B Part 15" certification (I guess this is standard for consumer-grade electronics intended for home/office use). Besides these I will also use an USB 2.0 or 3.0 cable to connect the camera to board and the board will wire to those 12V.

The device will be only an "assistant" and will not carry any life-critical function when driving. I think it may fall in the same category as car GPS navigation devices (Garmin etc.). I know that demands for a mission-critical automotive electronics (things like engine electronics, brake systems etc.) are very high, but as I said my application is not anywhere near this kind of usage.

The best situation for me of course would be no need for re-certification since I only bring/bundle already certified components together (besides the cabling) into a new product without altering any of them. In case the x86 setup could not get car-compliant my second attempt would be finding a powerful automotive-compliant embedded board (nVidia Jetson TK1 or Jetson Pro?) that I could compile my computer vision code on. I would like to avoid doing an FPGA-based design because rewriting my code to hardware is likely to be very costly.


closed as off-topic by user17592, Leon Heller, placeholder, Majenko, Chetan Bhargava Nov 22 '14 at 20:18

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  • \$\begingroup\$ If you are using OpenCV in your software - switching to nVidia Jetson will be not that painful. \$\endgroup\$ – Kamil Nov 22 '14 at 15:45
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    \$\begingroup\$ This question appears to be off-topic because it is about legal issues, not about electrical engineering (see meta.electronics.stackexchange.com/q/998/17592). Also, the answer on the question would depend on the country you're in / want to sell this product in. \$\endgroup\$ – user17592 Nov 22 '14 at 15:56
  • \$\begingroup\$ I think there are many regulation/certification (and thus law-oriented) questions on this site which are not tagged as off-topic so this gives me an impression this should be on-topic. Anyways, I reworded the question to ask about more about how to design my device to comply with the law which should be better since this site is about design. Also, I added target market countries. \$\endgroup\$ – Kozuch Nov 22 '14 at 16:17

1. My personal opinion and common sense

I think there is no special law that regulate selling/manufacturing of devices like this.

If I understand correctly - your device will be not connected with car and it will not modify car, so it is not car part. It does not affect any electrical, mechanical or safety system. It is not changing car behavior, fuel consumption, toxic substance emission etc. It is something like car TV or GPS receiver.

I heard somewhere that in Australia you cannot ship device with batteries to consumer, I'm not sure what is this about, but careful if you have some backup battery in your system.

FCC certyfication applies to communication devices like WiFi card, which is not your product. You will just resell it, so all you have to do is use FCC-certified device in your project.

End of personal opinion

2. Some facts about law and devices in car

You have to read regulations about placing anything on windshield. For example in USA - diffrent states have diffrent laws about that.

Another very important thing is that in some countries (and some states in US) driver cannot have any turned on screens in visibility range when he is driving.

In Europe we have 3 very important acts related with electronics:

In typical electronics - it's about buying parts with RoHS mark and using lead-free solder.

  • act about CE marking (more info: link)

The CE marking is required for many products. It states that the product is assessed before being placed on the market and meets EU safety, health and environmental protection requirements.

  • act about Electromagnetic Compatibility (EMC) (more info: link, more practical info: link)

All electric devices or installations influence each other when interconnected or close to each other. Sometimes you observe interference between your TV set, your GSM handset, your radio and nearby washing machine or electrical power lines. The purpose of electromagnetic compatibility (EMC) is to keep all those side effects under reasonable control. EMC designates all the existing and future techniques and technologies for reducing disturbance and enhancing immunity.

Here is a guide about EMC: link

Most important information for you:

A combination of several finished appliances which is made commercially available as a single functional unit intended for the end-user is considered to be apparatus31. Such a system, within the sense of the EMC Directive, is combined, and/or designed and/or put together by the same person (the “manufacturer”) and is intended to be placed on the market for distribution as a single functional unit for end-use and to be installed and operated together to perform a specific task. All provisions of the EMC Directive, as defined for apparatus, apply to the combination as a whole. It should be noted that combining two or more CE marked finished appliances does not automatically produce a “compliant” system e.g.: a combination of CE marked Programmable Logic Controllers and motor drives may fail to meet the protection requirements.

So if you want to build your product with ITX board, wifi card and some power supply - you have to test it for Electromagnetic Compatibility. Manufacturer can do it himself or pay for some laboratory to do it.

3. Personal opinion again

I think all you have to do is:

  • inform your customers how to install screen properly to help them avoid problems with law
  • follow rules about typical consumer electronics (CE in Europe, I don't know what is required in US and if there is some CE equivalent)
  • \$\begingroup\$ Thanks very much for your answer. I think the FCC watches all electromagnetic spectrum which is both intentional (Wi-Fi) and unintentional (PC motherboard etc.) radiators but as you say I probably only need to use tested components. Regarding placement on windscreen - I know about this and thus wrote "out of driver's FOV", which should solve the thing - this is exactly the same problem as GPS navigation devices have. \$\endgroup\$ – Kozuch Nov 22 '14 at 16:30
  • \$\begingroup\$ @Kozuch I updated my answer with informations about EU market. \$\endgroup\$ – Kamil Nov 22 '14 at 18:45
  • \$\begingroup\$ Thanks again for you great insights! I am thinking further - what if I wanted to create a real "autonomous emergency braking system" that can stop the car by itself? I know that aim is high and would need a lot of real world testing, but I am interested in the legislature. I would need to connect the device to the car - read steering angle sensor data (from CAN/OBD) and then initiate braking action (cars with ESC/ESP can brake by wire). Is the legislature much stricter for such system? Can a small company develop such product? You speak about "car part" - how is it defined legally actually? \$\endgroup\$ – Kozuch Jul 9 '15 at 21:02

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