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We want to start a crowd funding project for our IoT servomotor. It comes with an integrated controller and an ethernet connection (no wireless) and now we are not sure about certifications (FCC, RoHS, etc.) if we send it to the USA.

The device its not an end product (I don't know if this matters). It's intended for makers or students to help them with their projects and not no waste time with motor control. So its more like a arduino - a device for further development and instructed people (if this matters).

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  • \$\begingroup\$ What approvals/certifications do other servomotor vendors get for their products? \$\endgroup\$ – Andy aka Nov 10 '16 at 15:55
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    \$\begingroup\$ The importer of record is legally responsible for compliance in any case. \$\endgroup\$ – Spehro Pefhany Nov 10 '16 at 16:09
  • \$\begingroup\$ Its powered by a 24V power supply from the buyer itself (not provided by us). We recommend a laboratory power supply. \$\endgroup\$ – René H. Nov 10 '16 at 17:26
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The US system is rather different than the EU one. In the EU, CE marking is required, but, for many products, no independent testing is required. A CE mark is a claim, by the party placing goods on the EU market, that the goods comply with the applicable directives. Many of those directives, though, offer the option of having testing performed to particular standards by particular authorized testing laboratories. The party placing the goods on the market, however, is often at liberty to base the marking on its own testing or analysis.

In the States, "UL" is not legally required, although "listing" or "labelling" may be. There are numerous "nationally recognized testing laboratories", as well as other agencies that are accepted by various local authorities. The former are granted that status by the US Dept. of Labor, as the requirement is for equipment in workplaces. In some jurisdictions, "listing" or "labelling" may be required other than in workplaces.

The same is true in Canada with the Provincial Dept of Labour, if an exemption is needed for experimental work without CSA/UL approval. There is a small fee per unit in field prototypes exposed to the public at large, but is not needed for private lab R&D.

If you have no internal AC powered circuits or high voltage output and use external approved sources, you are ok to be exempt from UL requirements. Given that some servos use high voltage outputs, the onus is on the integrator who may sell their system to ensure it meets all safety and EMC requirements.

If your competition is someone like "OrientalMotor" note they have many products registered for safety. We don't have any specs for your concept!

So you better start collecting info for filing before volume shipments in case your customers don't have a good customs broker.

Abstract: World K Series RoHS-Compliant Induction Motors 1W / 3W 6W Features ; Optimal for Uni-Directional Continuous Operation Induction motors are optimal for uni-directional continuous operation such as a conveyor system. Safety Standards and CE Marking Standards 15 W UL 1004 UL 2111 CSA C22.2 No.100 CSA C22.2 No.77 Certification Body UL Standards File No. E64199 E64199 (1 W6 W Type) E64197 (15 W150 W Type) EN 60950-1 EN 60034-1 EN 60034-5 IEC 60664-1 Conform to EN/IEC Standards ...

http://www.orientalmotor.com/products/pdfs/2009-2010/G/usa_info_approved.pdf

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  • \$\begingroup\$ Note that a label is a mark that assures the buyer that a product is listed. A labeled product must be listed. In the US, federal government regulations give the listing of every Nationally Recognized Testing Laboratory equal weight. Lower jurisdictions can not legally require UL as the only acceptable listing. \$\endgroup\$ – Charles Cowie Nov 10 '16 at 16:23
  • \$\begingroup\$ yes "listing" = "labelling" so no label will fly under the radar \$\endgroup\$ – Tony Stewart Sunnyskyguy EE75 Nov 10 '16 at 16:29
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Any device that is connected to mains power in the USA needs to have a listing and labeled by a Nationally Recognized Testing Laboratory (NRTL). Underwriters Laboratories (UL) is the best known NRTL, but there are many others that are recognized by the US government. Some have offices in other countries to serve the needs of manufacturers wishing to manufacture goods for the US market.

Battery operated devices may not need an NRTL label, depending on their potential risk of causing personal injury.

Devices that have the possibility of emitting unintentional radio frequency (RF) noise must have be certified not exceed published emission limits. The required tests and certification can be performed by the manufacturer without verification by a third party. If they are later discovered to interfere with other equipment, the uses may be required to cease using them regardless of whether or not they exceed published limits. If they are in fact exceeding limits, they could be forced off the market.

The best thing to do would be to seek advice from a local branch of a US NRTL.

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  • \$\begingroup\$ I don't believe there is any such federal law regarding NRTL testing in the USA, and asking the NRTL is a bit like asking a barber if you need a haircut. That doesn't mean that it can be sold everywhere, or that distributors will actually purchase it without listing. \$\endgroup\$ – Spehro Pefhany Nov 10 '16 at 16:07
  • \$\begingroup\$ No. There is no federal law, but local laws and reluctance by retail sellers to deal with any mains powered devices that are not labeled pretty thoroughly prohibit unlabeled devices from being sold. Thus a label is needed. Granted that an NRTL has an incentive to sell a labeling service, they may still the best experts available. \$\endgroup\$ – Charles Cowie Nov 10 '16 at 16:15
  • \$\begingroup\$ I agree 100% with that. In this case it appears to be a crowd-funded project from outside the USA that would likely be imported individually by users. \$\endgroup\$ – Spehro Pefhany Nov 10 '16 at 16:20
  • \$\begingroup\$ Some retailers may be reluctant; others seem willing to sell any kind of junk USB power brick if it's cheap enough. \$\endgroup\$ – supercat Nov 10 '16 at 16:26
  • \$\begingroup\$ Marketing directly to the end user through in individual web site or via eBay essentially allows many products to be sold without regard to any US safety standards or regulations. Any US based reseller could be held responsible for any negligence. \$\endgroup\$ – Charles Cowie Nov 10 '16 at 16:40

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