We've been designing some smart home devices and softwares in past few years and they've been sold in some countries in middle-east. Basically, they were combination of ESP, Arduino and NodeMCU boards which we've added some relay board to them and make them a product since they came with a UI and web service we had provided.

At the moment, I am planning a company in Poland to start my own IOT service and my goal is to sell some NodeMCU based devices with a hosted software, such as temperature control or GPS tracking services. I would like to import relay boards and temperature sensors and so on from Aliexpress dealers, directly from China to Poland and Estonia.

What I am aware of, at least in paper work level I do need certifications from someone to cover my ass when I am selling these products, since they can make problems if they are overheated or higher current provided to them.

The question here remains is, which certifications the new product that I am designing must pass, in order to be installed on premises legally. Just in case, these devices make a fire, explosion or anything, what would be my escape goat, so I can say I have passed all tests before selling them to customers.

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    \$\begingroup\$ I think you're approaching this from the wrong side: You need to make sure your products are safe. That's way more important than that they are certified. A European court will send your behind to jail if they found you in gross neglect leading to harm to a person's health, no matter whether you found someone to give you a certificate for anything. So, while certification is necessary, it shouldn't be of your primary concern – what should be far more important is that you don't hurt humans, shouldn't it? \$\endgroup\$ – Marcus Müller Nov 2 '18 at 23:26
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    \$\begingroup\$ Also, certifying a safe product for safety is obviously easier than certifying the one you have – you seem to be rather worried it's not safe. If you know it's not safe, why do you intend to sell it? \$\endgroup\$ – Marcus Müller Nov 2 '18 at 23:28
  • \$\begingroup\$ @MarcusMüller Of course and +1 for it. But let's see that in other way. If my product is totally safe, and somebody makes a wrong installation and make my product an escape goat. \$\endgroup\$ – Alex Nov 3 '18 at 0:21
  • \$\begingroup\$ @MarcusMüller What I am doing is to provide a safe device and reliable. I am just wondering about how it's gonna be legal to sell. The organisation, or whatsoever. I know I can drive safe, but I need to have driving license, just in case somebody hit me. \$\endgroup\$ – Alex Nov 3 '18 at 0:23
  • \$\begingroup\$ No, you don't need a drivers license in case somebody hits you, you need a drivers license to drive in the first place. You don't get the driver's license to be legally safe in case someone hits you (how does a license help anyone if someone died?!), but a) because you need that license to drive without being arrested and b) because it's probably a good idea to get instructed by someone who actually got an education in instructing people to drive before sharing the road with millions of other > 1t murder machines at 180 km/h. \$\endgroup\$ – Marcus Müller Nov 3 '18 at 9:32

There's different things involved here:

To introduce an electronic device to the EU market, you will need some certifications. I'm not an expert, and you will have to see an import attorney or something similar to get the legal stuff sorted out, but the things from the top of my head are:

CE certification. That's essentially a document that says that you, yourself, guarantee the device adheres to standards. Depending on the type of device, these are different standard. You kind of picked the worst kind of device, it falls into a few of the hardest categories:

  • consumer device: Needs to be generally safe to handle.
  • attaches to the power outlets: Most device suppliers elegantly work around this by not building their own power supplies, but buying CE-conformant supplies that someone else builds. For you, that's not an option, because the core of your application is switching outlets. So, make yourself familiar with the regulations that CE has for such devices. I'll be honest here: most pictures of China-sourced relay boards that I've seen probably cannot be certified legally; clearances and creep distances just seem too small.
  • integrates transmitting radio hardware: Your things are based on WiFi and/or other wireless standards. Thus, the transmitters need to adhere to the radio regulations. You will need to know how to bring your devices into a test mode, and you will need a certified RF lab to test them for conformity with radio regulation. That's costly. You can avoid that by only using non-modifiable, pre-certified radio modules only.
  • Handling of electronic waste: If you want to sell a device in the EU, you have to pay for the disposal of electronics. It's a rather complex system, but in essence, for every ton of devices you sell, you'll have to pay for the disposal of a ton of devices. You also need to document that all your device's components adhere to RoHS guidelines. That, for example, means that your chinese boards must not be soldered with lead solder, and that the manufacturer guarantees that.

Aside from these mandatory certifications, you said you wanted someone to certify your device is especially safe. That's a good idea! There's TÜV Rheinland which does device testing and certification. The "GS" (for "geprüfte Sicherheit", tested safety in German) logo is a popular one and acts as advertisement logo, too.

As a general note: Generic IOT devices are a hard market where you compete with much larger companies that have very much lower legal and waste handling costs per device than you have. You have no distribution channels – while these devices are sold by the millions through supermarket chains. More than the legal and engineering problem that you'll be facing, I'd be worried about the economic aspects of this. Can you really sell your devices at even remotely competitive prices, competitive reliability and service? Consumer electronics is a hardly-fought battleground with low profit margins, and unless you have a unique value proposition for that market, I'd not try to enter it with something that established manufacturers can produce and sell by the millions.

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  • \$\begingroup\$ This is a good way to start. I am not sure the result of the product, or how many people will be eventually interested in this product. I hope I can increase the price quite enough because of modifications client would request. 1. Since I buy NodeMCU based on ESP8266, am I free from getting a radio regulations? \$\endgroup\$ – Alex Nov 3 '18 at 12:27
  • \$\begingroup\$ This is really interesting answer. Let's make it more efficient with a roadmap in case other people wanna do that in future. \$\endgroup\$ – Alex Nov 3 '18 at 12:31
  • \$\begingroup\$ no, you're not free from radio regulations. You're always subject to radio regulation. However, as I tried to explain, if you only use certified radio modules inside your product, then your overall product doesn't have to be re-certified. But: You will really need to consult a lawyer about the details here. It really really really depends. And: most radio modules that you directly buy from China are not pre-certified; you can pretty easily figure which ones are by them having an FCC id, typically, as well as a price difference. \$\endgroup\$ – Marcus Müller Nov 3 '18 at 12:40

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