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I am working on a fairly simple LED product that would use an external power supply (12V). Certain configurations of the product may require more than 100W. I could also configure the product to use 24V.

Are Class 2 power supplies my limit before requiring CE/CSA certification? Or is there a voltage/power limit before legally requiring CE/CSA certification?

Thanks in advance.

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I can only give some ideas for CE marking: -

It seems likely you can self-certify for CE but you need to create a technical file/document that justifies that your product meets the relevant directives and that any testing you have done is applicable and results indicate an acceptable "pass".

At 24V, you are within the voltage limits of the "Low voltage directive" so this doesn't apply BUT you should specify that a power supply that is CE marked is used.

However, you may be subject to the EMC directive in which case you have to justify why the limited tests you may apply justify not conducting full EMC testing.

There are a bunch of other directives that probably won't apply but it is down to you to specify which ones do and which ones don't AND, in the technical document justify why your product meets those various directives.

You also need to draft up a certificate that states all this stuff. There are examples on the web and there are good guidelines: -

UK government website for CE marking

guide on CE marking

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Regarding Canada case. Article 2.024 of Canadian Electrical Code states that electrical equipment shall be approved, but lets local jurisdiction make the determination of which approvals are good.

For Quebec code, the super-seeding Article 2.024 lists a number of acceptable certifications and also allows exclusions for electrical equipment of less than 100VA and less than 30VDC, with certain limits regarding lighting, heating and other types of applications.

For Ontario code, the super-seeding Article 2.024 lists a number of acceptable certifications and also allows exclusions for electrical equipments powered by (on the load side of) 100VA or less Class 2 power supply with a voltage below 42V, with again certain limits regarding lighting, heating and other types of applications.

Therefore, the Ontario code is more restrictive that Quebec's code in that matter. As a general rule, when faced with using some CE European or non-CSA certified instruments in a project, using a 100VA Class 2 24VDC Power Source is a good rule to stay within the bounds of the electrical code Country-wide in Canada.

Still, the manufacturer of the equipment has to ensure proper electrical design so as not cause fire or other hazards. In the end, the equipment manufacturer (or the distributor of the equipment, or ultimately the importer of the equipment) is liable for its proper and safe design.

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  • \$\begingroup\$ On a note, in regard to your question, the LED-type application is one of the exceptions of the allowable exclusion to have an approval requirement. In other words if this is LED application you have to get an approval. \$\endgroup\$ – Philibert Perusse Feb 18 '15 at 3:54
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I'm not going to get into the legal requirements or de facto requirements for UL/CSA in the US and Canada (it's kind of a tangled web, and you're in what could be a gray area in some regards, legally), but I'll note that 100W is more than enough to cause a fire, and therefore you should consider testing to UL and CSA standards (and listing) should be a requirement for sale to the general public. At least talk to your product liability insurer.

The "Class 2" means the external power supply is not itself a fire or shock hazard, but I think most of us would have no problem devising a load that would be capable of burning down buildings all day long.

Consider disk drives, which typically carry UL component markings, despite being low voltage and having a power of only a few watts.

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