Regulatory issues: Difference between revisions

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The moment you feed AC mains into a box, EU regulation EN 60950 of Directive 2006/95/EC, or Low Voltage Directive For Information Equipment takes force. It deals with safety in electronic information devices powered from AC mains. This regulation is considered to cover music electronics, analog or digital, simply because there is no direct regulation for music gear. Ssales figures are not sufficient to regulate and music gear is considered professional equipment. If it had been considered a domestic appliance, a synthesizer would be regulated under the more stringent EN60335 instead.
 
There's no mention of music or audio-recording gear in the complete list of [https://web.archive.org/web/20110825233542/http://ec.europa.eu/enterprise/policies/european-standards/documents/harmonised-standards-legislation/list-references/low-voltage/index_en.htm EU regulations for electrical safety]. There's a lot of regulations but most of them are aimed at mass-produced consumer appliances.
 
In the 1980s when Japanese companies such as [[Korg]], [[Roland]] and [[Yamaha]] started to seize the market for music synthesizers and other music gear, regulators in Europe demanded that those firms start meeting EU regulations for electrical safety. To avoid the high cost of electrical safety testing and certification by independent testing labs, a requirement in most of the world, these firms started making gear that ran from AC adapters only. The change from analog circuitry to microprocessors at the same time helped to facilitate this, by reducing power consumption and simplifying power supply design.
 
The United States has no direct federal regulation of electrical safety, but existing laws and court cases dealing with liability tend to use [https://web.archive.org/web/20110603121358/http://www.ul.com/global/eng/pages/ Underwriters Labs] standards for electrical safety of electronic gear. However, UL standards are quite different from EU standards, making them incompatible in test-lab certification. Getting a product UL certified either by UL itself or by a third-party lab can easily cost $12,000 or more, and the test does not apply in most other countries. Selling electronics in Canada requires [https://web.archive.org/web/20110208221847/http://www.csa.ca/cm/ca/en/home CSA] certification, which is roughly similar to UL certification but is different enough to require separate testing. Selling electrical products in Japan requires certification for a PSE mark, again the tests are different from all others, and require separate testing. Russia, Finland, the UK, China, Korea, and some other countries have similar but different safety regulations, requiring different testing. Sometimes they ignore low-production products, sometimes they crack down primarily to put up trade barriers to non-domestic products.
 
The UL is attempting to harmonize its safety standards with the EU standards, under [https://web.archive.org/web/20110816220508/http://www.ul.com/global/eng/pages/offerings/industries/hightech/consumerelectronics/pag/ UL 6500]. So that both standards can be tested for together, for a single price.
 
One side-effect of all this is that the number of certified testing labs has exploded in the last 20 years. Before, there were very few labs, because products tended to be simple and regulations were scarce. Only medical or other safety-critical gear was tested routinely. But the commonplace use of microprocessors, increasing legal controls, import/export regulations, and differences of all the regulations between countries have contributed to a climate of test everything just in case, and the consumer, are paying for it.
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== RFI and EMC ==
Radio frequency interference (RFI), is a major problem in our world of cellphones and wireless gadgets. US federal law is very specific about electronics being ''electromagnetic compatible'' with other products. [https://web.archive.org/web/20120113103717/http://www.i-spec.com/EMC/usa.html FCC Part 15] testing must be performed on any product having switching frequencies of more than 9 kHz in internal circuitry, including any device using a microprocessor. Commercial equipment must meet the Class A standard, while consumer products like small computers have to meet the more stringent Class B standard. A device that radiates a lot of wide-band RF noise, like a microprocessor-based music synth, could interfere with radio communications or broadcasting. Not only could interference cause lawsuits, it could cause criminal liability, by interfering with emergency services and their two-way radio communications.
 
Testing usually involves a RF-shielded chamber, sometimes an [[anechoic chamber]] to avoid measurement errors due to acoustic noise. Special antennae, and a [[spectrum analyzer]] capable of testing to 4 GHz, are mandatory. It should be conducted by an approved testing lab. Such labs are often the same companies that perform electrical-safety certification, and they sometimes offer manufacturers special pricing for testing packages. For a small firm, this testing can still be very costly and difficult to justify for low-production products like synthesizers. FCC Part 15 testing for a single product can easily cost $8,000 or up.
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To sell the same product in Europe, IEC 61000 testing is required to certify it for a CE mark. The CE mark simply states that the product has been tested, meets the EU standard, and is legally permitted to be sold in Europe. Needless to say, the IEC test is similar to the FCC Part 15 test, but different enough to make separate testing unavoidable. This typically costs $15,000-$20,000 for each separate product in the USA. The regulation also says that [[ESD]] (electrostatic discharge) testing is mandatory, to assure the product will not be damaged by static discharge from the user.
 
Other countries have their own EMC regulations, test conditions, and certifications. Japan has the [http://www.ce-mag.com/99ARG/Gubisch145.html VCCI] regulation, requiring separate testing but only by a VCCI-registered test lab. In Russia tests for the [https://web.archive.org/web/20090512221805/http://www.sgs.com/safety_v2/gost_r_mark.htm GOST-R mark] can be carried out outside the country and then exported to Russia with few problems.
 
So far, modular synthesizers have been too low in production to attract the attention of EMC regulators, in the US, in Japan or in the EU. The kit aspect of a modular synth might serve to invalidate EMC regulations, similarly to electrical-safety standards. The fact that most modules were analog (containing no RFI-generating microprocessors or other such circuits) in the past has been an advantage, since Part 15 simply doesn't apply to them. With the appearance of [[DSP]]-based or microprocessor-based modules in recent years, that could change. A legal challenge to the modular synth has not occurred to date.
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{{From Muff Wiggler wiki|Regulatory issues}}
== References ==
[https://web.archive.org/web/20120712170928/http://wiki.muffwiggler.com/wiki/Regulatory_issues ''Regulatory issues''] by [[Eric Barbour]], Muff's Modules & More wiki, May 2011
 
== External links ==