This publication is intended to draw the attention of the community of amateur radio and small manufacturers of electronic equipment to the forthcoming change in legislation. Perhaps in the near future you will be prosecuted for making and selling a smart feeder for an Arduino cat without a declaration of conformity, and then punished to the fullest extent.
To begin with, manufacturers of low-voltage equipment in the territory of the Russian Federation are obliged to comply, as a minimum, with the Technical Regulations of the Customs Union “On the Safety of Low-Voltage Equipment” ( 004/2011). The term "low-voltage equipment" to date, refers to electrical equipment designed to be used at a nominal voltage of 50 to 1000 V (inclusive) of alternating current and 75 to 1500 V (inclusive) of direct current. This includes computers, hand tools, household appliances, and so on. However, this definition does not include electronics with a rated voltage below 50 and 75 Volts for AC and DC, respectively. That is, not all electronics fall within this framework. For example, Arduino with Raspberry and their entire ecosystem does not fall.
But for some reason, the legislator is not satisfied with this state of affairs, and now the Decision on Amendments No. 1 to the aforementioned Technical Regulations is being prepared for signing. One of the main changes is the criterion for the applicability of technical regulations. Now, the term “low-voltage equipment” includes everything that uses voltage from 0 to 1000 V AC and from 0 to 1500 V DC. That is absolutely all electronics.
So what if any electronics falls under the scope of the Technical Regulations?
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Here is a list of only the most tangible consequences:
- The need to confirm compliance with the Technical Regulations at a minimum by means of a Declaration of Conformity.
- The need to test products in an accredited laboratory.
- Ban on the sale of products even in a single copy without a Declaration.
If the decision is made in this form, then all small electronics manufacturers who will be forced to invest money in testing for the Declaration of Conformity will be at risk. And this, you see, does not carry anything good.