13

If I want my smart plug design to be a commercial product in the EU it must surely meet some requirements, regulations or directives.

I know about the CE (Conformité Européenne) marking, which is mandatory in the European Economic Area. It means, if I can believe Wikipedia:

Most electrical products must comply with the Low Voltage Directive and the EMC Directive; toys must comply with the Toy Safety Directive

I am mainly concerned about the safety, as smart plugs and sockets have direct connection to mains voltage, live wires, which is always dangerous. Proper sealing is needed.

I have checked The Low Voltage Directive (LVD) and I think it covers the safety requirements for a smart plug based on the below part.

The LVD covers all health and safety risks of electrical equipment operating with a voltage between 50 and 1000 V for alternating current and between 75 and 1500 V for direct current. These voltage ratings refer to the voltage of the electrical input or output, not to voltages that may appear inside the equipment.

Now, there are other directives as well. For example Measuring Instruments Directive. It also mentions "Active electrical energy meters".

There is also a general product safety directive according to this list.

All in all which of the above mentioned and not mentioned directives are mandatory for commercial smart plug designs in the European Union? The main concern is safety.

5

I would imagine the same restrictions would apply to Smart Plugs and any other electrical device equally; there does not seem to be any specific legislation that applies to IoT devices.

The UK Government (which, despite the recent Brexit referendum, still respects EU law as of 2016) has published an extensive guide named Electrical equipment manufacturers: regulations and responsibilities. This may be helpful as guidance, and it is far less difficult to read than the full legal text of the Low Voltage Directive. However, since your question is about the EU and not specifically the UK, I will not focus on that aspect of electrical safety regulations.

The UK Health and Safety Executive list the Low Voltage Directive as the only regulation that needs to be followed under its list of European Community law on the supply of new products, however in the list of excluded products, plugs are listed:

The excluded items and phenomena are:

  • Electrical equipment for use in an explosive atmosphere
  • Electrical equipment for radiology and medical purposes
  • Electrical parts for goods and passenger lifts
  • Electricity meters
  • Plugs and socket outlets for domestic use
  • Electric fence controllers
  • Radio-electrical interference
  • Specialised electrical equipment, for use on ships, aircraft or railways, which complies with the safety provisions drawn up by international bodies in which the Member States participate

(emphasis mine)

Although, it is perhaps debatable whether a Smart Plug is really a plug, despite the name - it is not an electrical socket in the same sense, so perhaps the requirements are not as stringent. It may be worth contacting one of the Central contact points in charge of implementation of Directive 2014/35/EU [the LVD] for clarification if you're unsure - advice from the Internet is almost certainly not valid legal advice!

7

Most smart plugs I have come across are Wi-Fi controlled devices.

I expect the regulations would be similar to those imposed on a Wi-Fi router such as Technicolor's TG582n.

  • RTTE Directive 1999/5/EC: Radio and Telecommunications Terminal Equipment.
  • Commission Regulation (EC) No 1275/2008 implementing Directive 2009/105/EC: Ecodesign requirements for standby and off mode electric power consumption of electrical and electronic household and office equipment.
  • Commission Regulation (EC) No 278/2009 following the provisions of the Energy-related Product directive 2009/105/EC (ecodesign): Ecodesign requirements for no-load condition electric power consumption and average active efficiency of external power supplies. The standards and/or normative documents are as follows: SAFETY
  • EN 60950-1:2006 +Amendment Al 1:2009 + Amendment A12 + Amendment Al :2010 Information technology equipment - Safety Part 1: General requirements. EMC
  • EN 55022:2006 + Amendment Al: 2007 Information technology equipment - Radio disturbance characteristics - Limits and methods of measurement.
  • EN 55024: 1998 + Amendment Al: 2001 + Amendment A2: 2003 Information technology equipment - Immunity characteristics - Limits and methods of measurement.
  • EN 61000-3-2:2006 Electromagnetic compatibility (EMC) - Part 3-2: Limits - Limits for harmonic current emissions (equipment input current up to and including 16A per phase).
  • EN 61000-3-3:2008 electromagnetic compatibility (EMC) - Part 3-3: Limits - Limitation of voltage changes, voltage fluctuation and flicker in public low-voltage supply systems, for equipment with rated current <= 16 A per phase and not subject to conditional connection.
  • EN 301 489-01 VI .8.1 (2008-04) Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and services; Part 1: Common technical requirements.
  • EN 301 489-17 V2.1.1 (2009-05) Electromagnetic compatibility and Radio spectrum Matters (ERM); ElectroMagnetic Compatibility (EMC) standard for radio equipment and services; Part 17: Specific conditions for Wideband data and HIPERLAN equipment. SPECTRUM
  • EN 300 328 VI .7.1 (2006-10) Electromagnetic compatibility and Radio Spectrum Matters (ERM); Wideband Transmission systems; Data transmission equipment operating in the 2,4 GHz ISM band and using wide band modulation techniques; Harmonized EN covering essential requirements under article 3.2 of the R&TTE Directive. HEALTH
  • European Council Recommendation (1999/519/EC) on the limitation of exposure of general public

It's worth picking up the phone and talking to your local compliance house. I used CEI previously. It's not cheap but if you are serious and intend to sell your device, you will need to get someone to sign off on your product, otherwise it's a dangerous plug and not a smart plug.

  • Mains voltage measurement should be done somehow, so the line can be intecepted. I do not think that all, or the especially small ones include any isolation transformer, just some kind of voltage divider. That can mean line voltage on the PCB, not just a pass through. – Bence Kaulics Dec 9 '16 at 19:28
  • Maybe I was not clear and Smart Plug was a general term. I meant devices that measure line voltage and current or even switch it with a relay. – Bence Kaulics Dec 9 '16 at 19:32
  • 1
    @BenceKaulics That's a fair point, so it's not straight-through. In any case, the same regulations should apply. – SeanJ Dec 10 '16 at 0:55

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