Robert - We are a manufacturer for "componets" like relays and circuit breakers in the class "circuit breakers for equipment", not panel breakers - and, as the "regulatory guy" here, I too get asked this question almost daily.
The basic problem is that the CE legislation did exclude most "components" from the mark requirement - but did not define components broadly enough. Clearly, they exclude things like ICs but are vague on things like relays, switches, etc.. Some redefinition of policy/position has been promised for many months but has not yet been issued (to my knowledge). Most people I talk to seem to agree that components being used in the manufacture of equipment which will be subject to CE marking do NOT need CE on the component itself. The existence of VDE, Tv, etc. European agency marks is sufficient to allow easily meeting CE requirements on the end equipment. It is a little less clear where the same component can also be sold individually in a market where both OEMs and consumers have access. OEMs would not need it - but consumers (non-professionals?) would. Some of us even feel that indiscriminant use of the mark on components where untimate application of the device is not controlled is, in fact, giving users a potentially false signal of compliance to CE requirements because the devices might be used in a manner not in compliance with mark requirements. I feel this is particularly likely in the case of componet compliance to the EMC Directive. In your case, I believe your breakers would NOT need CE marking if used in equipment downstream from the supply panel and subject to CE qualification - but WOULD need the mark if they are panel breakers for power distribution. Similarly, if sold direct to OEMs or via OEM (or industrial) distributors if would not need it - but if sold via consumer outlets (Radio Shack, etc.) it would. I'll also be interested in the opinions of others on this forum. Disclaimer - Opinions expressed are my own and not necessarily the position of the corporation. Harold Leipold Siemens Electromechanical Components Princeton, IN Tel. (812)386-2161 E-mail - [email protected] ---------- From: Robert Macy To: LEIPOLHD; emc-pstc Subject: CE Approval List-Post: [email protected] Date: Wednesday, August 07, 1996 2:22AM This message was from [email protected] to ROBERT MACY, and was forwarded to you by ROBERT MACY. ------------------------- From: "Douglas J. Kirchner" <[email protected]> Subject: CE Approval List-Post: [email protected] Date: Tue, 6 Aug 96 17:49 EST To: [email protected] Message-Id: <83960806224938/[email protected]> -- [ From: Douglas J. Kirchner * EMC.Ver #2.5.03 ] -- Robert, Does a manufacturer of circuit breakers that has VDE and TUV approval, need to obtain CE approval in order to sell the breaker to an equipment manufacturer th at will in turn, sell their equipment to the EU community? Or since the breaker has VDE and TUV approval, is it up to the manufacturer to obtain the CE approval? I have heard two opposite answers to this question. First, since the breaker ha s VDE and TUV, the equipment manufacturer can obtain his CE approval. The secon d answer was no matter what approvals were obtained on the breaker, CE approval was required. I hope this is clear and makes sense. Will talk with you later. Regards, Doug Kirchner Wright Associate ----------------------------------------------------------- Robert A. Macy, PE [email protected] AJM Electronics --- ~ OLX 2.1 TD ~ I'll bet you think this is a tagline, but it's not.
