Alan,
We know what is "excluded" from needing a CE mark: (1) Products for which there are no legal requirements as to their technical characteristics (2) Products for which there only exist national requirements as to their technical characteristics (3) Products for which the requirements as to their technical characteristics are laid down in EC directives "OUTSIDE" the "new approach" Many of the authorities having jurisdiction now feel that we should consider as apparatus only "components of a complex nature" and that simple modular components such as for instance, diodes or integrated circuits, need not comply with the essential requirement, need not be subjected to any conformity assessment practices and need no marking. That, would not exclude your CBT system. The questions I would ask myself are: Are there legal EU requirements as to the technical characteristics of a CBT system ? If so, are they inside or outside directives under the "new approach" ? I suspect that the answer to the first question is NO, thus exempting your CBT system. Please note that this would NOT exempt the components of you CBT system from having to carry the CE marking. Having said that, I am convinced that each part of a system can be as safe as all get-up, but if assembled by somebody not steeped in the arts, may result in a dangerous package. This particularly holds for "distributed systems" such as PBXs, LANs, etc. Regards, Vic