Nick,
I've seen CE marks on a wrist support for sprained wrists etc. I
haven't a clue what that was all about.
Gary
-----Original Message-----
From: Nick Williams [mailto:nick.willi...@conformance.co.uk]
Sent: Thursday, December 14, 2000 3:29 PM
To: Courtland Thomas
Cc: emcpost
Subject: Re: CE Marking Passive devices
Courtland,
Since no one else seems to have answered your basic question, I will
have a go for you.
Passive devices and components such as cables are excluded from the
EMC Directive and as such carry no CE mark under this directive. This
is not to say that all components are excluded - this is a complex
matter which is covered in some depth in the Commission guide to the
Directive. If you don't already have a copy of this, you can download
it from the Commission EUROPA server or from my company web site -
mail me direct for the full URL details if you need them.
However, certain passive components (e.g cable) are within the scope
of the LVD and therefore require CE marking. It's unclear exactly how
this works, in the sense that this seems to be one of the few areas
of CE marking which is basically optional. It would be quite easy to
argue that cable and wires are outside the scope of the LVD and
therefore do not require a CE mark, but equally you could argue that
they are within the scope and therefore should have the mark. The
difference is basically made by what the manufacturer/seller claims
the cable is to be used for. The advantage of carrying the mark (at
least in theory) is, of course, unrestricted access to the whole EU
marketplace so I guess savvy manufacturers tend to 'opt in' and mark
their products.
In practice, some cables, such as those which are specifically
specified for use at mains voltages (e.g. house wiring, flexible
cords for power connection of household appliances, etc) clearly are
intended for use within the voltage limits of the LVD and must
therefore be CE marked.
There is an interesting (well, to CE anoraks like me, it's
interesting anyway!) twist here, because fixed wiring in also within
the scope of the Construction Products Directive, and CE marking is
optional under this directive. However, the CPD is a whole new can of
worms and it's far from clear what anyone is actually doing to comply
with it, if anyone is actually seriously bothering at all. (If
there's anyone else on this list with an interest in the CPD, I would
be interested to hear from them, but I digress.)
Again, the Commission guidance document on the LVD gives further
guidance on this topic. Basically it says that if it's possible to do
a safety assessment on the product, then such an assessment should
take place and the CE mark should be applied, but if the component is
so basic that its safety is totally reliant on how it is used then no
such assessment is possible on the component itself and the CE mark
should not be applied. I would tend to simplify this further and say
that as a rule of thumb if there is a harmonised standard for the
component under the LVD then it should be CE marked, and if there
isn't it should not.
To take the specific example of the surge protector, you need to be
specific about that of which you speak. If you mean a component such
as an MOV or a gas discharge tube, this is clearly a component and
therefore outside the scope of the both LVD and the EMC Directive. If
you mean an assembly in a box with connections (such as a telephone
line lightning suppressor assembly) this can be assessed for safety
and does require a CE mark under the LVD. An assembly such as this is
not a component within the meaning of the EMC directive either, and
will therefore need to comply with that directive too.
Hope this sheds a little light for you.
Regards
Nick.
At 09:36 -0800 12/12/2000, Courtland Thomas wrote:
>Hello group,
>
>I would like to know if there are any requirements for CE Marking a cable
or
>any passive device, such as a basic surge protector.
>
>
>Thanks,
>
>Courtland Thomas
>Patton Electronics
>
>
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