The R&TTE directive as interpreted by the notified bodies requires CE marking on the product, the installation instructions, AND (not OR) the carton.
David -----Original Message----- From: Maxwell, Chris [mailto:chr...@gnlp.com] Sent: Friday, December 15, 2000 11:54 AM To: 'wo...@sensormatic.com'; emc-p...@majordomo.ieee.org Subject: RE: Application of CE Mark Let's look at this from the point of view of a customs officer. Would I trust a box just because it has a CE mark on it? If I were a customs officer and I trusted every box that came through with a CE mark on it, I would be inviting smuggling. People could be smugglling God knows what into my country simply by using a CE marked box. So, if we put CE marks on all of our packages, I don't think that it guarantees that they won't be opened. I would assume that if customs officials were doing their jobs, they would be spot checking CE marked boxes and non-CE marked boxes. Maybe there is a lower probability of checking a CE marked box? If I were a customs officer and I opened a package. I would want to be able to clearly tell that the CE mark that I see applies to the product in the package. After all, couldn't somebody be simply re-using a CE marked box to ship something else? Even so, Chapter 12 of my version of The Guidelines on the Application of The EMC Directive state that the CE mark must be affixed on the product, if possible. If that isn't possible it allows the PACKAGING, instructions for use and the guarantee certificate in that order of priority. So, while CE marking boxes may not be forbidden (for the EMC Directive anyway), it certainly may be ineffective for the reasons that I mentioned above. Deciding where to mark should be applied in a case by case basis using common sense to figure out the best way to associate the CE mark with the product that it applies to. It seems that CENELEC already thought of this and that's why they gave us options listed in the guidelines document. Consider a basketball shipped in the typical three sided box. It may be CE marked on its "box" effectively because a customs official could see the CE mark on the package and see the product all without opening the "box". (For those unfamiliar with basketball packaging, they usually arrive in the store in a box with one-side partially open so the customer can see the ball.) Now consider a large box labelled as a handheld medical device. It's a great big, closed box with CE marks all over it, yet it smells like marijuana. (I myself wouldn't have the faintest idea what it smells like :-). If I was a customs official, maybe I'd decide to take a peek. If I opened the box only to find a bunch of marijuana, would I assume that this is alright to ship just because the box was CE marked? Happy holidays! Chris > -----Original Message----- > From: wo...@sensormatic.com [SMTP:wo...@sensormatic.com] > Sent: Friday, December 15, 2000 8:25 AM > To: emc-p...@majordomo.ieee.org > Subject: RE: Application of CE Mark > > > It is news to me that placing the CE marking on packaging is forbidden if > the directive does not specify the marking? Where did you find this > information? > > Richard Woods > > ---------- > From: CE-test - Ing. Gert Gremmen - ce-marking and more... > [SMTP:cet...@cetest.nl] > Sent: Friday, December 15, 2000 2:21 AM > To: Praveen Rao; 'Nick Williams'; binno...@ems-t.com > Cc: emc-p...@majordomo.ieee.org > Subject: RE: Application of CE Mark > > Hi Praveen, > > I would even attenuate that last statement. Officially the application of > ce > on boxes is forbidden so affixing "ce" would be just an invitation to > search into the boxes .... > :<)) > > I think it should make just no difference to customs if you do or do not > affix the sign, but > as they are human too..... > > Regards, > > Gert Gremmen, (Ing) > > ce-test, qualified testing > > > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > To cancel your subscription, send mail to: > majord...@ieee.org > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Jim Bacher: jim_bac...@mail.monarch.com > Michael Garretson: pstc_ad...@garretson.org > > For policy questions, send mail to: > Richard Nute: ri...@ieee.org > ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson: pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
