The RoHS directive may well apply, and since the start of this year, that's
been a CE-marking directive.  The D of C will tell you which directives they
are claiming to meet.

 

  _____  

From: Douglas Nix [mailto:d...@mac.com] 
Sent: 03 December 2013 17:12
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] "CE Marking" for wire and cable?

 

Colleagues,

 

For many years it was not possible to CE Mark wire and cable products
because they did not meet the basic definitions for apparatus under the LVD.
I am seeing increasing numbers of these products bearing CE Marks, and I
don't clearly understand the basis for this change in marking. 

 

For reference, 2006/95/EC states in Article 1:

 

Article 1

For the purposes of this Directive, 'electrical equipment' means

any equipment designed for use with a voltage rating of between

50 and 1 000 V for alternating current and between 75 and

1 500 V for direct current, other than the equipment and

phenomena listed in Annex II.

 

Annex II

Equipment and Phenomena outside the Scope of this Directive

*       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.

No further definition of "electrical equipment" is found in the Directive.
Note that wire and cable are not specifically excluded in Annex II.

 

Referring to the International
<http://www.electropedia.org/iev/iev.nsf/welcome?openform>  Electrotechnical
Vocabulary (IEV), IEC 60050  was the next logical step in trying to
understand what is covered. The IEV does not contain a definition for
"electrical equipment", but defines "equipment" 151-11-25
<http://www.electropedia.org/iev/iev.nsf/display?openform&ievref=151-11-25>
:

 

equipment

single apparatus or set of devices or apparatuses, or the set of main
devices of an installation, or all devices necessary to perform a specific
task

Note - Examples of equipment are a power transformer, the equipment of a
substation, measuring equipment.

 

"Apparatus" is defined 151-11-22
<http://www.electropedia.org/iev/iev.nsf/display?openform&ievref=151-11-22>
:

 

apparatus

device or assembly of devices which can be used as an independent unit for
specific functions

Note - In English, the term "apparatus" sometimes implies use by skilled
persons for professional purposes.

 

The definition for "device" is found at 151-11-20
<http://www.electropedia.org/iev/iev.nsf/display?openform&ievref=151-11-20>
:

 

device

material element or assembly of such elements intended to perform a required
function

Note - A device may form part of a larger device.

 

Finally, the definition for a "component", which does not appear in any of
the preceding definitions, is found at 151-11-21
<http://www.electropedia.org/iev/iev.nsf/display?openform&ievref=151-11-21>
:

 

component

constituent part of a device which cannot be physically divided into smaller
parts without losing its particular function

 

Based on these definitions, it seems clear to me that wire and cable
constitute components, and are therefore not devices, apparatus or equipment
and are therefore NOT subject to CE Marking. In addition to this, a quick
search for Declarations of Conformity on a number of wire and cable web
sites turned up NO DECLARATIONS.

 

With the withdrawal of much of the HD 21 and HD 22 series of harmonization
documents and their replacement with the EN 50525 series of standards, will
there be a change that requires the CE Marking of these products? If yes,
what is the legal rationale, since the definition of apparatus under the LVD
still does not seem to include these products?

 

>From the perspective of agencies assessing the compliance of products with
the LVD, what is the requirement regarding markings on wire and cable
products beyond the basic requirement for wire to be marked with the rated
voltage and gauge?

 

Thanks in advance for the assistance!

 

Doug Nix

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