Hello Doug, The RoHS 2 Directive, 2011/65/EU is now a CE marking directive. Its scope covers some wires and cables defined as cables rated less than 250 V that serve as a connection or extention to electronic equipment, either to the outlet or between pieces of equipment. As such, affected cables must be CE marked to meet the requirements.
Regards, Ted Eckert Compliance Engineer Microsoft Corporation ted.eck...@microsoft.com<mailto:ted.eck...@microsoft.com> The opinions expressed are my own and do not necessarily reflect those of my employer. From: Douglas Nix [mailto:d...@mac.com] Sent: Tuesday, December 3, 2013 9:12 AM 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 Electrotechnical Vocabulary (IEV), IEC 60050<http://www.electropedia.org/iev/iev.nsf/welcome?openform> 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 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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