Dave A DoI is only defined for the Machinery Directive, it has no application for other directives (though perhaps your suppliers are not aware of this).
I would not pass-on a supplier's paperwork (e.g., DoCs) with your own product, but retain them in your technical file as a partial basis for your own declarations. Declare to 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives if you believe your product is in scope. Incorporating a component in scope can effectively repurpose it out of scope. For example if you incorporate a gas meter (generally sold for monitoring and billing consumers) into a product just to measure gas feed into e.g., a toxic gas burner (and no "public interest" is involved per se), then I do not think it would be in scope of 20014/22/EC for that use. Regards, Lauren Crane KLA-Tencor -----Original Message----- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Friday, January 16, 2015 12:14 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CE Declaration of Conformity Hi folks, I design and manufacture light machinery that includes some sub-assemblies which we purchase and integrate. The sub-assemblies come with their own DoI. In particular I may integrate automatic and non-automatic weighing scales that would come with a DoI or DoC for the machinery and directive and a DoC or DoI for the EMC, 2004/22/EC Measuring Instruments, and 2009/23/EC Non-automatic Weighing Instruments directives. I do not modify the weighing functionality of the scales nor do I do any additional certification on them. The metrology directives require special marking, the CE mark as well as the "M" mark and notified body ID which come already on the units I integrate. There are no weighing devices that I directly manufacturer that are part of the machinery. What I'm not clear on is whether I should claim compliance to the 2004/22/EC Measuring Instruments and 2009/23/EC Non-automatic Weighing Instruments directives on my DoC and/or product nameplate for the complete machine or whether I should just include the OEM's DoC along with my DoC in the paperwork supplied with the machine (and technical file). I don't know if this situation is different than any are CE marked component within the machine but it would seem so. The EU directives do not actually apply directly to many components that the OEM marks and claims compliance to CE to make it easier for system builders like me. (Some actually state that on their DoCs). The Metrology directives are specific to the scales. Does anyone have any experience with this or something similar? thanks David P. Nyffenegger, PMP, SM-IEEE Product Development Manager - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
