Group,

I'm dealing with a scenario in which a storage assembly that includes some electronic functionality is assembled on-site by end-users. Various elements of this storage product are shipped from different factories. One package may include the electronic subassembly that has the product label attached. Another package may include plastic panels with no inherent standalone function (RoHS does not apply at this time). The set of component packages that comprise the product are imported into the EU from the USA. The UK distributor has asked that all packages have the CE Marking on the box. I'm reluctant to sign-up to this procedure in view of the fact that the CE Marking should not be applied to most sub-assemblies.

I've reviewed the 2014 Blue Guide, Regulation (EC) No 765/2008, and 768/2008/E seeking guidance on this scenario but find nothing. Is anybody within the group aware of some form of legal guidance that applies?

Thanks,

Carl

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