I can across this European Commission document on spare parts this week. It maybe of interest. I believe it states that for EMC Directive OEM parts do not require a DoC ergo no CE mark. Google "APPLICATION OF EMC DIRECTIVE AND/OR EMC VEHICLE DIRECTIVE TO AFTERMARKET EQUIPMENT"
http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact=8&ved=0CB4QFjAAahUKEwjfy73C2MnHAhUQRYgKHWphDz4&url=http%3A%2F%2Fec.europa.eu%2FDocsRoom%2Fdocuments%2F4543%2Fattachments%2F1%2Ftranslations%2Fen%2Frenditions%2Fnative&ei=7zvfVZ-YL5CKoQTqwr3wAw&usg=AFQjCNHmvmnYBItTKhMu7bZUXyC2olsYGA See if category B applies to you sub-assemblies? Chuck McDowell Compliance Specialist Meyer Sound Laboratories Inc. -----Original Message----- From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com] Sent: Thursday, August 27, 2015 8:28 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] CE Marking on Packaging of Assembly Components It depends on which directives apply to the product/components. The Machinery Direct is clear that partly complete machinery is not to carry a CE mark to avoid confusion when it's integrated with the complete system. Partly completed machinery should be accompanied by a DoI. However if your items are not machinery but instead fall under the LVD for example and you are going to provide a separate DoC for those items then it would make sense that they be marked. If you are not providing a separate DoC/DoI for these items because they have not been assessed as individual products then perhaps provide documentation/statement that they are part of the larger system to be integrated and provide a copy of the DoC of the complete system but do not CE mark the items/shipping container itself. I wouldn't put a CE mark on a component that falls under MD or LVD without having a DoC/DoI and technical file to back it up. -Dave -----Original Message----- From: Carl Newton [mailto:emcl...@gmail.com] Sent: Thursday, August 27, 2015 8:39 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] CE Marking on Packaging of Assembly Components 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 - ---------------------------------------------------------------- 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. 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