Carl
Personally, I would:
- Decide what is the most major part of the product which has a visible
external surface which be carrying all the other product identification
marking, and then put the CE marking on that part;
- Make sure that the product documentation going to the customers clearly
states that the product will only be compliant with all relevant "CE
Directives" and the DoC when assembled and installed according to the
detailed instructions you provide.
- Before making the final decisions, take a look at the recently updated
Commission "Blue Guide" - and particularly Chp 2 Section 2.1 "Product
Coverage" and the para beginning "A combination of products..." on Page
18
and Chp 4 Section 4.2.2.3 "Identification element" on Page 49.
John Allen
W.London, UK
-----Original Message-----
From: Chuck McDowell [mailto:chu...@meyersound.com]
Sent: 27 August 2015 17:52
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking on Packaging of Assembly Components
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%2Frendi
tions%2Fnative&ei=7zvfVZ-YL5CKoQTqwr3wAw&usg=AFQjCNHmvmnYBItTKhMu7bZUXyC2ols
YGA
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
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