That is what used to be called a 'system', although the term seems to
have been dropped now. Each piece should be CE marked, otherwise the
surveillance authorities won't know it's legitimate. You don't need a
DoC for each bit, only for the system, but each bit needs an identifier,
which could be a part number, but could also be something less nerdy.
For example, if the whole system is called 'E-Box One', the bits could
be marked 'EB1a', 'EB1b'... . Upgrade bits can refer to the system DoC
provided they are explicitly included in it. They need the CE mark and
the identifier. Supplying a replacement part IS officially 'marketing'
in Europe.
That is, in my opinion, the simplest solution. You might be able to
claim that, as an add-on has no function on its own, other rules apply,
but I think this is just adding a needless complication. However you
describe the bits, they have to meet all applicable Directives and
Regulations. There is no escape.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-08-12 19:31, Brian Kunde wrote:
If I have an electronic product that I want to place on the market in
Europe, and the product is made up of several individual electronic
devices each powered by AC mains (packaged and sold together), do I
place the CE marking on only one of the devices or all devices?
And if the answer is "all devices", then do I need a DoC for each
device or will one DoC be ok? If each device has its own identifier,
can I just list all identifiers on the DoC? OR can I simply list what
the devices are instead of their specific part numbers?
In the same train of thought, If my product is called "E-box One", for
example, AND the product is made up of many individual electronic
devices each with their own identifying part number, does the
marketing name "E-box One" have to be on at least one of the devices
that make it up OR does it have to be on every one of the devices?
How do we handle the case were say two years down the road a customer
with a 4-device system wants to expand to a 5-device system?
Individually these devices are nothing and could be viewed as an
upgrade kit. Does this "kit" have to have its own CE Marking and DoC?
What if the "kit" is not officially marketed; just the customer
ordered a kit similar to ordering a replacement part?
How should these be handled?
Thanks,
The Other Brian
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