Re: [PSES] CE marking for avionic in-flight entertainment equipment

[Karen Burnham]

Would the component requirements of RTCA DO160 apply here?

Best,

-=-Karen Burnham
President and Chief EMC Engineer, NCE
EMC United, Inc.
www.emcunited.com


On Wed, Sep 11, 2024 at 1:18 PM Charlie Blackham <
char...@sulisconsultants.com> wrote:

> David
>
>
>
> Given that you can only CE Mark a product when it is in the scope of, and
> compliant with, one or more Directives that require/allow for CE Marking,
> you need to explain to your customers why your products are out of scope –
> I would recommend citing the applicable Articles and Annexes in the
> Directives that would otherwise be applicable.
>
>
>
> There may well be other requirements that you need to comply with that are
> outside the scope of these Directives.
>
>
>
> If you sell these items for use other than on aircraft, they would of
> course need to be CE marked
>
>
>
> Best regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: https://sulisconsultants.com/ <https://sulisconsultants.com/> *
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* David Gelfand 
> *Sent:* 11 September 2024 16:40
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] CE marking for avionic in-flight entertainment equipment
>
>
>
> Hello to all,
>
>
>
> What CE directives and which standards would apply to electronic equipment
> to be installed in an aircraft?  LVD, EMCD and RED do not seem to apply.
>
>
>
> We design and manufacture servers with satellite and LTE modems, for
> in-flight wifi access and entertainment.  Some of our clients are asking
> for CE marking.  Any guidance would be most appreciated.
>
>
>
> Thanks,
>
>
>
> David
>
>
>
> *David Gelfand, Ing. P.Eng.*
>
> Spécialiste en conformité / Conformity Specialist
>
>
>
> [image: A blue text on a black background Description automatically
> generated] <https://kontron.com/>
>
> [image: signature_811446924]
>
> *Kontron Canada Inc.  *4555 Ambroise-Lafortune | Boisbriand (Québec) J7H
> 0A4 | Canada   •   Privacy Statement
> <https://www.kontron.com/en/privacy-statement> |Legal Statement
> <https://www.kontron.com/en/legal-and-copyright-information> |Communications
> Électroniques
> <http://www.kontron.com/additional/informations-legales-et-droits-d-auteur>
>
>
>
> [image: A blue and black logo Description automatically generated]
> <https://www.linkedin.com/company/2661537> [image: A black and green
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Re: [PSES] CE marking for avionic in-flight entertainment equipment

[Charlie Blackham]

David

Given that you can only CE Mark a product when it is in the scope of, and 
compliant with, one or more Directives that require/allow for CE Marking, you 
need to explain to your customers why your products are out of scope - I would 
recommend citing the applicable Articles and Annexes in the Directives that 
would otherwise be applicable.

There may well be other requirements that you need to comply with that are 
outside the scope of these Directives.

If you sell these items for use other than on aircraft, they would of course 
need to be CE marked

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: David Gelfand 
Sent: 11 September 2024 16:40
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE marking for avionic in-flight entertainment equipment

Hello to all,

What CE directives and which standards would apply to electronic equipment to 
be installed in an aircraft?  LVD, EMCD and RED do not seem to apply.

We design and manufacture servers with satellite and LTE modems, for in-flight 
wifi access and entertainment.  Some of our clients are asking for CE marking.  
Any guidance would be most appreciated.

Thanks,

David

David Gelfand, Ing. P.Eng.
Spécialiste en conformité / Conformity Specialist

[A blue text on a black background  Description automatically 
generated]<https://kontron.com/>

Kontron Canada Inc.  4555 Ambroise-Lafortune | Boisbriand (Québec) J7H 0A4 | 
Canada   *   Privacy Statement<https://www.kontron.com/en/privacy-statement> 
|Legal Statement<https://www.kontron.com/en/legal-and-copyright-information> 
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Électroniques<http://www.kontron.com/additional/informations-legales-et-droits-d-auteur>

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[PSES] CE marking for avionic in-flight entertainment equipment

[David Gelfand]

Hello to all,

What CE directives and which standards would apply to electronic equipment to 
be installed in an aircraft?  LVD, EMCD and RED do not seem to apply.

We design and manufacture servers with satellite and LTE modems, for in-flight 
wifi access and entertainment.  Some of our clients are asking for CE marking.  
Any guidance would be most appreciated.

Thanks,

David

David Gelfand, Ing. P.Eng.
Spécialiste en conformité / Conformity Specialist

[A blue text on a black background  Description automatically 
generated]<https://kontron.com/>

Kontron Canada Inc.  4555 Ambroise-Lafortune | Boisbriand (Québec) J7H 0A4 | 
Canada   *   Privacy Statement<https://www.kontron.com/en/privacy-statement> 
|Legal Statement<https://www.kontron.com/en/legal-and-copyright-information> 
|Communications 
Électroniques<http://www.kontron.com/additional/informations-legales-et-droits-d-auteur>

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Re: [PSES] AW: [PSES] Directives that require the CE Marking

[Charlie Blackham]

Me again 😊

The opening sentence tells you to tread carefully:

The CE mark is a certification mark that indicates conformity with health, 
safety, and environmental protection standards for products sold within the 
European Economic Area (EEA


  *   It’s not a “certification” mark
  *   Not all CE marking Directives cover safety or health
  *   There are no CE marking Directives that cover environmental protection
  *   The rules don’t apply to products “sold”, they apply to products “placed 
on the market” – there doesn’t need to be a monetary exchange, and the lack of 
one does not put you out of scope

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: rmm.priv...@gmail.com 
Sent: Sunday, October 8, 2023 4:56 PM
To: Charlie Blackham 
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] AW: [PSES] Directives that require the CE Marking

I agree that tools like ChatGPT have a long way to go before their response can 
be trusted without question, but the response below is from the free version.  
The $20 a month version might provide a clearer answer.  I use ChatGPT as a 
starting point for topics I have some familiarity with, then I drill down on 
the details.

I asked ChatGPT “under what conditions should I not apply the CE Mark ?”, and 
it answered:

=
The CE mark is a certification mark that indicates conformity with health, 
safety, and environmental protection standards for products sold within the 
European Economic Area (EEA).  It demonstrates that a product complies with the 
relevant EU directives and regulations. However, there are certain conditions 
or situations where you should not apply the CE mark:

  1.  Non-conforming products: If your product does not meet the essential 
requirements or standards specified by the relevant EU directives or 
regulations, you should not apply the CE mark. It is essential to ensure that 
your product complies with all applicable requirements before affixing the CE 
mark.
  2.  Non-covered products: Some products or product categories may not be 
covered by specific EU directives or regulations, and therefore, the CE mark 
may not be applicable to them. Always check whether your product falls under 
any relevant EU legislation before considering the CE mark.
  3.  Self-declaration without applicable legislation: In some cases, a 
manufacturer may incorrectly self-declare conformity and affix the CE mark to a 
product without any applicable EU directive or regulation. This is not allowed, 
and the CE mark should only be applied when there is clear and relevant 
legislation to comply with.
  4.  Non-EEA sales: The CE mark is primarily intended for products intended 
for sale within the EEA. If your product is not intended for the EEA market, 
applying the CE mark may not be necessary. However, you should comply with the 
regulatory requirements of the specific market where you intend to sell your 
product.
  5.  Unauthorized use: The CE mark should only be applied by manufacturers or 
authorized representatives who have fulfilled the necessary conformity 
assessment procedures and legal obligations. Unauthorized use of the CE mark is 
not allowed and can result in legal consequences.
  6.  False or misleading information: Providing false or misleading 
information, documentation, or test results to obtain the CE mark is illegal 
and should not be done under any circumstances.

It's crucial to consult with regulatory authorities, experts, or legal counsel 
knowledgeable about the specific product and its applicable regulations to 
ensure compliance with CE marking requirements. Incorrectly applying the CE 
mark can lead to legal consequences, including fines and product recalls.
==

Ralph

From: Charlie Blackham 
mailto:char...@sulisconsultants.com>>
Sent: Saturday, October 7, 2023 1:17 AM
To: rmm.priv...@gmail.com<mailto:rmm.priv...@gmail.com>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] AW: [PSES] Directives that require the CE Marking

A nice example of why ChatGPT won’t put us all out of a job just yet 😊

Point 9 is wrong – you may not use the CE mark to demonstrate compliance with a 
“non CE marking” Directive, that is one that does not contain the provision for 
CE marking within its Articles or Annexes

Point 3 does not make it clear that the Directive also includes products that 
are “likely, under reasonably foreseeable conditions, to be used by consumers 
even if not intended for them” – an example of this would be something like a 
corporate branded battery pack phone charger which is supplied only on a B2B 
basis, but is likely to be taken home by the recipient

Best regards
Charlie

Charlie Blackha

Re: [PSES] [PSES] Directives that require the CE Marking

[Douglas Nix]

Gentlemen,

ChatGPT is not a research tool. It hallucinates wildly because it is optimized 
to give a response to the user.

Do not use ChatGPT as a research tool unless you want to be mislead. There are 
many many other, better tools for this purpose.

Doug Nix
d...@mac.com

"The man who does not read good books has no advantage over the man who can't 
read these books." Mark Twain 

> On Oct 8, 2023, at 11:55, Ralph McDiarmid  wrote:
> 
> I agree that tools like ChatGPT have a long way to go before their response 
> can be trusted without question, but the response below is from the free 
> version.  The $20 a month version might provide a clearer answer.  I use 
> ChatGPT as a starting point for topics I have some familiarity with, then I 
> drill down on the details.
>  
> I asked ChatGPT “under what conditions should I not apply the CE Mark ?”, and 
> it answered:
>  
> =
> The CE mark is a certification mark that indicates conformity with health, 
> safety, and environmental protection standards for products sold within the 
> European Economic Area (EEA).  It demonstrates that a product complies with 
> the relevant EU directives and regulations. However, there are certain 
> conditions or situations where you should not apply the CE mark:
> Non-conforming products: If your product does not meet the essential 
> requirements or standards specified by the relevant EU directives or 
> regulations, you should not apply the CE mark. It is essential to ensure that 
> your product complies with all applicable requirements before affixing the CE 
> mark.
> Non-covered products: Some products or product categories may not be covered 
> by specific EU directives or regulations, and therefore, the CE mark may not 
> be applicable to them. Always check whether your product falls under any 
> relevant EU legislation before considering the CE mark.
> Self-declaration without applicable legislation: In some cases, a 
> manufacturer may incorrectly self-declare conformity and affix the CE mark to 
> a product without any applicable EU directive or regulation. This is not 
> allowed, and the CE mark should only be applied when there is clear and 
> relevant legislation to comply with.
> Non-EEA sales: The CE mark is primarily intended for products intended for 
> sale within the EEA. If your product is not intended for the EEA market, 
> applying the CE mark may not be necessary. However, you should comply with 
> the regulatory requirements of the specific market where you intend to sell 
> your product.
> Unauthorized use: The CE mark should only be applied by manufacturers or 
> authorized representatives who have fulfilled the necessary conformity 
> assessment procedures and legal obligations. Unauthorized use of the CE mark 
> is not allowed and can result in legal consequences.
> False or misleading information: Providing false or misleading information, 
> documentation, or test results to obtain the CE mark is illegal and should 
> not be done under any circumstances.
>  
> It's crucial to consult with regulatory authorities, experts, or legal 
> counsel knowledgeable about the specific product and its applicable 
> regulations to ensure compliance with CE marking requirements. Incorrectly 
> applying the CE mark can lead to legal consequences, including fines and 
> product recalls.
> ==
>  
> Ralph
>  
> From: Charlie Blackham  
> Sent: Saturday, October 7, 2023 1:17 AM
> To: rmm.priv...@gmail.com; EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: RE: [PSES] AW: [PSES] Directives that require the CE Marking
>  
> A nice example of why ChatGPT won’t put us all out of a job just yet 😊
>  
> Point 9 is wrong – you may not use the CE mark to demonstrate compliance with 
> a “non CE marking” Directive, that is one that does not contain the provision 
> for CE marking within its Articles or Annexes
>  
> Point 3 does not make it clear that the Directive also includes products that 
> are “likely, under reasonably foreseeable conditions, to be used by consumers 
> even if not intended for them” – an example of this would be something like a 
> corporate branded battery pack phone charger which is supplied only on a B2B 
> basis, but is likely to be taken home by the recipient
>  
> Best regards
> Charlie
>  
> Charlie Blackham
> Sulis Consultants Ltd
> Tel: +44 (0)7946 624317
> Web: https://sulisconsultants.com/
> Registered in England and Wales, number 05466247
>  
> From: Ralph McDiarmid mailto:rmm.priv...@gmail.com>> 
> Sent: Friday, October 6, 2023 10:59 PM
> To: EMC-PSTC@LISTSERV.IEEE.OR

Re: [PSES] AW: [PSES] Directives that require the CE Marking

[Ralph McDiarmid]

I agree that tools like ChatGPT have a long way to go before their response can 
be trusted without question, but the response below is from the free version.  
The $20 a month version might provide a clearer answer.  I use ChatGPT as a 
starting point for topics I have some familiarity with, then I drill down on 
the details.

 

I asked ChatGPT “under what conditions should I not apply the CE Mark ?”, and 
it answered:

 

=

The CE mark is a certification mark that indicates conformity with health, 
safety, and environmental protection standards for products sold within the 
European Economic Area (EEA).  It demonstrates that a product complies with the 
relevant EU directives and regulations. However, there are certain conditions 
or situations where you should not apply the CE mark:

1.  Non-conforming products: If your product does not meet the essential 
requirements or standards specified by the relevant EU directives or 
regulations, you should not apply the CE mark. It is essential to ensure that 
your product complies with all applicable requirements before affixing the CE 
mark.
2.  Non-covered products: Some products or product categories may not be 
covered by specific EU directives or regulations, and therefore, the CE mark 
may not be applicable to them. Always check whether your product falls under 
any relevant EU legislation before considering the CE mark.
3.  Self-declaration without applicable legislation: In some cases, a 
manufacturer may incorrectly self-declare conformity and affix the CE mark to a 
product without any applicable EU directive or regulation. This is not allowed, 
and the CE mark should only be applied when there is clear and relevant 
legislation to comply with.
4.  Non-EEA sales: The CE mark is primarily intended for products intended 
for sale within the EEA. If your product is not intended for the EEA market, 
applying the CE mark may not be necessary. However, you should comply with the 
regulatory requirements of the specific market where you intend to sell your 
product.
5.  Unauthorized use: The CE mark should only be applied by manufacturers 
or authorized representatives who have fulfilled the necessary conformity 
assessment procedures and legal obligations. Unauthorized use of the CE mark is 
not allowed and can result in legal consequences.
6.  False or misleading information: Providing false or misleading 
information, documentation, or test results to obtain the CE mark is illegal 
and should not be done under any circumstances.

 

It's crucial to consult with regulatory authorities, experts, or legal counsel 
knowledgeable about the specific product and its applicable regulations to 
ensure compliance with CE marking requirements. Incorrectly applying the CE 
mark can lead to legal consequences, including fines and product recalls.

==

 

Ralph

 

From: Charlie Blackham  
Sent: Saturday, October 7, 2023 1:17 AM
To: rmm.priv...@gmail.com; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] AW: [PSES] Directives that require the CE Marking

 

A nice example of why ChatGPT won’t put us all out of a job just yet 😊

 

Point 9 is wrong – you may not use the CE mark to demonstrate compliance with a 
“non CE marking” Directive, that is one that does not contain the provision for 
CE marking within its Articles or Annexes

 

Point 3 does not make it clear that the Directive also includes products that 
are “likely, under reasonably foreseeable conditions, to be used by consumers 
even if not intended for them” – an example of this would be something like a 
corporate branded battery pack phone charger which is supplied only on a B2B 
basis, but is likely to be taken home by the recipient

 

Best regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web: https://sulisconsultants.com/ 

Registered in England and Wales, number 05466247

 

From: Ralph McDiarmid mailto:rmm.priv...@gmail.com> > 
Sent: Friday, October 6, 2023 10:59 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] AW: [PSES] Directives that require the CE Marking

 

Here’s what ChatGPT told me about this directive:

 

The General Product Safety Directive (2001/95/EC) in the European Union (EU) is 
a legal framework designed to ensure the safety of consumer products placed on 
the EU market. It sets out general requirements for the safety of products, 
regardless of whether specific product safety regulations exist for them. Here 
are key aspects of the General Product Safety Directive (GPSD):

1.  Scope: The GPSD applies to all consumer products, excluding food, 
pharmaceuticals, medical devices, cosmetics, and chemicals, which are covered 
by other specific regulations.
2.  Safety Requirement: The primary obje

Re: [PSES] AW: [PSES] Directives that require the CE Marking

[Charlie Blackham]

A nice example of why ChatGPT won’t put us all out of a job just yet 😊

Point 9 is wrong – you may not use the CE mark to demonstrate compliance with a 
“non CE marking” Directive, that is one that does not contain the provision for 
CE marking within its Articles or Annexes

Point 3 does not make it clear that the Directive also includes products that 
are “likely, under reasonably foreseeable conditions, to be used by consumers 
even if not intended for them” – an example of this would be something like a 
corporate branded battery pack phone charger which is supplied only on a B2B 
basis, but is likely to be taken home by the recipient

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Ralph McDiarmid 
Sent: Friday, October 6, 2023 10:59 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] AW: [PSES] Directives that require the CE Marking

Here’s what ChatGPT told me about this directive:

The General Product Safety Directive (2001/95/EC) in the European Union (EU) is 
a legal framework designed to ensure the safety of consumer products placed on 
the EU market. It sets out general requirements for the safety of products, 
regardless of whether specific product safety regulations exist for them. Here 
are key aspects of the General Product Safety Directive (GPSD):

  1.  Scope: The GPSD applies to all consumer products, excluding food, 
pharmaceuticals, medical devices, cosmetics, and chemicals, which are covered 
by other specific regulations.
  2.  Safety Requirement: The primary objective of the GPSD is to ensure that 
products placed on the market are safe for consumers when used under normal or 
reasonably foreseeable conditions. Manufacturers and distributors have an 
obligation to provide safe products.
  3.  Definition of Consumer Products: The directive defines "consumer 
products" broadly to encompass any product intended for consumers, including 
both new and second-hand products.
  4.  Obligations of Economic Operators: Economic operators, including 
manufacturers, importers, and distributors, must ensure that products they 
place on the market are safe. They are responsible for assessing and managing 
risks, monitoring product safety, and taking corrective actions if safety 
issues arise.
  5.  Traceability: Economic operators must be able to trace the origin of the 
products they handle and, if necessary, inform the relevant authorities and 
consumers about safety issues or recalls.
  6.  Rapid Alert System: The GPSD establishes a Rapid Alert System for 
Non-Food (RAPEX) to facilitate the rapid exchange of information about 
dangerous products among EU member states and the European Commission. This 
system helps to ensure that dangerous products are quickly removed from the 
market.
  7.  Market Surveillance: EU member states are responsible for carrying out 
market surveillance activities to ensure compliance with the GPSD. They can 
take measures such as conducting inspections, ordering recalls, or imposing 
fines for non-compliance.
  8.  Cooperation with Other EU Legislation: The GPSD complements other EU 
product safety regulations, such as the Toy Safety Directive or the Machinery 
Directive. In cases where specific product safety legislation exists, that 
legislation takes precedence.
  9.  CE Marking: While the GPSD does not require products to bear the CE 
marking (a conformity marking indicating compliance with EU safety standards), 
manufacturers may choose to use it to demonstrate compliance with the directive.
  10. Harmonized Standards: Manufacturers can use harmonized European standards 
to demonstrate compliance with the GPSD's safety requirements.
The General Product Safety Directive plays a crucial role in protecting 
consumers within the EU by establishing a baseline level of safety for a wide 
range of consumer products. It encourages manufacturers and other economic 
operators to ensure that their products are safe for use and allows for swift 
action in the event of safety concerns. It is important to note that the GPSD 
is subject to updates and amendments to align with changing safety requirements 
and technological advancements.

Ralph

From: Dürrer Bernd mailto:bernd.duer...@wilo.com>>
Sent: Tuesday, September 19, 2023 6:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] AW: [PSES] Directives that require the CE Marking

Hello Brian,

in lack of any more specific EU Directive, a product will be in the scope of 
the General Product Safety Directive 2001/95/EC (Consolidated TEXT: 32001L0095 
— EN — 01.01.2010 
(europa.eu)<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02001L0095-20100101#tocId3>)
 that covers any product intended for consumers. As far as I know, the GPSD 
does neither require a CE Declaration of Conformity, nor CE marking on the 
prod

Re: [PSES] AW: [PSES] Directives that require the CE Marking

[Ralph McDiarmid]

Here’s what ChatGPT told me about this directive:

 

The General Product Safety Directive (2001/95/EC) in the European Union (EU)
is a legal framework designed to ensure the safety of consumer products
placed on the EU market. It sets out general requirements for the safety of
products, regardless of whether specific product safety regulations exist
for them. Here are key aspects of the General Product Safety Directive
(GPSD):

1.  Scope: The GPSD applies to all consumer products, excluding food,
pharmaceuticals, medical devices, cosmetics, and chemicals, which are
covered by other specific regulations.
2.  Safety Requirement: The primary objective of the GPSD is to ensure
that products placed on the market are safe for consumers when used under
normal or reasonably foreseeable conditions. Manufacturers and distributors
have an obligation to provide safe products.
3.  Definition of Consumer Products: The directive defines "consumer
products" broadly to encompass any product intended for consumers, including
both new and second-hand products.
4.  Obligations of Economic Operators: Economic operators, including
manufacturers, importers, and distributors, must ensure that products they
place on the market are safe. They are responsible for assessing and
managing risks, monitoring product safety, and taking corrective actions if
safety issues arise.
5.  Traceability: Economic operators must be able to trace the origin of
the products they handle and, if necessary, inform the relevant authorities
and consumers about safety issues or recalls.
6.  Rapid Alert System: The GPSD establishes a Rapid Alert System for
Non-Food (RAPEX) to facilitate the rapid exchange of information about
dangerous products among EU member states and the European Commission. This
system helps to ensure that dangerous products are quickly removed from the
market.
7.  Market Surveillance: EU member states are responsible for carrying
out market surveillance activities to ensure compliance with the GPSD. They
can take measures such as conducting inspections, ordering recalls, or
imposing fines for non-compliance.
8.  Cooperation with Other EU Legislation: The GPSD complements other EU
product safety regulations, such as the Toy Safety Directive or the
Machinery Directive. In cases where specific product safety legislation
exists, that legislation takes precedence.
9.  CE Marking: While the GPSD does not require products to bear the CE
marking (a conformity marking indicating compliance with EU safety
standards), manufacturers may choose to use it to demonstrate compliance
with the directive.
10. Harmonized Standards: Manufacturers can use harmonized European
standards to demonstrate compliance with the GPSD's safety requirements.

The General Product Safety Directive plays a crucial role in protecting
consumers within the EU by establishing a baseline level of safety for a
wide range of consumer products. It encourages manufacturers and other
economic operators to ensure that their products are safe for use and allows
for swift action in the event of safety concerns. It is important to note
that the GPSD is subject to updates and amendments to align with changing
safety requirements and technological advancements.

 

Ralph

 

From: Dürrer Bernd  
Sent: Tuesday, September 19, 2023 6:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] AW: [PSES] Directives that require the CE Marking

 

Hello Brian,

 

in lack of any more specific EU Directive, a product will be in the scope of
the General Product Safety Directive 2001/95/EC (
<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02001L0095-2
0100101#tocId3> Consolidated TEXT: 32001L0095 — EN — 01.01.2010 (europa.eu))
that covers any product intended for consumers. As far as I know, the GPSD
does neither require a CE Declaration of Conformity, nor CE marking on the
product. An overview of EU Directives and applicable harmonized standards
may be found at
<https://single-market-economy.ec.europa.eu/single-market/european-standards
/harmonised-standards_en> Harmonised Standards (europa.eu).

 

Is the product intended to be permanently connected to a potable water
supply? If yes, national regulations of EU member countries may apply.

 

Kind regards,

 

Bernd

 

Von: Brian Kunde mailto:bkundew...@gmail.com> > 
Gesendet: Dienstag, 19. September 2023 15:31
An: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Betreff: [PSES] Directives that require the CE Marking

 


[EXTERNAL E-MAIL] This email originated from outside of the organization. Do
not click links or open attachments unless you recognize the sender. 



I have a non-electrical benchtop product that holds a piece of sandpaper
while slowly running water over the sandpaper. The only connection to this
product is a water supply at normal water supply pressure.  The User holds
the item they want to sand in their

Re: [PSES] Directives that require the CE Marking

[Chris Wordley]

Hi Brian

Unless it is for use in an explosive atmosphere, then I can’t see that any CE 
marking legislation will apply. 

If it is intended for consumers or likely, under reasonably foreseeable 
conditions, to be used by consumers even if not intended for them, then the 
General Product Safety Directive (and its replacement the General Product 
Safety Regulation) would apply. Plus there’s REACH that applies to almost 
everything. 

And yes, 'Sales and Marketing types’ are the same the world over.  

Regards
Chris 


> On 19 Sep 2023, at 14:31, Brian Kunde  wrote:
> 
> I have a non-electrical benchtop product that holds a piece of sandpaper 
> while slowly running water over the sandpaper. The only connection to this 
> product is a water supply at normal water supply pressure.  The User holds 
> the item they want to sand in their hand and rubs it back and forth on the 
> sandpaper.  It is as simple as that.
> 
> Is there an EU Directive that covers this type of product and if so, is the 
> Directive part of the CE Scheme?  I don't think there is but I am not 
> familiar with all of the EU Directives.  
> 
> 
> So why am I asking?  Believe it or not, some Sales and Marketing types like 
> to see the CE Marking on products. They feel it makes things sell better and 
> it avoids uneducated customers from asking why there is no CE marking on the 
> product.  
> 
> Thanks for any advice, ideas, information, or suggestions.
> The Other Brian
> 
> 
> 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 All 
> emc-pstc postings are archived and searchable on the web at: 
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[PSES] AW: [PSES] Directives that require the CE Marking

[Dürrer Bernd]

Hello Brian,

in lack of any more specific EU Directive, a product will be in the scope of 
the General Product Safety Directive 2001/95/EC (Consolidated TEXT: 32001L0095 
- EN - 01.01.2010 
(europa.eu)<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02001L0095-20100101#tocId3>)
 that covers any product intended for consumers. As far as I know, the GPSD 
does neither require a CE Declaration of Conformity, nor CE marking on the 
product. An overview of EU Directives and applicable harmonized standards may 
be found at Harmonised Standards 
(europa.eu)<https://single-market-economy.ec.europa.eu/single-market/european-standards/harmonised-standards_en>.

Is the product intended to be permanently connected to a potable water supply? 
If yes, national regulations of EU member countries may apply.

Kind regards,

Bernd

Von: Brian Kunde 
Gesendet: Dienstag, 19. September 2023 15:31
An: EMC-PSTC@LISTSERV.IEEE.ORG
Betreff: [PSES] Directives that require the CE Marking

[EXTERNAL E-MAIL] This email originated from outside of the organization. Do 
not click links or open attachments unless you recognize the sender.
I have a non-electrical benchtop product that holds a piece of sandpaper while 
slowly running water over the sandpaper. The only connection to this product is 
a water supply at normal water supply pressure.  The User holds the item they 
want to sand in their hand and rubs it back and forth on the sandpaper.  It is 
as simple as that.

Is there an EU Directive that covers this type of product and if so, is the 
Directive part of the CE Scheme?  I don't think there is but I am not familiar 
with all of the EU Directives.


So why am I asking?  Believe it or not, some Sales and Marketing types like to 
see the CE Marking on products. They feel it makes things sell better and it 
avoids uneducated customers from asking why there is no CE marking on the 
product.

Thanks for any advice, ideas, information, or suggestions.
The Other Brian




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[PSES] Directives that require the CE Marking

[Brian Kunde]

I have a non-electrical benchtop product that holds a piece of sandpaper
while slowly running water over the sandpaper. The only connection to this
product is a water supply at normal water supply pressure.  The User holds
the item they want to sand in their hand and rubs it back and forth on the
sandpaper.  It is as simple as that.

Is there an EU Directive that covers this type of product and if so, is the
Directive part of the CE Scheme?  I don't think there is but I am not
familiar with all of the EU Directives.


So why am I asking?  Believe it or not, some Sales and Marketing types like
to see the CE Marking on products. They feel it makes things sell better
and it avoids uneducated customers from asking why there is no CE marking
on the product.

Thanks for any advice, ideas, information, or suggestions.
The Other Brian

-

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Re: [PSES] CE marking of a high voltage output supply for laboratory / industrial environmental use

[Douglas E Powell]

I have worked with H.V. power supplies in the past, and there is a point
where IEC-based standards simply run out.

In most cases, I found certifying agencies are accepting of IEC 61010-1 (or
national derivatives) using the tables in Annex K (2010 edition). You still
need to pay attention to the mains voltage, but in your case I believe the
spacings you need are all secondary circuits. Starting at Table K.10 and
following.  In there you will find clearance and creepage requirements up
to 63 kV.  This will apply to steady state voltages as well as calculations
for plasma strike voltages, in the standard referred to as temporary
overvoltages or repetitive peaks.

Above 63 kV, I found some agencies I worked with were willing to accept an
engineering rationale using classical HV e-field evaluation for uniform
fields around geometric structures for clearances; and a linear
extrapolation for creepage, up to as high as 200 kV.  Of course, creepage
can never be less than clearance in your results.  And you must pay
close attention to electrode shaping, CTI, Pollution Degree, altitude, etc.
I also found it very helpful to study parts of the IEC 60664-X standards.
There is a wealth of information there.

The considerations for solid insulation are very different, and the old
rule of thumb using 0.4mm thickness for everything is no where close to
accurate.  Let's just say that small thicknesses like that are almost
useless after a point, and especially when the solid insulation is adjacent
to an air gap, which essentially forms a multiple dielectric capacitor.  As
it turns out, almost 100% of the voltage distributed across the dielectric
stack up is impressed almost entirely on the air layer, as opposed to that
of the solid insulation layer.

Best of luck,  -Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com
LinkedIn 

(UTC -06:00) Mountain Time (US-MDT)






On Thu, Aug 18, 2022 at 1:43 PM  wrote:

> Dear experts,
>
>
>
> A client is looking for regulatory guidance to CE certify a high voltage
> output supply  (with regular AC mains 230V/50Hz input).
>
> The supply has an output voltage upto 25kV (upto 50kHz) output.   It
> concerns a supply to be used for plasma reactor applications.
>
>
>
> As the output voltage is not inside the  voltage limits for the Low
> Voltage Directive, the LVD directive is not applicable?
>
> The  Machine Directive also excludes these high voltage products.
>
>
>
> So, wondering which Directive to apply related tot he safety testing
> part.  (The General Safety Product Directive?)
>
> Any suggestions as to which safety standard to apply for such products?
>
>
>
> Any suggestions are highly appreciated.
>
>
>
> Thanks !
> -
> 
>
> 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
>
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> unsubscribe) 
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>
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>
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> Jim Bacher 
> David Heald 
> --
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Re: [PSES] CE marking of a high voltage output supply for laboratory / industrial environmental use

[bart . de . geeter]

Thanks Gert,

 

I agree with you that the LVD directive is indeed applicable: 

 

I looked up the original tekst which states the below:  (the confusion was that 
another source was stating that both input and output voltages needed to fit 
within these limits, which does not seem to be the case. )  The standards you 
refer were indeed also the onces we were considering at first.

Article 1

Subject matter and scope

The purpose of this Directive is to ensure that electrical equipment on the 
market fulfils the requirements providing for a high level of protection of 
health and safety of persons, and of domestic animals and property, while 
guaranteeing the functioning of the internal market.

This Directive shall apply to electrical equipment designed for use with a 
voltage rating of between 50 and 1 000 V for alternating current and between 75 
and 1 500 V for direct current, other than the equipment and phenomena listed 
in Annex II.

 

 

Thanks for your help !

 

Greetings,

Bart

 

Van: Gert Gremmen  
Verzonden: donderdag 18 augustus 2022 21:59
Aan: bart.de.gee...@telenet.be; EMC-PSTC@LISTSERV.IEEE.ORG
Onderwerp: Re: [PSES] CE marking of a high voltage output supply for laboratory 
/ industrial environmental use

 

Dear Bart,

As the input is within the LVD limit, the whole equipment is.

EN 61326-1 comes to mind for EMC

EN 61010-1 for electrical safety

The output is just a "circuit" (in terms of 61010) and clearance and creepage 
requirement (up to 60 kV) are given in Table 6 and 7

There are more requirements than just clearance and creepage.

Good luck in making your equipment safe.

Gert Gremmen

 

On 18-8-2022 21:43, bart.de.gee...@telenet.be 
<mailto:bart.de.gee...@telenet.be>  wrote:

Dear experts,

 

A client is looking for regulatory guidance to CE certify a high voltage output 
supply  (with regular AC mains 230V/50Hz input).

The supply has an output voltage upto 25kV (upto 50kHz) output.   It concerns a 
supply to be used for plasma reactor applications.

 

As the output voltage is not inside the  voltage limits for the Low Voltage 
Directive, the LVD directive is not applicable?

The  Machine Directive also excludes these high voltage products.

 

So, wondering which Directive to apply related tot he safety testing part.  
(The General Safety Product Directive?)  

Any suggestions as to which safety standard to apply for such products?

 

Any suggestions are highly appreciated.

 

Thanks !

-


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-- 
Independent Expert on CE marking 
EMC Consultant
Electrical Safety Consultant

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Re: [PSES] CE marking of a high voltage output supply for laboratory / industrial environmental use

[Scott Aldous]

You may find this article from UL helpful:

https://code-authorities.ul.com/wp-content/uploads/sites/40/2015/02/UL_WP_Final_Effects-of-High-Frequency-Voltage-Stress-on-Air-Insulation-and-Solid-Insulation_v4_HR.pdf

On Thu, Aug 18, 2022 at 12:59 PM Gert Gremmen  wrote:

> Dear Bart,
>
> As the input is within the LVD limit, the whole equipment is.
>
> EN 61326-1 comes to mind for EMC
>
> EN 61010-1 for electrical safety
>
> The output is just a "circuit" (in terms of 61010) and clearance and
> creepage requirement (up to 60 kV) are given in Table 6 and 7
>
> There are more requirements than just clearance and creepage.
>
> Good luck in making your equipment safe.
>
> Gert Gremmen
>
>
> On 18-8-2022 21:43, bart.de.gee...@telenet.be wrote:
>
> Dear experts,
>
>
>
> A client is looking for regulatory guidance to CE certify a high voltage
> output supply  (with regular AC mains 230V/50Hz input).
>
> The supply has an output voltage upto 25kV (upto 50kHz) output.   It
> concerns a supply to be used for plasma reactor applications.
>
>
>
> As the output voltage is not inside the  voltage limits for the Low
> Voltage Directive, the LVD directive is not applicable?
>
> The  Machine Directive also excludes these high voltage products.
>
>
>
> So, wondering which Directive to apply related tot he safety testing
> part.  (The General Safety Product Directive?)
>
> Any suggestions as to which safety standard to apply for such products?
>
>
>
> Any suggestions are highly appreciated.
>
>
>
> Thanks !
> -
> 
>
> 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:
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> --
> Independent Expert on CE marking
> EMC Consultant
> Electrical Safety Consultant
>
> -
> 
>
> 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>
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> All emc-pstc postings are archived and searchable on the web at:
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 650-253-1994

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Re: [PSES] CE marking of a high voltage output supply for laboratory / industrial environmental use

[Gert Gremmen]

Dear Bart,

As the input is within the LVD limit, the whole equipment is.

EN 61326-1 comes to mind for EMC

EN 61010-1 for electrical safety

The output is just a "circuit" (in terms of 61010) and clearance and 
creepage requirement (up to 60 kV) are given in Table 6 and 7


There are more requirements than just clearance and creepage.

Good luck in making your equipment safe.

Gert Gremmen


On 18-8-2022 21:43, bart.de.gee...@telenet.be wrote:


Dear experts,

A client is looking for regulatory guidance to CE certify a high 
voltage output supply  (with regular AC mains 230V/50Hz input).


The supply has an output voltage upto 25kV (upto 50kHz) output.   It 
concerns a supply to be used for plasma reactor applications.


As the output voltage is not inside the  voltage limits for the Low 
Voltage Directive, the LVD directive is not applicable?


The  Machine Directive also excludes these high voltage products.

So, wondering which Directive to apply related tot he safety testing 
part.  (The General Safety Product Directive?)


Any suggestions as to which safety standard to apply for such products?

Any suggestions are highly appreciated.

Thanks !

-


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--
Independent Expert on CE marking
EMC Consultant
Electrical Safety Consultant

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begin:vcard
fn:Gert Gremmen
n:Gremmen;Gert
adr:;;Lieu Dit Pirot;Chauffailles;;71170;France
email;internet:g.grem...@cetest.nl
tel;cell:+33 7 84507010
note;quoted-printable:Independent Expert on CE marking =
	=0D=0A=
	Harmonised Standards (HAS-) Consultant @ European Commission for RED, LVD=
	 and EMC=0D=0A=
	EMC Consultant=0D=0A=
	Electrical Safety Consultant=0D=0A=
	
x-mozilla-html:TRUE
version:2.1
end:vcard

[PSES] CE marking of a high voltage output supply for laboratory / industrial environmental use

[bart . de . geeter]

Dear experts,

 

A client is looking for regulatory guidance to CE certify a high voltage output 
supply  (with regular AC mains 230V/50Hz input).

The supply has an output voltage upto 25kV (upto 50kHz) output.   It concerns a 
supply to be used for plasma reactor applications.

 

As the output voltage is not inside the  voltage limits for the Low Voltage 
Directive, the LVD directive is not applicable?

The  Machine Directive also excludes these high voltage products.

 

So, wondering which Directive to apply related tot he safety testing part.  
(The General Safety Product Directive?)  

Any suggestions as to which safety standard to apply for such products?

 

Any suggestions are highly appreciated.

 

Thanks !


-

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 


All emc-pstc postings are archived and searchable on the web at:
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Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

[Philip Stevenson]

Dear Doug

Thanks Doug for your input. My company does something similar as mitigation 
against the tin whisker problem in that we specify the use of a leaded 
soldering process and “re-lead” safety critical lead-free components.

Regards

Philip Stevenson

Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows

From: Douglas E Powell<mailto:doug...@gmail.com>
Sent: 22 October 2021 19:47
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

There are other examples of exemptions.

My son works for a power conversion company in Colorado who deals with both the 
US Military and NASA. There have been instances where their contract 
specifically states you shall not use lead-free (RoHS) materials.  Apparently 
they are aware of the tin whisker problem and explicitly prohibit the use of 
such materials.

Have a great weekend,

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com<mailto:doug...@gmail.com>
http://www.linkedin.com/in/dougp01

On Fri, Oct 22, 2021 at 4:35 AM Matthew Wilson | GBE 
mailto:matthew.wil...@gbelectronics.com>> 
wrote:
It’s old now but this article, written by someone working for TUV SUD, was 
handy for me when needing to deal with the ‘military exempt argument’ a while 
ago.

https://www.newelectronics.co.uk/electronics-technology/the-military-ce-marking-conundrum/64803/

It agrees with your stance, which I personally also agree with, FWIW.

“They have informed us that there is a CE Marking Exemption for Military 
Equipment in France and Germany for these products”

Why not ask them for documentary proof or some such of the exemption?  They may 
well struggle!

Good luck.

Matthew Wilson,
GB Electronics (UK) Ltd.

[cid:image002.png@01D7C800.384FFB80][cid:17ca94f89f686d224ea1]
Disclaimer:​ This email and any files transmitted with it are confidential and 
intended solely for the use of the individual or entity to whom they are 
addressed. If you have received this email in error please delete it from your 
system, do not use or disclose the information in any way and notify the sender 
immediately. The contents of this message may contain personal views which are 
not the views of the company, unless specifically stated.
​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.
From: Philip Stevenson mailto:pw...@hotmail.co.uk>>
Sent: 21 October 2021 11:16
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] EU CE Marking Exemptions for Military Equipment Query

Dear All

I am contacting this forum for advice on whether there are any EU CE Marking 
Exemptions for Military Equipment in France and Germany?

My reason for asking is that the manufacturers of Military off the shelf 
equipment (MOTS) who are based in France and Germany that we incorporate into 
some of our Military CE marked products which we manufacture. They have 
informed us that there is a CE Marking Exemption for Military Equipment in 
France and Germany for these products. These products are not covered by 
Article 296 and therefore not specifically exempt CE Marking. This equipment 
also falls within the scope of the EMC Directive.

My view is that Military equipment not covered by Article 296 do not have a 
general exemption to CE marking EMC requirements and that exemptions for 
specific applications are contained within certain directives such as 
2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other directives 
such as EMC and Low Voltage Directives do not contain any exemption.

Is my assessment correct?

If you prefer please contact me directly at my personal Email address below and 
I will not post these replies online.

Regards

Philip Stevenson

Email: pw...@hotmail.co.uk<mailto:pw...@hotmail.co.uk>

-


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 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
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Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

[Philip Stevenson]

Dear Charlie

Many thanks for your reply. I agree with your assessment that no one has asked 
for the “CE evidence” before. I believe they think that this equipment is radio 
based and within the scope of RED which has a military exemption. But ignoring 
the fact that the EMC Directive is still applicable.



Regards

Philip Stevenson



Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows

From: Charlie Blackham<mailto:char...@sulisconsultants.com>
Sent: 22 October 2021 12:17
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

Philip

> They have informed us that there is a CE Marking Exemption for Military 
> Equipment in France and Germany for these products

I suspect what they mean is “our customers in France and Germany are not asking 
for evidence of CE compliance”

That’s perfectly fine – the customer has nothing to do with it as the 
obligation to comply with EMCD and LVD is on he manufacturer and they cannot be 
exempted by a customer.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Matthew Wilson | GBE 
Sent: 22 October 2021 11:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

It’s old now but this article, written by someone working for TUV SUD, was 
handy for me when needing to deal with the ‘military exempt argument’ a while 
ago.

https://www.newelectronics.co.uk/electronics-technology/the-military-ce-marking-conundrum/64803/

It agrees with your stance, which I personally also agree with, FWIW.

“They have informed us that there is a CE Marking Exemption for Military 
Equipment in France and Germany for these products”

Why not ask them for documentary proof or some such of the exemption?  They may 
well struggle!

Good luck.

Matthew Wilson,
GB Electronics (UK) Ltd.

[cid:image001.png@01D7C73E.196331F0]
Disclaimer:​ This email and any files transmitted with it are confidential and 
intended solely for the use of the individual or entity to whom they are 
addressed. If you have received this email in error please delete it from your 
system, do not use or disclose the information in any way and notify the sender 
immediately. The contents of this message may contain personal views which are 
not the views of the company, unless specifically stated.
​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.
From: Philip Stevenson mailto:pw...@hotmail.co.uk>>
Sent: 21 October 2021 11:16
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] EU CE Marking Exemptions for Military Equipment Query

Dear All

I am contacting this forum for advice on whether there are any EU CE Marking 
Exemptions for Military Equipment in France and Germany?

My reason for asking is that the manufacturers of Military off the shelf 
equipment (MOTS) who are based in France and Germany that we incorporate into 
some of our Military CE marked products which we manufacture. They have 
informed us that there is a CE Marking Exemption for Military Equipment in 
France and Germany for these products. These products are not covered by 
Article 296 and therefore not specifically exempt CE Marking. This equipment 
also falls within the scope of the EMC Directive.

My view is that Military equipment not covered by Article 296 do not have a 
general exemption to CE marking EMC requirements and that exemptions for 
specific applications are contained within certain directives such as 
2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other directives 
such as EMC and Low Voltage Directives do not contain any exemption.

Is my assessment correct?

If you prefer please contact me directly at my personal Email address below and 
I will not post these replies online.

Regards

Philip Stevenson

Email: pw...@hotmail.co.uk<mailto:pw...@hotmail.co.uk>

-


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 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
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Attachme

Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

[Philip Stevenson]

Dear Matthew

Many thanks for your reply and the article link. I remember reading this 
article before. Finally thanks for your agreement with my assessment.

Regards

Philip Stevenson


Sent from Mail<https://go.microsoft.com/fwlink/?LinkId=550986> for Windows

From: Matthew Wilson | GBE<mailto:matthew.wil...@gbelectronics.com>
Sent: 22 October 2021 11:34
To: Philip Stevenson<mailto:pw...@hotmail.co.uk>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] EU CE Marking Exemptions for Military Equipment Query

It’s old now but this article, written by someone working for TUV SUD, was 
handy for me when needing to deal with the ‘military exempt argument’ a while 
ago.

https://www.newelectronics.co.uk/electronics-technology/the-military-ce-marking-conundrum/64803/

It agrees with your stance, which I personally also agree with, FWIW.

“They have informed us that there is a CE Marking Exemption for Military 
Equipment in France and Germany for these products”

Why not ask them for documentary proof or some such of the exemption?  They may 
well struggle!

Good luck.

Matthew Wilson,
GB Electronics (UK) Ltd.

[cid:image002.png@01D7C7E5.B7DAB180][cid:image947110.png@B3C24FB2.1D3B2D3F]
Disclaimer:​ This email and any files transmitted with it are confidential and 
intended solely for the use of the individual or entity to whom they are 
addressed. If you have received this email in error please delete it from your 
system, do not use or disclose the information in any way and notify the sender 
immediately. The contents of this message may contain personal views which are 
not the views of the company, unless specifically stated.
​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.
From: Philip Stevenson 
Sent: 21 October 2021 11:16
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU CE Marking Exemptions for Military Equipment Query

Dear All

I am contacting this forum for advice on whether there are any EU CE Marking 
Exemptions for Military Equipment in France and Germany?

My reason for asking is that the manufacturers of Military off the shelf 
equipment (MOTS) who are based in France and Germany that we incorporate into 
some of our Military CE marked products which we manufacture. They have 
informed us that there is a CE Marking Exemption for Military Equipment in 
France and Germany for these products. These products are not covered by 
Article 296 and therefore not specifically exempt CE Marking. This equipment 
also falls within the scope of the EMC Directive.

My view is that Military equipment not covered by Article 296 do not have a 
general exemption to CE marking EMC requirements and that exemptions for 
specific applications are contained within certain directives such as 
2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other directives 
such as EMC and Low Voltage Directives do not contain any exemption.

Is my assessment correct?

If you prefer please contact me directly at my personal Email address below and 
I will not post these replies online.

Regards

Philip Stevenson

Email: pw...@hotmail.co.uk<mailto:pw...@hotmail.co.uk>

-


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 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/<https://eur02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fproduct-compliance.oc.ieee.org%2F&data=04%7C01%7Cmatthew.wilson%40gbelectronics.com%7Ca13968a157c04093dbc808d9947bc20f%7C0991060a48f54e72abaa7189692c6192%7C1%7C0%7C637704081525408366%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=6a0a1dt7gDKh4I35R3QCqrSQjmav8cTVG1rNskQ83Fo%3D&reserved=0>
 can be used for graphics (in well-used formats), large files, etc.

Website: 
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Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

[Douglas E Powell]

There are other examples of exemptions.

My son works for a power conversion company in Colorado who deals with both
the US Military and NASA. There have been instances where their contract
specifically states you shall not use lead-free (RoHS) materials.
Apparently they are aware of the tin whisker problem and explicitly
prohibit the use of such materials.

Have a great weekend,

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com
http://www.linkedin.com/in/dougp01

On Fri, Oct 22, 2021 at 4:35 AM Matthew Wilson | GBE <
matthew.wil...@gbelectronics.com> wrote:

> It’s old now but this article, written by someone working for TUV SUD, was
> handy for me when needing to deal with the ‘military exempt argument’ a
> while ago.
>
>
>
>
> https://www.newelectronics.co.uk/electronics-technology/the-military-ce-marking-conundrum/64803/
>
>
>
> It agrees with your stance, which I personally also agree with, FWIW.
>
>
>
> “They have informed us that there is a CE Marking Exemption for Military
> Equipment in France and Germany for these products”
>
>
>
> Why not ask them for documentary proof or some such of the exemption?
> They may well struggle!
>
>
>
> Good luck.
>
>
>
> Matthew Wilson,
>
> GB Electronics (UK) Ltd.
>
>
> Disclaimer:​ This email and any files transmitted with it are
> confidential and intended solely for the use of the individual or entity to
> whom they are addressed. If you have received this email in error please
> delete it from your system, do not use or disclose the information in any
> way and notify the sender immediately. The contents of this message may
> contain personal views which are not the views of the company, unless
> specifically stated.
> ​GB Electronics (UK) Ltd is a company registered in England and Wales
> under number 06210991.
> ​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea,
> West Sussex, BN12 4QY.
>
> *From:* Philip Stevenson 
> *Sent:* 21 October 2021 11:16
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] EU CE Marking Exemptions for Military Equipment Query
>
>
>
> Dear All
>
>
>
> I am contacting this forum for advice on whether there are any EU CE
> Marking Exemptions for Military Equipment in France and Germany?
>
>
>
> My reason for asking is that the manufacturers of Military off the shelf
> equipment (MOTS) who are based in France and Germany that we incorporate
> into some of our Military CE marked products which we manufacture. They
> have informed us that there is a CE Marking Exemption for Military
> Equipment in France and Germany for these products. These products are not
> covered by Article 296 and therefore not specifically exempt CE Marking.
> This equipment also falls within the scope of the EMC Directive.
>
>
>
> My view is that Military equipment not covered by Article 296 do not have
> a general exemption to CE marking EMC requirements and that exemptions for
> specific applications are contained within certain directives such as
> 2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other
> directives such as EMC and Low Voltage Directives do not contain any
> exemption.
>
>
>
> Is my assessment correct?
>
>
>
> If you prefer please contact me directly at my personal Email address
> below and I will not post these replies online.
>
>
>
> Regards
>
>
>
> Philip Stevenson
>
>
>
> Email: pw...@hotmail.co.uk
>
>
>
> -
> 
>
> 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
> <https://eur02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.ieee-pses.org%2Femc-pstc.html&data=04%7C01%7Cmatthew.wilson%40gbelectronics.com%7Ca13968a157c04093dbc808d9947bc20f%7C0991060a48f54e72abaa7189692c6192%7C1%7C0%7C637704081525408366%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=A8HbYGG993laHHBSPLjqva7w03aW58z3WJzSLNup5Ew%3D&reserved=0>
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/
> <https://eur02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fproduct-compliance.oc.ieee.org%2F&data=04%7C01%7Cmatthew.wilson%40gbelectronics.com%7Ca13968a157c04093dbc808d9947bc20f%7C0991060a48f54e72abaa7189692c6192%7C1%7C0%7C637704081525408366%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzI

Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

[Charlie Blackham]

Philip

> They have informed us that there is a CE Marking Exemption for Military 
> Equipment in France and Germany for these products

I suspect what they mean is “our customers in France and Germany are not asking 
for evidence of CE compliance”

That’s perfectly fine – the customer has nothing to do with it as the 
obligation to comply with EMCD and LVD is on he manufacturer and they cannot be 
exempted by a customer.

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Matthew Wilson | GBE 
Sent: 22 October 2021 11:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

It’s old now but this article, written by someone working for TUV SUD, was 
handy for me when needing to deal with the ‘military exempt argument’ a while 
ago.

https://www.newelectronics.co.uk/electronics-technology/the-military-ce-marking-conundrum/64803/

It agrees with your stance, which I personally also agree with, FWIW.

“They have informed us that there is a CE Marking Exemption for Military 
Equipment in France and Germany for these products”

Why not ask them for documentary proof or some such of the exemption?  They may 
well struggle!

Good luck.

Matthew Wilson,
GB Electronics (UK) Ltd.

[cid:image001.png@01D7C73E.196331F0]
Disclaimer:​ This email and any files transmitted with it are confidential and 
intended solely for the use of the individual or entity to whom they are 
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system, do not use or disclose the information in any way and notify the sender 
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not the views of the company, unless specifically stated.
​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.
From: Philip Stevenson mailto:pw...@hotmail.co.uk>>
Sent: 21 October 2021 11:16
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] EU CE Marking Exemptions for Military Equipment Query

Dear All

I am contacting this forum for advice on whether there are any EU CE Marking 
Exemptions for Military Equipment in France and Germany?

My reason for asking is that the manufacturers of Military off the shelf 
equipment (MOTS) who are based in France and Germany that we incorporate into 
some of our Military CE marked products which we manufacture. They have 
informed us that there is a CE Marking Exemption for Military Equipment in 
France and Germany for these products. These products are not covered by 
Article 296 and therefore not specifically exempt CE Marking. This equipment 
also falls within the scope of the EMC Directive.

My view is that Military equipment not covered by Article 296 do not have a 
general exemption to CE marking EMC requirements and that exemptions for 
specific applications are contained within certain directives such as 
2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other directives 
such as EMC and Low Voltage Directives do not contain any exemption.

Is my assessment correct?

If you prefer please contact me directly at my personal Email address below and 
I will not post these replies online.

Regards

Philip Stevenson

Email: pw...@hotmail.co.uk<mailto:pw...@hotmail.co.uk>

-


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 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/<https://eur02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fproduct-compliance.oc.ieee.org%2F&data=04%7C01%7Cmatthew.wilson%40gbelectronics.com%7Ca13968a157c04093dbc808d9947bc20f%7C0991060a48f54e72abaa7189692c6192%7C1%7C0%7C637704081525408366%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=6a0a1dt7gDKh4I35R3QCqrSQjmav8cTVG1rNskQ83Fo%3D&reserved=0>
 can be used for graphics (in well-used formats), large files, etc.

Website: 
http://www.ieee-pses.org/<https://eur02.safelin

Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

[Matthew Wilson | GBE]

It's old now but this article, written by someone working for TUV SUD, was 
handy for me when needing to deal with the 'military exempt argument' a while 
ago.

https://www.newelectronics.co.uk/electronics-technology/the-military-ce-marking-conundrum/64803/

It agrees with your stance, which I personally also agree with, FWIW.

"They have informed us that there is a CE Marking Exemption for Military 
Equipment in France and Germany for these products"

Why not ask them for documentary proof or some such of the exemption?  They may 
well struggle!

Good luck.

Matthew Wilson,
GB Electronics (UK) Ltd.


Matthew Wilson
Technical Director
GB Electronics (UK) Ltd
matthew.wil...@gbelectronics.com
https://gbelectronics.uk
+44 (0)1903 244 500
Ascot House//Mulberry Close//Woods Way
Goring-by-Sea//West Sussex//BN12 4QY//UK

Disclaimer: This email and any files transmitted with it are confidential and 
intended solely for the use of the individual or entity to whom they are 
addressed. If you have received this email in error please delete it from your 
system, do not use or disclose the information in any way and notify the sender 
immediately. The contents of this message may contain personal views which are 
not the views of the company, unless specifically stated.
​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.
From: Philip Stevenson 
Sent: 21 October 2021 11:16
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU CE Marking Exemptions for Military Equipment Query

Dear All

I am contacting this forum for advice on whether there are any EU CE Marking 
Exemptions for Military Equipment in France and Germany?

My reason for asking is that the manufacturers of Military off the shelf 
equipment (MOTS) who are based in France and Germany that we incorporate into 
some of our Military CE marked products which we manufacture. They have 
informed us that there is a CE Marking Exemption for Military Equipment in 
France and Germany for these products. These products are not covered by 
Article 296 and therefore not specifically exempt CE Marking. This equipment 
also falls within the scope of the EMC Directive.

My view is that Military equipment not covered by Article 296 do not have a 
general exemption to CE marking EMC requirements and that exemptions for 
specific applications are contained within certain directives such as 
2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other directives 
such as EMC and Low Voltage Directives do not contain any exemption.

Is my assessment correct?

If you prefer please contact me directly at my personal Email address below and 
I will not post these replies online.

Regards

Philip Stevenson

Email: pw...@hotmail.co.uk<mailto:pw...@hotmail.co.uk>

-


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 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
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Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/<https://eur02.safelinks.protection.outlook.com/?url=http%3A%2F%2Fproduct-compliance.oc.ieee.org%2F&data=04%7C01%7Cmatthew.wilson%40gbelectronics.com%7Ca13968a157c04093dbc808d9947bc20f%7C0991060a48f54e72abaa7189692c6192%7C1%7C0%7C637704081525408366%7CUnknown%7CTWFpbGZsb3d8eyJWIjoiMC4wLjAwMDAiLCJQIjoiV2luMzIiLCJBTiI6Ik1haWwiLCJXVCI6Mn0%3D%7C1000&sdata=6a0a1dt7gDKh4I35R3QCqrSQjmav8cTVG1rNskQ83Fo%3D&reserved=0>
 can be used for graphics (in well-used formats), large files, etc.

Website: 
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[PSES] EU CE Marking Exemptions for Military Equipment Query

[Philip Stevenson]

Dear All

I am contacting this forum for advice on whether there are any EU CE Marking 
Exemptions for Military Equipment in France and Germany?

My reason for asking is that the manufacturers of Military off the shelf 
equipment (MOTS) who are based in France and Germany that we incorporate into 
some of our Military CE marked products which we manufacture. They have 
informed us that there is a CE Marking Exemption for Military Equipment in 
France and Germany for these products. These products are not covered by 
Article 296 and therefore not specifically exempt CE Marking. This equipment 
also falls within the scope of the EMC Directive.

My view is that Military equipment not covered by Article 296 do not have a 
general exemption to CE marking EMC requirements and that exemptions for 
specific applications are contained within certain directives such as 
2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other directives 
such as EMC and Low Voltage Directives do not contain any exemption.

Is my assessment correct?

If you prefer please contact me directly at my personal Email address below and 
I will not post these replies online.

Regards

Philip Stevenson

Email: pw...@hotmail.co.uk<mailto:pw...@hotmail.co.uk>


-

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 


All emc-pstc postings are archived and searchable on the web at:
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Website:  http://www.ieee-pses.org/
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For help, send mail to the list administrators:
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[PSES] CE marking for Automatic Voltage regulator

[Youngsik Kim]

Hi all
The products is a voltage stabilizer for power plants.
What EMC standard apply for CE certification?

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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 


All emc-pstc postings are archived and searchable on the web at:
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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/
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For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

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Jim Bacher:  
David Heald: 

Re: [PSES] AW: [PSES] ErP Directive requiring CE Marking

[Scott Xe]

Dear Bernd,



Many thanks for your clear pointer!  I looked into the delegated
regulations incorrectly.



Best regards,



Scott



On Tue, 29 Sep 2020 at 14:24, Dürrer Bernd  wrote:

> Hi Scott,
>
> Article 5 of ErP Directive 2009/125/EC requires CE marking (
> https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32009L0125&from=EN#d1e903-10-1
> ).
>
> Kind regards,
>
> Bernd
> --
> *Von:* Scott Xe 
> *Gesendet:* Dienstag, 29. September 2020 07:53
> *An:* EMC-PSTC@LISTSERV.IEEE.ORG 
> *Betreff:* [PSES] ErP Directive requiring CE Marking
>
> I have learnt that ErP Directive requires CE Marking as compliance with
> the Directive.  I could not find this requirement in the Directive like
> others such as LVD, EMC, etc.  Can someone advise if I got incorrect info
> or where to document this requirement.
>
> Thanks and regards,
>
> Scott
>
>
> -
> 
>
> 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>
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> All emc-pstc postings are archived and searchable on the web at:
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> Attachments are not permitted but the IEEE PSES Online Communities site at
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[PSES] AW: [PSES] ErP Directive requiring CE Marking

[Dürrer Bernd]

Hi Scott,

Article 5 of ErP Directive 2009/125/EC requires CE marking 
(https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32009L0125&from=EN#d1e903-10-1).

Kind regards,

Bernd

Von: Scott Xe 
Gesendet: Dienstag, 29. September 2020 07:53
An: EMC-PSTC@LISTSERV.IEEE.ORG 
Betreff: [PSES] ErP Directive requiring CE Marking

I have learnt that ErP Directive requires CE Marking as compliance with the 
Directive.  I could not find this requirement in the Directive like others such 
as LVD, EMC, etc.  Can someone advise if I got incorrect info or where to 
document this requirement.

Thanks and regards,

Scott


-


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 
mailto:emc-p...@ieee.org>>

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Attachments are not permitted but the IEEE PSES Online Communities site at 
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[PSES] ErP Directive requiring CE Marking

[Scott Xe]

I have learnt that ErP Directive requires CE Marking as compliance with the
Directive.  I could not find this requirement in the Directive like others
such as LVD, EMC, etc.  Can someone advise if I got incorrect info or where
to document this requirement.

Thanks and regards,

Scott

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Re: [PSES] CE marking quality manufacturing requirements

[Regan Arndt]

Perfect. Exactly what I was looking for. I guess I fell asleep again
reading this directive before I reached this clauselol

Thanks everyone for replying. Very good feedback/input from all of you.

Cheers!
Regan

On Wed, Jan 15, 2020 at 12:04 AM Charlie Blackham <
char...@sulisconsultants.com> wrote:

> Regan
>
>
>
> CE marking of course applies to all products manufactured on an ongoing
> basis, and the requirement you refer to is in the Directives
>
>
>
> Quoting from the LVD as an example (Annex III, Module A)
>
>
>
> *3. Manufacturing *
>
> The manufacturer shall take all measures necessary so that the
> manufacturing process and its monitoring ensure compliance of the
> manufactured electrical equipment with the technical documentation referred
> to in point 2 and with the requirements of this Directive that apply to it.
>
>
>
> To which the LVD guide adds
>
>
>
> The manufacturer has to ensure, that the manufacturing process permanently
> leads to compliant electrical equipment. One means to achieve this could be
> a supervised QM-System.
>
>
>
> You as the manufacturer need to decide what is prudent, for example:
>
>- NRTL audits generally concern themselves with safety critical
>components – which assists with safety, but doesn’t cover EMC
>- Alternative components may well meet all necessary safety standards
>and have equivalent electrical performance for EMC compliance, but what
>about RoHS?
>
>
>
> The manufacturing quote is similar in the EMC Directive: Annex II, Module
> A, section 4
>
>
>
> Regards
>
> Charlie
>
>
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: **https://sulisconsultants.com/* <https://sulisconsultants.com/>
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Regan Arndt 
> *Sent:* 15 January 2020 00:23
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] CE marking quality manufacturing requirements
>
>
>
> Greetings team members,
>
>
>
> I seem to recall somewhere either in a directive or the blue guide where
> it states (or implies) that part of the CE marking requirements entails
> that the manufacture must have a product quality system/production
> control..and this is where I need clarification: Does it imply that
> the quality system entail that *one must conduct an internal product
> safety audit (or the like) *to reassure themselves that there has been no
> deviation to the product design/documentation that originally supported
> their CE marking testing/declaration.
>
>
>
> *Note that I am not referring to the module conformity assessment protocol
> which involves a notified body, but just the simple self-declaration
> scheme. My search always seems to point me towards the notified body
> modules section, where they say that the 3rd party conducts factory audits,
> etc. but there is nothing that states this for the non-notified body
> involvement.*
>
>
>
> If there is no such production verification audit required, would it not
> be prudent to do this? ….just like the NRTL program? My experience
> indicates that most manufacturers do not conduct internal product audits
> relating to CE marking unless they forced to because they also have a
> certification mark on the product (i.e. NRTL program or other certification
> scheme via a Notified Body).
>
>
>
> Thanks for any help you can provide me with an official exact
> clause/text/excerpt from the OJ, guides and/or directives.
>
>
>
> Regan Arndt
>
> -
> 
>
> 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) <http://www.ieee-pses.org/list.html>
> List rules: http://www.ieee-pses.org/listrules.html
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> Scott Douglas 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>

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This message is from the IEEE Product Safety Engineering Society emc-pstc

Re: [PSES] CE marking quality manufacturing requirements

[Gert Gremmen]

These are phrases with a high degree of conformal viability, but most 
companies using this Route A  (SME's) do not have the slightest idea how 
to start "a quality system that entails"


In practice this can be done by :

 * Have the product be approved according to one or more harmonised
   standards (seek advice on choice)
 * Document all (CE) required modifications after compliance is
   achieved , add them to the production files, and complete it with
   the test report to obtain a "technical construction file"
 * Create the EU Declaration of Conformity (acc. to the above
   harmonised standards)
 * Freeze the product manufacturing status
 * Implement a control scheme on _purchase_ and_production_ with a
   focus on earlier failures and _improvements_ and _invisible safety
   "measures"_
 o /_Purchase_ /as components may change without notice, possibly
   driven by costs, but also by performance increase (/BTW never
   rely on unspecified /undocumented component properties -even if
   it passed tests- as these may change without notice)/
 o _/Improvements/_ as detected during the approval process are by
   definition difficult to implement for a variety of reasons (!!)
 o _/Invisible safety measures/_ shall be explicitly checked upon
   (such as insulation rings and washers)
 o _Unnotable on fail safety measures _shall be explicitly checked
   upon (such as varistors, fuse values, double/paralled safety
   features)
 * Carry out a basic safety test for electrical safety on insulation
   acc to a suitable standard
 * Define an equivalent test method that is able to detect EMC failures
   (based on approval test results) (even a properly tuned SW/VHF 
   receiver can detect sudden changes in emissions)
 * Keep a test log per serialized equipment (preferred) , batch or
   other logical production unit
 * Mark the product for inspection and verified.

This will more or less cover the most failures in production.

Please add your 2 cents


Just my few cents

Gert

On 15-1-2020 11:37, Matthew Wilson | GBE wrote:


Look at 
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:218:0082:0128:en:PDF 



This is, “DECISION No 768/2008/EC OF THE EUROPEAN PARLIAMENT AND OF 
THE COUNCIL of 9 July 2008 on a common framework for the marketing of 
products”


See Annex II Module A1 and Module A2 in that document.

The choice is down to the manufacturer how to achieve this requirement 
but yes I think this implies, “that the quality system entail that one 
must conduct an internal product safety audit (or the like) to 
reassure themselves that there has been no deviation to the product 
design/documentation that originally supported their CE marking 
testing/declaration.”


HTH

Matthew Wilson,

Technical Director,

GB Electronics (UK) Ltd.

Disclaimer:​This email and any files transmitted with it are 
confidential and intended solely for the use of the individual or 
entity to whom they are addressed. If you have received this email in 
error please delete it from your system, do not use or disclose the 
information in any way and notify the sender immediately. The contents 
of this message may contain personal views which are not the views of 
the company, unless specifically stated.


​GB Electronics (UK) Ltd is a company registered in England and Wales 
under number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By 
Sea, West Sussex, BN12 4QY.


*From:*Regan Arndt 
*Sent:* 15 January 2020 00:23
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] CE marking quality manufacturing requirements

Greetings team members,

I seem to recall somewhere either in a directive or the blue guide 
where it states (or implies) that part of the CE marking requirements 
entails that the manufacture must have a product quality 
system/production control..and this is where I need 
clarification: Does it imply that the quality system entail that *_one 
must conduct an internal product safety audit (or the like) _*to 
reassure themselves that there has been no deviation to the product 
design/documentation that originally supported their CE marking 
testing/declaration.


_Note that I am not referring to the module conformity assessment 
protocol which involves a notified body, but just the simple 
self-declaration scheme. My search always seems to point me towards 
the notified body modules section, where they say that the 3rd party 
conducts factory audits, etc. but there is nothing that states this 
for the non-notified body involvement._


If there is no such production verification audit required, would it 
not be prudent to do this? ….just like the NRTL program? My experience 
indicates that most manufacturers do not conduct internal product 
audits relating to CE marking unless they forced to because they also 
have a certification mark on the product (i.e. NRTL program or other 
certification scheme

Re: [PSES] CE marking quality manufacturing requirements

[Matthew Wilson | GBE]

Look at 
https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2008:218:0082:0128:en:PDF
This is, “DECISION No 768/2008/EC OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL 
of 9 July 2008 on a common framework for the marketing of products”

See Annex II Module A1 and Module A2 in that document.

The choice is down to the manufacturer how to achieve this requirement but yes 
I think this implies, “that the quality system entail that one must conduct an 
internal product safety audit (or the like) to reassure themselves that there 
has been no deviation to the product design/documentation that originally 
supported their CE marking testing/declaration.”

HTH

Matthew Wilson,
Technical Director,
GB Electronics (UK) Ltd.


Matthew Wilson
Technical Director
GB Electronics (UK) Ltd
matthew.wil...@gbelectronics.com
https://gbelectronics.uk
+44 (0)1903 244 500
Ascot House//Mulberry Close//Woods Way
Goring-by-Sea//West Sussex//BN12 4QY//UK

Disclaimer: This email and any files transmitted with it are confidential and 
intended solely for the use of the individual or entity to whom they are 
addressed. If you have received this email in error please delete it from your 
system, do not use or disclose the information in any way and notify the sender 
immediately. The contents of this message may contain personal views which are 
not the views of the company, unless specifically stated.
​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.
From: Regan Arndt 
Sent: 15 January 2020 00:23
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE marking quality manufacturing requirements

Greetings team members,

I seem to recall somewhere either in a directive or the blue guide where it 
states (or implies) that part of the CE marking requirements entails that the 
manufacture must have a product quality system/production control..and 
this is where I need clarification: Does it imply that the quality system 
entail that one must conduct an internal product safety audit (or the like) to 
reassure themselves that there has been no deviation to the product 
design/documentation that originally supported their CE marking 
testing/declaration.

Note that I am not referring to the module conformity assessment protocol which 
involves a notified body, but just the simple self-declaration scheme. My 
search always seems to point me towards the notified body modules section, 
where they say that the 3rd party conducts factory audits, etc. but there is 
nothing that states this for the non-notified body involvement.

If there is no such production verification audit required, would it not be 
prudent to do this? ….just like the NRTL program? My experience indicates that 
most manufacturers do not conduct internal product audits relating to CE 
marking unless they forced to because they also have a certification mark on 
the product (i.e. NRTL program or other certification scheme via a Notified 
Body).

Thanks for any help you can provide me with an official exact 
clause/text/excerpt from the OJ, guides and/or directives.

Regan Arndt
-


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discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

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Re: [PSES] CE marking quality manufacturing requirements

[Rodriguez, Daniel (ESP)]

Good morningRegan
I agree with you that most manufacturers don’t conduct audits
In my opinion I recommend the following actions

  1.  Implement safety test in the production. For example Annex F of  EN 
61010-1:2010 indicate some routine test
  2.  Spot check. Select a sample of a batch and perform a representative test 
(for example Radiated Emissions for EMC)
But at the end is manufacturer responsibility to decide what level of test to 
do.

I hope that it helps. Let me know if you have additional questions.

Kind Regards / Saludos cordiales / Mit freundlichen Grüßen
Daniel Rodríguez


From: Charlie Blackham 
Sent: Wednesday, 15 January 2020 09:05
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking quality manufacturing requirements

Caution: This email originated from outside of the organization. DO NOT CLICK 
on links or open attachments unless you recognize the sender and know the 
content is safe.


Regan

CE marking of course applies to all products manufactured on an ongoing basis, 
and the requirement you refer to is in the Directives

Quoting from the LVD as an example (Annex III, Module A)


3. Manufacturing
The manufacturer shall take all measures necessary so that the manufacturing 
process and its monitoring ensure compliance of the manufactured electrical 
equipment with the technical documentation referred to in point 2 and with the 
requirements of this Directive that apply to it.

To which the LVD guide adds

The manufacturer has to ensure, that the manufacturing process permanently 
leads to compliant electrical equipment. One means to achieve this could be a 
supervised QM-System.

You as the manufacturer need to decide what is prudent, for example:

  *   NRTL audits generally concern themselves with safety critical components 
– which assists with safety, but doesn’t cover EMC
  *   Alternative components may well meet all necessary safety standards and 
have equivalent electrical performance for EMC compliance, but what about RoHS?

The manufacturing quote is similar in the EMC Directive: Annex II, Module A, 
section 4

Regards
Charlie


Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
https://sulisconsultants.com/<https://urldefense.com/v3/__https:/sulisconsultants.com/__;!!Nkc5UzxO!_46FSYSwQrWeuNlnFnjaHoK6jP6qpzr4cUnq_2phMVcZRt2dpLlkd2NSpliDlbCH$>
Registered in England and Wales, number 05466247

From: Regan Arndt mailto:reganar...@gmail.com>>
Sent: 15 January 2020 00:23
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] CE marking quality manufacturing requirements

Greetings team members,

I seem to recall somewhere either in a directive or the blue guide where it 
states (or implies) that part of the CE marking requirements entails that the 
manufacture must have a product quality system/production control..and 
this is where I need clarification: Does it imply that the quality system 
entail that one must conduct an internal product safety audit (or the like) to 
reassure themselves that there has been no deviation to the product 
design/documentation that originally supported their CE marking 
testing/declaration.

Note that I am not referring to the module conformity assessment protocol which 
involves a notified body, but just the simple self-declaration scheme. My 
search always seems to point me towards the notified body modules section, 
where they say that the 3rd party conducts factory audits, etc. but there is 
nothing that states this for the non-notified body involvement.

If there is no such production verification audit required, would it not be 
prudent to do this? ….just like the NRTL program? My experience indicates that 
most manufacturers do not conduct internal product audits relating to CE 
marking unless they forced to because they also have a certification mark on 
the product (i.e. NRTL program or other certification scheme via a Notified 
Body).

Thanks for any help you can provide me with an official exact 
clause/text/excerpt from the OJ, guides and/or directives.

Regan Arndt
-


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 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
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 can be used for graphics (in well-used formats), large files, etc.

Website: 
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Re: [PSES] CE marking quality manufacturing requirements

[Charlie Blackham]

Regan

CE marking of course applies to all products manufactured on an ongoing basis, 
and the requirement you refer to is in the Directives

Quoting from the LVD as an example (Annex III, Module A)


3. Manufacturing
The manufacturer shall take all measures necessary so that the manufacturing 
process and its monitoring ensure compliance of the manufactured electrical 
equipment with the technical documentation referred to in point 2 and with the 
requirements of this Directive that apply to it.

To which the LVD guide adds

The manufacturer has to ensure, that the manufacturing process permanently 
leads to compliant electrical equipment. One means to achieve this could be a 
supervised QM-System.

You as the manufacturer need to decide what is prudent, for example:

  *   NRTL audits generally concern themselves with safety critical components 
– which assists with safety, but doesn’t cover EMC
  *   Alternative components may well meet all necessary safety standards and 
have equivalent electrical performance for EMC compliance, but what about RoHS?

The manufacturing quote is similar in the EMC Directive: Annex II, Module A, 
section 4

Regards
Charlie


Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Regan Arndt 
Sent: 15 January 2020 00:23
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE marking quality manufacturing requirements

Greetings team members,

I seem to recall somewhere either in a directive or the blue guide where it 
states (or implies) that part of the CE marking requirements entails that the 
manufacture must have a product quality system/production control..and 
this is where I need clarification: Does it imply that the quality system 
entail that one must conduct an internal product safety audit (or the like) to 
reassure themselves that there has been no deviation to the product 
design/documentation that originally supported their CE marking 
testing/declaration.

Note that I am not referring to the module conformity assessment protocol which 
involves a notified body, but just the simple self-declaration scheme. My 
search always seems to point me towards the notified body modules section, 
where they say that the 3rd party conducts factory audits, etc. but there is 
nothing that states this for the non-notified body involvement.

If there is no such production verification audit required, would it not be 
prudent to do this? ….just like the NRTL program? My experience indicates that 
most manufacturers do not conduct internal product audits relating to CE 
marking unless they forced to because they also have a certification mark on 
the product (i.e. NRTL program or other certification scheme via a Notified 
Body).

Thanks for any help you can provide me with an official exact 
clause/text/excerpt from the OJ, guides and/or directives.

Regan Arndt
-


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[PSES] CE marking quality manufacturing requirements

[Regan Arndt]

Greetings team members,



I seem to recall somewhere either in a directive or the blue guide where it
states (or implies) that part of the CE marking requirements entails that
the manufacture must have a product quality system/production
control..and this is where I need clarification: Does it imply that
the quality system entail that *one must conduct an internal product safety
audit (or the like) *to reassure themselves that there has been no
deviation to the product design/documentation that originally supported
their CE marking testing/declaration.



*Note that I am not referring to the module conformity assessment protocol
which involves a notified body, but just the simple self-declaration
scheme. My search always seems to point me towards the notified body
modules section, where they say that the 3rd party conducts factory audits,
etc. but there is nothing that states this for the non-notified body
involvement.*



If there is no such production verification audit required, would it not be
prudent to do this? ….just like the NRTL program? My experience indicates
that most manufacturers do not conduct internal product audits relating to
CE marking unless they forced to because they also have a certification
mark on the product (i.e. NRTL program or other certification scheme via a
Notified Body).


Thanks for any help you can provide me with an official exact
clause/text/excerpt from the OJ, guides and/or directives.


Regan Arndt

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[PSES] SV: [PSES] ETSI standard for device with LTE (CE-marking RED)

[Amund Westin]

Great Michael,

 

I'll check out these standards.

 

BR

Amund

 

 

 

Fra: micha...@acbcert.com 
Sendt: 11. oktober 2019 08:19
Til: EMC-PSTC@LISTSERV.IEEE.ORG
Emne: Re: [PSES] ETSI standard for device with LTE (CE-marking RED)

 

Hi Amund,

 

You should look at EN 301 908-1 and EN 301 908-13.

 

Also, EN 301 489-52 for the LTE (and EN 301 489-17 for the BLE)

 

Thanks,

 

Michael.

 

 

From: Amund Westin mailto:am...@westin-emission.no> > 
Sent: 11 October 2019 06:27
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] ETSI standard for device with LTE (CE-marking RED)

 

A wireless sensor contains BLE and LTE chips.

For BLE, the standard ETSI EN 300 328 applies. But which standard should we
dig into because of the LTE?

 

 

BR

Amund

 

 

 

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Re: [PSES] ETSI standard for device with LTE (CE-marking RED)

[michaeld]

Hi Amund,

 

You should look at EN 301 908-1 and EN 301 908-13.

 

Also, EN 301 489-52 for the LTE (and EN 301 489-17 for the BLE)

 

Thanks,

 

Michael.

 

 

From: Amund Westin  
Sent: 11 October 2019 06:27
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] ETSI standard for device with LTE (CE-marking RED)

 

A wireless sensor contains BLE and LTE chips.

For BLE, the standard ETSI EN 300 328 applies. But which standard should we
dig into because of the LTE?

 

 

BR

Amund

 

 

 

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[PSES] ETSI standard for device with LTE (CE-marking RED)

[Amund Westin]

A wireless sensor contains BLE and LTE chips.

For BLE, the standard ETSI EN 300 328 applies. But which standard should we
dig into because of the LTE?

 

 

BR

Amund

 

 

 


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Re: [PSES] CE Marking and DoC for Multi Device Product

[Steve Brody]

IMO, part of the answer is how it is being sold.  If the product is known and 
sold as Model ABC, then it should be tested as a system for compliance to the 
applicable directives and standards and a DoC would be written for Model ABC 
and it would indicate the various 'components' that comprise Model ABC.  If we 
assume LVD and EMC then it would be tested as a system for compliance in a 
typical user configuration (we won't go down that path for now).


The TCF would have critical components list, basically the various 'components' 
that make up Model ABC and if they all have their own individual approvals, 
your done.  If, however, they do not have individual approvals you may need to 
describe them in mode detail in the TCF.


When additional 'components' are added, again assuming they have their own 
approvals you can add them to the DoC and the TCF.  If you decide to not do any 
additional testing then write an Engineering Justification as to why no 
additional  tests were done.  Or you can retest the original configuration with 
the additional 'components'.


My two cents worth.

> On August 12, 2019 at 2:31 PM 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
> -
> 
> 
> 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 
> mailto:emc-p...@ieee.org >
> 
> All emc-pstc postings are archived and searchable on the web at: 
> http://www.ieee-pses.org/emc-pstc.html
> 
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> at http://product-compliance.oc.ieee.org/ can be used for graphics (in 
> well-used formats), large files, etc.
> 
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Re: [PSES] CE Marking and DoC for Multi Device Product

[lauren . crane]

Regarding upgrade, it might be feasible to look at it this way, depending on 
the fine point details.

If the customer buys your upgrade parts in a B2B transaction (i.e. they 
essentially hire you to provide parts that will upgrade equipment they already 
own). Then the upgrade hardware is just components the customer is purchasing 
to expanding the functionality of a product they already own. Components 
intended for further incorporation in to a final product tend not to be 
directly in scope of many/most/all CE marking directives. The Customer, then, 
is on the hook for re-assessing their new product to applicable directives, and 
creating a new DoC. You, as a helpful supplier, can anticipate their needs and 
do much of the work for them.

If you are marketing an upgrade kit that any J.Q. Public can purchase as an 
"expansion option" for their product, the situation is different. Then the item 
is more of an "accessory" an probably has to be CE marked etc.. on its own.

Regards,
Lauren Crane
Tokyo Electron
From: John Woodgate 
Sent: Monday, August 12, 2019 2:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking and DoC for Multi Device Product


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<http://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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Re: [PSES] CE Marking and DoC for Multi Device Product

[John Woodgate]

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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[PSES] CE Marking and DoC for Multi Device Product

[Brian Kunde]

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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Re: [PSES] CE marking - mixture of responsibilities

[Lauren Crane]

James,

Also review current version of directives redone for the NLF (which currently 
has not touched the Machinery Directive), they all take the same approach in 
putting direct obligations on importers for issues the oem has not covered.

e.g., in EMCD






Article 9

Obligations of importers

1. Importers shall place only compliant apparatus on the market.

2. Before placing apparatus on the market importers shall ensure that the 
appropriate conformity assessment procedure referred to in Article 14 has been 
carried out by the manufacturer. They shall ensure that the manufacturer has 
drawn up the technical documentation, that the apparatus bears the CE marking 
and is accompanied by the required documents, and that the manufacturer has 
complied with the requirements set out in Article 7(5) and (6).
Where an importer considers or has reason to believe that apparatus is not in 
conformity with the essential requirements set out in Annex I, he shall not 
place the apparatus on the market until it has been brought into conformity. 
Furthermore, where the apparatus presents a risk, the importer shall inform the 
manufacturer and the market surveillance authorities to that effect.

…etc


-Lauren Crane

From: Scott Xe 
Sent: Tuesday, September 04, 2018 5:21 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

Hi James,

It is quite normal attitude for an oem or odm manufacturer.  They have over 
hundred buyers to keep their business alive and lack of resource to meet all 
standards of their buyers.  In order to meet your requirements, you have to 
actively educate them for what they have to supply in order to fulfillment of 
business contract.

In your 2nd para, for the product design, Yes.  In terms of production units, 
you have to verify by yourselves or hire a 3rd party body upon your behalf to 
verify if they have a good quality assurance system to maintain the production 
units within the tolerance of approved sample.  If you act as a retailer only, 
the product under their brand and their contact, you may have limited 
responsibilities, otherwise, you actually act as a manufacturer in EU.  For 
example, if your product is picked up by the market surveillance for validation 
of compliance with applicable regulations, do they contact your supplier or you?

Hope it is useful to your consideration!

Scott

On Thu, 30 Aug 2018 at 15:55, James Pawson (U3C) 
mailto:ja...@unit3compliance.co.uk>> wrote:
Hello all,

I’m working with a company who are importing some IT products from China to the 
EU. The Chinese manufacturer is taking a very much “hands off” approach to 
approvals, expecting the importer to draw up the DoC and perform much of the 
testing. However access to the parts of the Technical File that detail product 
construction are being held by the manufacturer and getting access to these is 
not straightforward.

My question is: provided that all the documentation boxes are ticked and the 
product has been sufficiently assessed, can one reasonably take on 
responsibilities for other actors in the supply chain in this manner?

I’m undecided if this is acceptable. My feeling is that whilst it is not to the 
letter of the law, it is to the spirit and would be acceptable depending on the 
importers tolerance to risk. However the letter of the directives is explicit 
in determining responsibilities e.g. that the manufacturer shall draw up the 
DoC.

I would be interested to hear your thoughts on the matter.

Thanks and all the best
James
-


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All emc-pstc postings are archived and searchab

Re: [PSES] CE marking - mixture of responsibilities

[Scott Xe]

Hi James,

It is quite normal attitude for an oem or odm manufacturer.  They have over
hundred buyers to keep their business alive and lack of resource to meet
all standards of their buyers.  In order to meet your requirements, you
have to actively educate them for what they have to supply in order to
fulfillment of business contract.

In your 2nd para, for the product design, Yes.  In terms of production
units, you have to verify by yourselves or hire a 3rd party body upon your
behalf to verify if they have a good quality assurance system to maintain
the production units within the tolerance of approved sample.  If you act
as a retailer only, the product under their brand and their contact, you
may have limited responsibilities, otherwise, you actually act as a
manufacturer in EU.  For example, if your product is picked up by the
market surveillance for validation of compliance with applicable
regulations, do they contact your supplier or you?

Hope it is useful to your consideration!

Scott

On Thu, 30 Aug 2018 at 15:55, James Pawson (U3C) <
ja...@unit3compliance.co.uk> wrote:

> Hello all,
>
>
>
> I’m working with a company who are importing some IT products from China
> to the EU. The Chinese manufacturer is taking a very much “hands off”
> approach to approvals, expecting the importer to draw up the DoC and
> perform much of the testing. However access to the parts of the Technical
> File that detail product construction are being held by the manufacturer
> and getting access to these is not straightforward.
>
>
>
> My question is: provided that all the documentation boxes are ticked and
> the product has been sufficiently assessed, can one reasonably take on
> responsibilities for other actors in the supply chain in this manner?
>
>
>
> I’m undecided if this is acceptable. My feeling is that whilst it is not
> to the letter of the law, it is to the spirit and would be acceptable
> depending on the importers tolerance to risk. However the letter of the
> directives is explicit in determining responsibilities e.g. that the
> manufacturer shall draw up the DoC.
>
>
>
> I would be interested to hear your thoughts on the matter.
>
>
>
> Thanks and all the best
>
> James
> -
> 
>
> 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 
> Mike Cantwell 
>
> For policy questions, send mail to:
> Jim Bacher 
> David Heald 
>

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Re: [PSES] CE marking - mixture of responsibilities

[Peter E Perkins]

 Dave,My experience is that products which are certified to worldwide 
harmonized standards - eg 60950 or 61010 - are evaluated for the full voltage 
and frequency as stated on the product nameplate and reported in both the NRTL 
cert report as well as the CB report.  If you are not asking for both reports 
you are not taking full advantage of the evaluation available.   Are you using 
a standard that is harmonized worldwide? are you requesting full certification 
to the standard as part of your NRTL evaluation project?  



I agree (and did say so earlier) that this strategy does not cover 
everything but will provide regular factory construction inspections to 
maintain the safety features of the design as certified  As your mother would 
say: half a loaf is better than none.  



:>)br,Pete
p.perk...@ieee.org

 

 

-Original Message-
From: Nyffenegger, Dave 
To: EMC-PSTC 
Sent: Thu, Aug 30, 2018 12:24 pm
Subject: Re: [PSES] CE marking - mixture of responsibilities



Not true in my experience.  The same lab may do certification reports for EU 
declarations in addition to NRTL certification/report.  The NRTL listing report 
is specific to US and/or Canadian standards.  We put a 50Hz input rating on the 
nameplate but that’s never been included in the NRTL report.  The NRTL factory 
inspectors only inspect to the NRTL listing report.  And as John said there is 
much more to EU i.e. EMC, RoHS, WEEE, then what NRTL covers.
 
-Dave
 

From: Richard Nute [mailto:ri...@ieee.org]
Sent: Thursday, August 30, 2018 2:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 
 
A NRTL tests to ALL the equipment ratings even if they include EU ratings.
Rich
 

From: John Woodgate 
Sent: Thursday, August 30, 2018 10:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 
That's a bit dodgy, Pete. The EU product must be for 230 V mains, so the NRTL 
won't cover safety test with 230 V 50 Hz input. There may be issues with 
different EMC standards, as well.
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
-

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Re: [PSES] CE marking - mixture of responsibilities

[Peter E Perkins]

 

 John,Yes, there are many very clever ways to cheat in life.  In this case 
no NRTL mark invalidates the acceptability of the CE marking downstream; the 
importers QA inspection is needed.  My suggestion only works if the folks 
downstream who are on the hook legally for the Euro conformity are paying 
attention to the details and watching for completeness and forgeries.  
Vigilance is the price of freedom.  or, as President Reagan emphasized, trust 
but verify.  



:>)br,Pete

 

-Original Message-
From: John Woodgate 
To: EMC-PSTC 
Sent: Thu, Aug 30, 2018 11:44 am
Subject: Re: [PSES] CE marking - mixture of responsibilities



But I can think of a few work-arounds thatwould invalidate that, with 
NRTL on the EU product initially,but made in a different factory with 
no NRTL inspection and lessidentical later. It's been done.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 19:37, John Woodgate  wrote:



Ah! To maximize revenue, no doubt.
  
  
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
  
On 2018-08-30 19:05, Richard Nutewrote:
  
  

  
 
  
A NRTL  tests to ALL the equipment ratings even if they include EU  
ratings.
  
Rich
  
 
  

  
From: John Woodgate   

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Re: [PSES] CE marking - mixture of responsibilities

[Nyffenegger, Dave]

Not true in my experience.  The same lab may do certification reports for EU 
declarations in addition to NRTL certification/report.  The NRTL listing report 
is specific to US and/or Canadian standards.  We put a 50Hz input rating on the 
nameplate but that’s never been included in the NRTL report.  The NRTL factory 
inspectors only inspect to the NRTL listing report.  And as John said there is 
much more to EU i.e. EMC, RoHS, WEEE, then what NRTL covers.

-Dave

From: Richard Nute [mailto:ri...@ieee.org]
Sent: Thursday, August 30, 2018 2:06 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities


A NRTL tests to ALL the equipment ratings even if they include EU ratings.
Rich

From: John Woodgate 
Sent: Thursday, August 30, 2018 10:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities


That's a bit dodgy, Pete. The EU product must be for 230 V mains, so the NRTL 
won't cover safety test with 230 V 50 Hz input. There may be issues with 
different EMC standards, as well.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
-


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Re: [PSES] CE marking - mixture of responsibilities

[John Woodgate]

But you are honest.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 19:43, Greg McClure wrote:


Actually we certify all of our products for both 110-127 V and 220-240 
V 50/60 Hz with a NRTL.


And we do sell the 220-240 V models to the US government. (FAA and 
military)


Gregory H. McClure

Lexmark Product Safety

Product Safety Team Lead

859-232-3240 office

*From:*John Woodgate 
*Sent:* Thursday, August 30, 2018 2:38 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] CE marking - mixture of responsibilities

Ah! To maximize revenue, no doubt.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-08-30 19:05, Richard Nute wrote:

A NRTL tests to ALL the equipment ratings even if they include EU
ratings.

Rich

*From:*John Woodgate  <mailto:j...@woodjohn.uk>
*Sent:* Thursday, August 30, 2018 10:57 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* Re: [PSES] CE marking - mixture of responsibilities

That's a bit dodgy, Pete. The EU product must be for 230 V mains,
so the NRTL won't cover safety test with 230 V 50 Hz input. There
may be issues with different EMC standards, as well.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>

Rayleigh, Essex UK

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<http://www.ieee-pses.org/emc-pstc.html>

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Re: [PSES] CE marking - mixture of responsibilities

[John Woodgate]

But I can think of a few work-arounds that would invalidate that, with 
NRTL on the EU product initially, but made in a different factory with 
no NRTL inspection and less identical later. It's been done.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 19:37, John Woodgate wrote:


Ah! To maximize revenue, no doubt.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-08-30 19:05, Richard Nute wrote:


A NRTL tests to ALL the equipment ratings even if they include EU 
ratings.


Rich

*From:*John Woodgate 
*Sent:* Thursday, August 30, 2018 10:57 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] CE marking - mixture of responsibilities

That's a bit dodgy, Pete. The EU product must be for 230 V mains, so 
the NRTL won't cover safety test with 230 V 50 Hz input. There may be 
issues with different EMC standards, as well.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK
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Re: [PSES] CE marking - mixture of responsibilities

[John Woodgate]

Ah! To maximize revenue, no doubt.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 19:05, Richard Nute wrote:


A NRTL tests to ALL the equipment ratings even if they include EU ratings.

Rich

*From:*John Woodgate 
*Sent:* Thursday, August 30, 2018 10:57 AM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] CE marking - mixture of responsibilities

That's a bit dodgy, Pete. The EU product must be for 230 V mains, so 
the NRTL won't cover safety test with 230 V 50 Hz input. There may be 
issues with different EMC standards, as well.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK
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Re: [PSES] CE marking - mixture of responsibilities

[Richard Nute]

 

A NRTL tests to ALL the equipment ratings even if they include EU ratings.

Rich

 

From: John Woodgate  
Sent: Thursday, August 30, 2018 10:57 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

That's a bit dodgy, Pete. The EU product must be for 230 V mains, so the NRTL 
won't cover safety test with 230 V 50 Hz input. There may be issues with 
different EMC standards, as well.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

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Re: [PSES] CE marking - mixture of responsibilities

[John Woodgate]

That's a bit dodgy, Pete. The EU product must be for 230 V mains, so the 
NRTL won't cover safety test with 230 V 50 Hz input. There may be issues 
with different EMC standards, as well.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 17:46, Peter E Perkins wrote:

James & PSnet folks,

    I could envision a scenario that could be more comfortable for 
all.  If the same product was sold worldwide and bore a US NRTL (UL, 
etc) mark along with the CE marking then the importer would know that 
the factory was having quarterly construction inspections.  At the 
Euro end just audit the incoming and ensure that the US NRTL mark 
continues to appear on the product.  there are still outstanding 
issues but the largest exposure is covered.


:>)    br,    Pete


-Original Message-
From: John Allen <09cc677f395b-dmarc-requ...@ieee.org>
To: EMC-PSTC 
Sent: Thu, Aug 30, 2018 6:34 am
Subject: Re: [PSES] CE marking - mixture of responsibilities

Head in hands – and liability insurance paper in back pocket (hopefully)!
*From:*James Pawson (U3C) [mailto:ja...@unit3compliance.co.uk 
<mailto:ja...@unit3compliance.co.uk?>]

*Sent:* 30 August 2018 13:18
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:p...@listserv.ieee.org>
*Subject:* Re: [PSES] CE marking - mixture of responsibilities
Charlie, John, thanks for the insightful feedback as always.
The latest email from the manufacturer doesn’t do much to inspire 
confidence!

James
*From:*Charlie Blackham <mailto:char...@sulisconsultants.com>>

*Sent:* 30 August 2018 10:29
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:p...@listserv.ieee.org>
*Subject:* Re: [PSES] CE marking - mixture of responsibilities
Completely agree
The importer can do all the testing on the 1^st sample, but then the 
manufacturer can make whatever they like with impunity and the 
importer takes on all the manufacturer change control risk for ongoing 
compliance without any means of controlling or monitoring it.

Barge pole at the ready
regards
Charlie
*Charlie Blackham*
*Sulis Consultants Ltd*
*Tel: +44 (0)7946 624317*
*Web: *** 
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f>*www.sulisconsultants.com 
<http://www.sulisconsultants.com>*

Registered in England and Wales, number 05466247
*From:*John Woodgate mailto:j...@woodjohn.uk>>
*Sent:* 30 August 2018 10:01
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* Re: [PSES] CE marking - mixture of responsibilities
Run, do not walk, away from this manufacturer. Either they are 
dangerously unaware of the EU requirements, or they are deliberately 
avoiding commitment.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK
On 2018-08-30 08:48, James Pawson (U3C) wrote:

Hello all,
I’m working with a company who are importing some IT products from
China to the EU. The Chinese manufacturer is taking a very much
“hands off” approach to approvals, expecting the importer to draw
up the DoC and perform much of the testing. However access to the
parts of the Technical File that detail product construction are
being held by the manufacturer and getting access to these is not
straightforward.
My question is: provided that all the documentation boxes are
ticked and the product has been sufficiently assessed, can one
reasonably take on responsibilities for other actors in the supply
chain in this manner?
I’m undecided if this is acceptable. My feeling is that whilst it
is not to the letter of the law, it is to the spirit and would be
acceptable depending on the importers tolerance to risk. However
the letter of the directives is explicit in determining
responsibilities e.g. that the manufacturer shall draw up the DoC.
I would be interested to hear your thoughts on the matter.
Thanks and all the best
James
-

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emc-pstc discussion list. To post a message to the list, send your
e-mail to mailto:emc-p...@ieee.org>>
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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/
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Scott Douglas mailto:sdoug...@ieee.org>>
Mike Cantwell mailto:mcan

Re: [PSES] CE marking - mixture of responsibilities

[Peter E Perkins]

 James & PSnet folks,


I could envision a scenario that could be more comfortable for all.  If the 
same product was sold worldwide and bore a US NRTL (UL, etc) mark along with 
the CE marking then the importer would know that the factory was having 
quarterly construction inspections.  At the Euro end just audit the incoming 
and ensure that the US NRTL mark continues to appear on the product.  there are 
still outstanding issues but the largest exposure is covered.  



:>)br,Pete

 

 

-Original Message-
From: John Allen <09cc677f395b-dmarc-requ...@ieee.org>
To: EMC-PSTC 
Sent: Thu, Aug 30, 2018 6:34 am
Subject: Re: [PSES] CE marking - mixture of responsibilities



Head in hands – and liability insurance paper in back pocket (hopefully)!
 

From: James Pawson (U3C) [mailto:ja...@unit3compliance.co.uk] 
Sent: 30 August 2018 13:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 
Charlie, John, thanks for the insightful feedback as always.
The latest email from the manufacturer doesn’t do much to inspire confidence!
James
 

From: Charlie Blackham  
Sent: 30 August 2018 10:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 
Completely agree
 
The importer can do all the testing on the 1st sample, but then the 
manufacturer can make whatever they like with impunity and the importer takes 
on all the manufacturer change control risk for ongoing compliance without any 
means of controlling or monitoring it.
 
Barge pole at the ready
 
regards
Charlie
 

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: www.sulisconsultants.com
Registered in England and Wales, number 05466247

 

From: John Woodgate  
Sent: 30 August 2018 10:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 
Run, do not walk, away from this manufacturer. Either they are dangerously 
unaware of the EU requirements, or they are deliberately avoiding commitment.
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 08:48, James Pawson (U3C) wrote:

Hello all,
 
I’m working with a company who are importing some IT products from China to the 
EU. The Chinese manufacturer is taking a very much “hands off” approach to 
approvals, expecting the importer to draw up the DoC and perform much of the 
testing. However access to the parts of the Technical File that detail product 
construction are being held by the manufacturer and getting access to these is 
not straightforward.
 
My question is: provided that all the documentation boxes are ticked and the 
product has been sufficiently assessed, can one reasonably take on 
responsibilities for other actors in the supply chain in this manner?
 
I’m undecided if this is acceptable. My feeling is that whilst it is not to the 
letter of the law, it is to the spirit and would be acceptable depending on the 
importers tolerance to risk. However the letter of the directives is explicit 
in determining responsibilities e.g. that the manufacturer shall draw up the 
DoC.
 
I would be interested to hear your thoughts on the matter.
 
Thanks and all the best
James
-

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discussion list. To post a message to the list, send your e-mail to 

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.
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Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html 
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Scott Douglas 
Mike Cantwell  
For policy questions, send mail to:
Jim Bacher 
David Heald  

 
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This message is from the IEEE Product Safet

Re: [PSES] CE marking - mixture of responsibilities

[John Allen]

Head in hands - and liability insurance paper in back pocket (hopefully)!

 

From: James Pawson (U3C) [mailto:ja...@unit3compliance.co.uk] 
Sent: 30 August 2018 13:18
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

Charlie, John, thanks for the insightful feedback as always.

The latest email from the manufacturer doesn't do much to inspire
confidence!

James

 

From: Charlie Blackham  
Sent: 30 August 2018 10:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

Completely agree

 

The importer can do all the testing on the 1st sample, but then the
manufacturer can make whatever they like with impunity and the importer
takes on all the manufacturer change control risk for ongoing compliance
without any means of controlling or monitoring it.

 

Barge pole at the ready

 

regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f
5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: John Woodgate  
Sent: 30 August 2018 10:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

Run, do not walk, away from this manufacturer. Either they are dangerously
unaware of the EU requirements, or they are deliberately avoiding
commitment.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 08:48, James Pawson (U3C) wrote:

Hello all,

 

I'm working with a company who are importing some IT products from China to
the EU. The Chinese manufacturer is taking a very much "hands off" approach
to approvals, expecting the importer to draw up the DoC and perform much of
the testing. However access to the parts of the Technical File that detail
product construction are being held by the manufacturer and getting access
to these is not straightforward.

 

My question is: provided that all the documentation boxes are ticked and the
product has been sufficiently assessed, can one reasonably take on
responsibilities for other actors in the supply chain in this manner?

 

I'm undecided if this is acceptable. My feeling is that whilst it is not to
the letter of the law, it is to the spirit and would be acceptable depending
on the importers tolerance to risk. However the letter of the directives is
explicit in determining responsibilities e.g. that the manufacturer shall
draw up the DoC.

 

I would be interested to hear your thoughts on the matter.

 

Thanks and all the best

James

-


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discussion list. To post a message to the list, send your e-mail to


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) <http://www.ieee-pses.org/list.html> 
List rules: http://www.ieee-pses.org/listrules.html 

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell  

For policy questions, send mail to:
Jim Bacher 
David Heald  

 

-


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discussion list. To post a message to the list, send your e-mail to


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) <http://www.ieee-pses.org/list.html> 
List rules: http://www.ieee-pses.org/listrules.html 

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell  

For policy questions, send mail to:
Jim Bacher 
David Heald  

-


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


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:

Re: [PSES] CE marking - mixture of responsibilities

[James Pawson (U3C)]

Charlie, John, thanks for the insightful feedback as always.

The latest email from the manufacturer doesn't do much to inspire
confidence!

James

 

From: Charlie Blackham  
Sent: 30 August 2018 10:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

Completely agree

 

The importer can do all the testing on the 1st sample, but then the
manufacturer can make whatever they like with impunity and the importer
takes on all the manufacturer change control risk for ongoing compliance
without any means of controlling or monitoring it.

 

Barge pole at the ready

 

regards

Charlie

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f
5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: John Woodgate mailto:j...@woodjohn.uk> > 
Sent: 30 August 2018 10:01
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: Re: [PSES] CE marking - mixture of responsibilities

 

Run, do not walk, away from this manufacturer. Either they are dangerously
unaware of the EU requirements, or they are deliberately avoiding
commitment.

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk <http://www.woodjohn.uk> 
Rayleigh, Essex UK

On 2018-08-30 08:48, James Pawson (U3C) wrote:

Hello all,

 

I'm working with a company who are importing some IT products from China to
the EU. The Chinese manufacturer is taking a very much "hands off" approach
to approvals, expecting the importer to draw up the DoC and perform much of
the testing. However access to the parts of the Technical File that detail
product construction are being held by the manufacturer and getting access
to these is not straightforward.

 

My question is: provided that all the documentation boxes are ticked and the
product has been sufficiently assessed, can one reasonably take on
responsibilities for other actors in the supply chain in this manner?

 

I'm undecided if this is acceptable. My feeling is that whilst it is not to
the letter of the law, it is to the spirit and would be acceptable depending
on the importers tolerance to risk. However the letter of the directives is
explicit in determining responsibilities e.g. that the manufacturer shall
draw up the DoC.

 

I would be interested to hear your thoughts on the matter.

 

Thanks and all the best

James

-


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discussion list. To post a message to the list, send your e-mail to
mailto: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
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List rules: http://www.ieee-pses.org/listrules.html 

For help, send mail to the list administrators:
Scott Douglas mailto:sdoug...@ieee.org> >
Mike Cantwell mailto:mcantw...@ieee.org> > 

For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org> >
David Heald mailto:dhe...@gmail.com> > 

 

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discussion list. To post a message to the list, send your e-mail to
mailto:emc-p...@ieee.org> >

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Attachments are not permitted but the IEEE PSES Online Communities site at
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David Heald mailto:dhe...@gmail.com> > 

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discussion list. To post a message to the list, send your e-mail to
mailto:emc-p...@ieee.org> >

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Attachments are not permitted but the

Re: [PSES] CE marking - mixture of responsibilities

[Charlie Blackham]

Completely agree

The importer can do all the testing on the 1st sample, but then the 
manufacturer can make whatever they like with impunity and the importer takes 
on all the manufacturer change control risk for ongoing compliance without any 
means of controlling or monitoring it.

Barge pole at the ready

regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: John Woodgate 
Sent: 30 August 2018 10:01
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE marking - mixture of responsibilities


Run, do not walk, away from this manufacturer. Either they are dangerously 
unaware of the EU requirements, or they are deliberately avoiding commitment.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-08-30 08:48, James Pawson (U3C) wrote:
Hello all,

I'm working with a company who are importing some IT products from China to the 
EU. The Chinese manufacturer is taking a very much "hands off" approach to 
approvals, expecting the importer to draw up the DoC and perform much of the 
testing. However access to the parts of the Technical File that detail product 
construction are being held by the manufacturer and getting access to these is 
not straightforward.

My question is: provided that all the documentation boxes are ticked and the 
product has been sufficiently assessed, can one reasonably take on 
responsibilities for other actors in the supply chain in this manner?

I'm undecided if this is acceptable. My feeling is that whilst it is not to the 
letter of the law, it is to the spirit and would be acceptable depending on the 
importers tolerance to risk. However the letter of the directives is explicit 
in determining responsibilities e.g. that the manufacturer shall draw up the 
DoC.

I would be interested to hear your thoughts on the matter.

Thanks and all the best
James
-


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 
mailto: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 
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List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas mailto:sdoug...@ieee.org>>
Mike Cantwell mailto:mcantw...@ieee.org>>

For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org>>
David Heald mailto:dhe...@gmail.com>>

-


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Re: [PSES] CE marking - mixture of responsibilities

[John Woodgate]

Run, do not walk, away from this manufacturer. Either they are 
dangerously unaware of the EU requirements, or they are deliberately 
avoiding commitment.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-08-30 08:48, James Pawson (U3C) wrote:


Hello all,

I’m working with a company who are importing some IT products from 
China to the EU. The Chinese manufacturer is taking a very much “hands 
off” approach to approvals, expecting the importer to draw up the DoC 
and perform much of the testing. However access to the parts of the 
Technical File that detail product construction are being held by the 
manufacturer and getting access to these is not straightforward.


My question is: provided that all the documentation boxes are ticked 
and the product has been sufficiently assessed, can one reasonably 
take on responsibilities for other actors in the supply chain in this 
manner?


I’m undecided if this is acceptable. My feeling is that whilst it is 
not to the letter of the law, it is to the spirit and would be 
acceptable depending on the importers tolerance to risk. However the 
letter of the directives is explicit in determining responsibilities 
e.g. that the manufacturer shall draw up the DoC.


I would be interested to hear your thoughts on the matter.

Thanks and all the best

James

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[PSES] CE marking - mixture of responsibilities

[James Pawson (U3C)]

Hello all,

 

I'm working with a company who are importing some IT products from China to
the EU. The Chinese manufacturer is taking a very much "hands off" approach
to approvals, expecting the importer to draw up the DoC and perform much of
the testing. However access to the parts of the Technical File that detail
product construction are being held by the manufacturer and getting access
to these is not straightforward.

 

My question is: provided that all the documentation boxes are ticked and the
product has been sufficiently assessed, can one reasonably take on
responsibilities for other actors in the supply chain in this manner?

 

I'm undecided if this is acceptable. My feeling is that whilst it is not to
the letter of the law, it is to the spirit and would be acceptable depending
on the importers tolerance to risk. However the letter of the directives is
explicit in determining responsibilities e.g. that the manufacturer shall
draw up the DoC.

 

I would be interested to hear your thoughts on the matter.

 

Thanks and all the best

James


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Re: [PSES] CE marking of machinery that moves about

[Doug Nix, C.E.T.]

Pete,

Got time for a phone call later today or this week? I’ve done some work in this 
area and might be able to add some thoughts. 

Best,
Doug Nix

d...@ieee.org
Mobile: (519) 729-5704
Office:(519) 650-4753

> On Aug 2, 2018, at 08:52, John Allen 
> <09cc677f395b-dmarc-requ...@ieee.org> wrote:
> 
> Look for relevant Type B and specific Type C EN standards.
>  
> John E Allen
> W.London, UK
>  
> From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] 
> Sent: 02 August 2018 13:29
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] CE marking of machinery that moves about
>  
> Colleagues, I’ve been dealing with CE marking of machinery for some 
> time but now am interested in a variation on that theme, machinery that 
> moves.  Think of a fork-lift or front loader each of which lifts a load and 
> moves it before setting it down again.  What additional requirements are 
> placed upon such a machine. 
>  
> :>) br,  Pete
>  
> Peter E Perkins, PE
> Principal Product Safety & Regulatory Affairs Consultant
> PO Box 23427
> Tigard, ORe  97281-3427
>  
> 503/452-1201
>  
> IEEE Life Fellow
> p.perk...@ieee.org
>  
> -
> 
> 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 
> 
> 
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> 
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> formats), large files, etc.
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> -
> 
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> 
> 
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Re: [PSES] CE marking of machinery that moves about

[Doug Powell]

It seems to me that in addition to the MD, you may need to look at any
vehicular issues.  Depending on the engine type possibly batteries, fuels,
etc.  The term forklift may not work and instead try lift truck.

I would be curious to see what you finally decide.

Thanks,  Doug

-

Werner Heisenberg, Kurt Gödel, and Noam Chomsky walk into a bar. Heisenberg
turns to the other two and says, “Clearly this is a joke, but how can we
figure out if it’s funny or not?” Gödel replies, “We can’t know that
because we’re inside the joke.” Chomsky says, “Of course it’s funny. You’re
just telling it wrong.”


On Thu, Aug 2, 2018 at 8:08 AM Mike Sherman  wrote:

> Pete --
>
> Things to consider:
> 1.  Section 3 of Annex I of the Machinery Safety Directive.
>
> 2.  There may be some Type C EN standards that are applicable, or from
> which you could glean some useful requirements.
>
> 3.  Product might be out of scope of RoHS directive, if it meets the
> definition of professional off road mobile machinery. See Guideline to the
> RoHS directive for the finer points of this.
>
> Mike Sherman
> Graco Inc.
>
> --
> *From: *"Pete Perkins" <0061f3f32d0c-dmarc-requ...@ieee.org>
> *To: *"EMC-PSTC" 
> *Sent: *Thursday, August 2, 2018 7:28:39 AM
> *Subject: *[PSES] CE marking of machinery that moves about
>
> Colleagues, I’ve been dealing with CE marking of machinery for
> some time but now am interested in a variation on that theme, machinery
> that moves.  Think of a fork-lift or front loader each of which lifts a
> load and moves it before setting it down again.  What additional
> requirements are placed upon such a machine.
>
>
>
> :>) br,  Pete
>
>
>
> Peter E Perkins, PE
>
> Principal Product Safety & Regulatory Affairs Consultant
>
> PO Box 23427
>
> Tigard, ORe  97281-3427
>
>
>
> 503/452-1201
>
>
>
> IEEE Life Fellow
>
> p.perk...@ieee.org
>
>
> -
> 
>
> 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:
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>
> Attachments are not permitted but the IEEE PSES Online Communities site at
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> well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
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> -
> 
>
> 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>
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-- 

Douglas E Powell

doug...@gmail.com
http://www.linkedin.com/in/dougp01

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Re: [PSES] CE marking of machinery that moves about

[Mike Sherman]

Pete -- 

Things to consider: 
1. Section 3 of Annex I of the Machinery Safety Directive. 

2. There may be some Type C EN standards that are applicable, or from which you 
could glean some useful requirements. 

3. Product might be out of scope of RoHS directive, if it meets the definition 
of professional off road mobile machinery. See Guideline to the RoHS directive 
for the finer points of this. 

Mike Sherman 
Graco Inc. 

- Original Message -

From: "Pete Perkins" <0061f3f32d0c-dmarc-requ...@ieee.org> 
To: "EMC-PSTC"  
Sent: Thursday, August 2, 2018 7:28:39 AM 
Subject: [PSES] CE marking of machinery that moves about 



Colleagues, I’ve been dealing with CE marking of machinery for some time but 
now am interested in a variation on that theme, machinery that moves. Think of 
a fork-lift or front loader each of which lifts a load and moves it before 
setting it down again. What additional requirements are placed upon such a 
machine. 



:>) br, Pete 



Peter E Perkins, PE 

Principal Product Safety & Regulatory Affairs Consultant 

PO Box 23427 

Tigard, ORe 97281-3427 



503/452-1201 



IEEE Life Fellow 

p.perk...@ieee.org 


- 
 


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Re: [PSES] CE marking of machinery that moves about

[Nick Williams]

Mobile machines are addressed by section 3 of Annex 1 of the Machinery 
Directive. Machines for lifting loads are addressed by section 4. Machines for 
lifting people are addressed by section 6. 

Regards

Nick. 

> On 2 Aug 2018, at 13:28, Pete Perkins 
> <0061f3f32d0c-dmarc-requ...@ieee.org> wrote:
> 
> Colleagues, I’ve been dealing with CE marking of machinery for some 
> time but now am interested in a variation on that theme, machinery that 
> moves.  Think of a fork-lift or front loader each of which lifts a load and 
> moves it before setting it down again.  What additional requirements are 
> placed upon such a machine.  
>  
> :>) br,  Pete
>  
> Peter E Perkins, PE
> Principal Product Safety & Regulatory Affairs Consultant
> PO Box 23427
> Tigard, ORe  97281-3427
>  


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Re: [PSES] CE marking of machinery that moves about

[John Allen]

Look for relevant Type B and specific Type C EN standards.

 

John E Allen

W.London, UK

 

From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] 
Sent: 02 August 2018 13:29
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE marking of machinery that moves about

 

Colleagues, I've been dealing with CE marking of machinery for some
time but now am interested in a variation on that theme, machinery that
moves.  Think of a fork-lift or front loader each of which lifts a load and
moves it before setting it down again.  What additional requirements are
placed upon such a machine.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

p.perk...@ieee.org

 

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[PSES] CE marking of machinery that moves about

[Pete Perkins]

Colleagues, I've been dealing with CE marking of machinery for some
time but now am interested in a variation on that theme, machinery that
moves.  Think of a fork-lift or front loader each of which lifts a load and
moves it before setting it down again.  What additional requirements are
placed upon such a machine.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

p.perk...@ieee.org <mailto:p.perk...@ieee.org> 

 


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Re: [PSES] Looking for Industrial CE Marking consultant in the US Midwest.

[Mel Soliven]

 Hi Mr Nix,
I am interested for EMC as cosultant.
Kind regards and many thanks for your recommendation.
Regards,mel
   On Tuesday, 29 May 2018, 4:45:15 AM GMT+9, Doug Nix  wrote: 
 
 Thanks to all who replied to this post. There were a number of familiar people 
(you know who your are!) as well as one or two new folks. I’ve passed along 
contact information to the people concerned.
Doug Nix
d...@ieee.org
+1 (519) 729-5704


On 17-May-18, at 16:22, Doug Nix  wrote:

I am looking for an industrial CE Marking consultant with expertise in at least 
the following Directives:
MachineryLow VoltageEMCPressure EquipmentATEXIndustrial Gas Burning Equipment
This is for occasional consulting as a third-party consultant to the client.
Doug Nix
d...@ieee.org
+1 (519) 729-5704

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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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher 
David Heald 
  

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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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

[PSES] Looking for Industrial CE Marking consultant in the US Midwest.

[Doug Nix]

I am looking for an industrial CE Marking consultant with expertise in at least 
the following Directives:

Machinery
Low Voltage
EMC
Pressure Equipment
ATEX
Industrial Gas Burning Equipment

This is for occasional consulting as a third-party consultant to the client.

Doug Nix
d...@ieee.org
+1 (519) 729-5704


-

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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] CE Marking HDMI Cables

[Monrad Monsen]

Hi Scott,

I agree with Ted. The Low Voltage Directive 2014/35/EU states that the 
“Directive shall apply to electrical equipment designed for use with a voltage 
rating of between 50 and 1000 V for alternating current and between 75 and 1500 
V for direct current” {Article 1}, so the HDMI cables are outside of the 
directive’s scope alone and only must meet the safety requirements as an 
authorized component of in-scope electrical equipment.

 

In contrast, HDMI cables are in-scope for the RoHS Directive 2011/65/EU.  Read 
the RoHS Frequently Asked Questions (FAQ) in section 5 with the responses to 
questions 5.1 to 5.3.  

http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf 

 

Hope this helps. 

 

Monrad Monsen

 

NOTE: All opinions expressed in this email are wholly my own and are not 
necessarily those of any company I work for.

 

From: Ted Eckert [mailto:07cf6ebeab9d-dmarc-requ...@ieee.org] 
Sent: Sunday, January 07, 2018 3:40 PM
To: EMC-PSTC@listserv.ieee.org
Subject: Re: [PSES] CE Marking HDMI Cables

 

Hello Scott,

 

I believe that line voltage wires and cables used for electrical distribution 
within buildings fall under the Low Voltage Directive. The Construction 
Products Directive covers many of the products that form the physical structure 
of buildings. It does not cover mechanical and electrical systems. Many 
electrical products will still fall under the Low Voltage Directive. However, 
the voltage of an HDMI cable is below the lower limit of the Low Voltage 
Directive, so it would not be covered.

 

Here is the specification sheet for a Belden Cat5 Ethernet cable for use inside 
of walls. (I am not necessarily recommending Belden. I just expected them to be 
more diligent about listing compliance standards than other vendors.)

HYPERLINK 
"https://urldefense.proofpoint.com/v2/url?u=https-3A__edesk.belden.com_products_techdata_english_pdf_7960A.pdf&d=DwMGaQ&c=RoP1YumCXCgaWHvlZYR8PZh8Bv7qIrMUB65eapI_JnE&r=bdhQMzFxnmYEOUrCJpiaOszYW-e590kX_eWuZIISyNU&m=96WfaC1wxJzxaLa3I4zk9Fty6qb7WiZ8RhtjPC4e5qg&s=zSwxaS72qhP3a8NJvexmcEtP6w2D8TLCNqAuwd99WJw&e="https://edesk.belden.com/products/techdata/english/pdf/7960A.pdf

It has North American safety certifications, but nothing for Europe. Belden 
covers RoHS, WEEE, ELV, and BFR Directives, all environmentally related. Maybe 
I’m missing something, but I don’t see a declaration of any European safety 
requirements.

 

Ted Eckert

Microsoft Corporation

 

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

 

From: Scott Douglas [mailto:sdouglas...@gmail.com] 
Sent: Sunday, January 7, 2018 12:31 PM
To: Ted Eckert mailto:ted.eck...@microsoft.com"ted.eck...@microsoft.com>; HYPERLINK 
"mailto:EMC-PSTC@LISTSERV.IEEE.ORG"EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking HDMI Cables

 

Ted,

I sent the the RoHS FAQ and they agree the cables need to be RoHS. They resist 
CE Marking because the cables have UL approvals for use inside walls (read 
flammability). They claim there are "matching" safety requirements in the EU 
and these were not tested for. So they cannot apply the CE Mark. I contend that 
those "matching" EU safety requirements are not CE Marking requirements so do 
not apply.

Is anyone aware of any CE Marking requirements for cables used inside walls? 
Possibly under Construction Products or General Safety?

Thanks again for all comments.

Scott

On 1/4/2018 6:55 PM, Ted Eckert wrote:

Hello Scott,

 

There are U.S. and Canadian national differences to many safety standards that 
mandates flame resistance for cables such as this. Cables under 3.05 meter in 
length must be VW-1 or FT-1 or better in flame rating. (Longer cables are 
subject to stricter requirements.) This is why you can find UL approvals on 
cables, but not necessarily other international safety certifications for HDMI, 
USB and other data cables. The LVD would not apply to an HDMI cable sold on its 
own as it is below the lower voltage limit of the scope.

 

Generally, if the cable is bundled with a product, the cable does not need the 
CE marking. If the cable is sold on its own, the CE mark is required for RoHS. 
See pages 15 and 16 in the European Commission guidance document.

HYPERLINK 
"https://urldefense.proofpoint.com/v2/url?u=https-3A__na01.safelinks.protection.outlook.com_-3Furl-3Dhttp-253A-252F-252Fec.europa.eu-252Fenvironment-252Fwaste-252Frohs-5Feee-252Fpdf-252Ffaq.pdf-26data-3D02-257C01-257CTed.Eckert-2540microsoft.com-257C4d79f6d2f44a4851e41908d5560d925c-257C72f988bf86f141af91ab2d7cd011db47-257C1-257C1-257C636509538657872815-26sdata-3DosG1mS0ZUgv1ZiezjcV3D3hdLLoCk-252FSamQsdvaykYEo-253D-26reserved-3D0&d=DwMGaQ&c=RoP1YumCXCgaWHvlZYR8PZh8Bv7qIrMUB65eapI_JnE&r=bdhQMzFxnmYEOUrCJpiaOszYW-e590kX_eWuZIISyNU&m=96WfaC1wxJzxaLa3I4zk9Fty6qb7WiZ8RhtjPC4e5qg&s=upBf7dPfWE9zIA-pVwZMhoopsR2yxhVfCOsObEzTmxw&e=&quo

Re: [PSES] CE Marking HDMI Cables

[Charlie Blackham]

Scott

By affixing the CE mark the manufacturer is declaring compliance against all 
applicable directives – if a particular directive isn’t applicable then it 
doesn’t matter.

Whilst lots of people like seeing UL marks on things, it has no meaning within 
EU legislation, anymore that CE marking does in US legislation

They should remember that there are over 20 “CE marking Directives” and they’re 
not declaring compliance against all the other ones either because the product 
is not in scope

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: Scott Douglas [mailto:sdouglas...@gmail.com]
Sent: 07 January 2018 20:31
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking HDMI Cables

Ted,

I sent the the RoHS FAQ and they agree the cables need to be RoHS. They resist 
CE Marking because the cables have UL approvals for use inside walls (read 
flammability). They claim there are "matching" safety requirements in the EU 
and these were not tested for. So they cannot apply the CE Mark. I contend that 
those "matching" EU safety requirements are not CE Marking requirements so do 
not apply.

Is anyone aware of any CE Marking requirements for cables used inside walls? 
Possibly under Construction Products or General Safety?

Thanks again for all comments.

Scott

On 1/4/2018 6:55 PM, Ted Eckert wrote:
Hello Scott,

There are U.S. and Canadian national differences to many safety standards that 
mandates flame resistance for cables such as this. Cables under 3.05 meter in 
length must be VW-1 or FT-1 or better in flame rating. (Longer cables are 
subject to stricter requirements.) This is why you can find UL approvals on 
cables, but not necessarily other international safety certifications for HDMI, 
USB and other data cables. The LVD would not apply to an HDMI cable sold on its 
own as it is below the lower voltage limit of the scope.

Generally, if the cable is bundled with a product, the cable does not need the 
CE marking. If the cable is sold on its own, the CE mark is required for RoHS. 
See pages 15 and 16 in the European Commission guidance document.
http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer.


From: Scott Douglas [mailto:sdouglas...@gmail.com]
Sent: Thursday, January 4, 2018 6:42 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] CE Marking HDMI Cables

My opinion is only the RoHS Directive should apply. But my last email from the 
ODM tonight says the cables have UL Approvals too, on the cable, on the 
connector and then flammability on the assembly. So they think that there must 
be some safety directive that applies (and was not tested for). They are 
checking with their factory (again).
On 1/4/2018 6:27 PM, Brent DeWitt wrote:
Hi Scott,

Which Directives do you think should apply?

From: Scott Douglas [mailto:sdouglas...@gmail.com]
Sent: Thursday, January 04, 2018 7:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] CE Marking HDMI Cables


I am going around with an ODM making a HDMI cable for us. Standard cable just 
has our brand logo molded in the connector shell. Cable is to be used with 
Category 4 (ITE) Equipment and is sold separately.

The question is CE Marked or not CE Marked. I say it must be CE Marked and they 
say not required. I have been through the directives and FAQ more than a few 
times and it seems black and white to me.

They say they talked to three different compliance labs, at least one of which 
is familiar to a lot of us on the west coast, and all say not required. They 
say their compliance engineers all went to the required training and they all 
say not required.


Am I the only one that thinks these HDMI cables need to be CE Marked? Or am I 
missing something? Like maybe not required today but required to be marked at 
some future date like 2019 maybe?

Last, assuming I am not on some good psychedelics and CE Marking is required on 
or for HDMI cables, can I get away with putting the CE Mark on the single unit 
package, like a label on the poly bag it is sealed in?

I thank everybody that helps answer the question and keeps me from consuming 
more of those pink pills.

Happy New Year to all.
Scott

-


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 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html<https://na01.safelinks.protect

Re: [PSES] CE Marking HDMI Cables

[Ted Eckert]

Hello Scott,

I believe that line voltage wires and cables used for electrical distribution 
within buildings fall under the Low Voltage Directive. The Construction 
Products Directive covers many of the products that form the physical structure 
of buildings. It does not cover mechanical and electrical systems. Many 
electrical products will still fall under the Low Voltage Directive. However, 
the voltage of an HDMI cable is below the lower limit of the Low Voltage 
Directive, so it would not be covered.

Here is the specification sheet for a Belden Cat5 Ethernet cable for use inside 
of walls. (I am not necessarily recommending Belden. I just expected them to be 
more diligent about listing compliance standards than other vendors.)
https://edesk.belden.com/products/techdata/english/pdf/7960A.pdf
It has North American safety certifications, but nothing for Europe. Belden 
covers RoHS, WEEE, ELV, and BFR Directives, all environmentally related. Maybe 
I’m missing something, but I don’t see a declaration of any European safety 
requirements.

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer.

From: Scott Douglas [mailto:sdouglas...@gmail.com]
Sent: Sunday, January 7, 2018 12:31 PM
To: Ted Eckert ; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking HDMI Cables

Ted,

I sent the the RoHS FAQ and they agree the cables need to be RoHS. They resist 
CE Marking because the cables have UL approvals for use inside walls (read 
flammability). They claim there are "matching" safety requirements in the EU 
and these were not tested for. So they cannot apply the CE Mark. I contend that 
those "matching" EU safety requirements are not CE Marking requirements so do 
not apply.

Is anyone aware of any CE Marking requirements for cables used inside walls? 
Possibly under Construction Products or General Safety?

Thanks again for all comments.

Scott

On 1/4/2018 6:55 PM, Ted Eckert wrote:
Hello Scott,

There are U.S. and Canadian national differences to many safety standards that 
mandates flame resistance for cables such as this. Cables under 3.05 meter in 
length must be VW-1 or FT-1 or better in flame rating. (Longer cables are 
subject to stricter requirements.) This is why you can find UL approvals on 
cables, but not necessarily other international safety certifications for HDMI, 
USB and other data cables. The LVD would not apply to an HDMI cable sold on its 
own as it is below the lower voltage limit of the scope.

Generally, if the cable is bundled with a product, the cable does not need the 
CE marking. If the cable is sold on its own, the CE mark is required for RoHS. 
See pages 15 and 16 in the European Commission guidance document.
http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fec.europa.eu%2Fenvironment%2Fwaste%2Frohs_eee%2Fpdf%2Ffaq.pdf&data=02%7C01%7CTed.Eckert%40microsoft.com%7C4d79f6d2f44a4851e41908d5560d925c%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C1%7C636509538657872815&sdata=osG1mS0ZUgv1ZiezjcV3D3hdLLoCk%2FSamQsdvaykYEo%3D&reserved=0>

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer.


From: Scott Douglas [mailto:sdouglas...@gmail.com]
Sent: Thursday, January 4, 2018 6:42 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] CE Marking HDMI Cables

My opinion is only the RoHS Directive should apply. But my last email from the 
ODM tonight says the cables have UL Approvals too, on the cable, on the 
connector and then flammability on the assembly. So they think that there must 
be some safety directive that applies (and was not tested for). They are 
checking with their factory (again).
On 1/4/2018 6:27 PM, Brent DeWitt wrote:
Hi Scott,

Which Directives do you think should apply?

From: Scott Douglas [mailto:sdouglas...@gmail.com]
Sent: Thursday, January 04, 2018 7:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] CE Marking HDMI Cables


I am going around with an ODM making a HDMI cable for us. Standard cable just 
has our brand logo molded in the connector shell. Cable is to be used with 
Category 4 (ITE) Equipment and is sold separately.

The question is CE Marked or not CE Marked. I say it must be CE Marked and they 
say not required. I have been through the directives and FAQ more than a few 
times and it seems black and white to me.

They say they talked to three different compliance labs, at least one of which 
is familiar to a lot of us on the west coast, and all say not required. They 
say their compliance engineers all went to the required training and they all 
say not required.


Am I the only one that thinks these HDMI cables need to be CE Marked? Or am I 
missing something? Like maybe not required today but required to be marked at 
some fut

Re: [PSES] CE Marking HDMI Cables

[Scott Douglas]

Ted,

I sent the the RoHS FAQ and they agree the cables need to be RoHS. They 
resist CE Marking because the cables have UL approvals for use inside 
walls (read flammability). They claim there are "matching" safety 
requirements in the EU and these were not tested for. So they cannot 
apply the CE Mark. I contend that those "matching" EU safety 
requirements are not CE Marking requirements so do not apply.


Is anyone aware of any CE Marking requirements for cables used inside 
walls? Possibly under Construction Products or General Safety?


Thanks again for all comments.

Scott


On 1/4/2018 6:55 PM, Ted Eckert wrote:


Hello Scott,

There are U.S. and Canadian national differences to many safety 
standards that mandates flame resistance for cables such as this. 
Cables under 3.05 meter in length must be VW-1 or FT-1 or better in 
flame rating. (Longer cables are subject to stricter requirements.) 
This is why you can find UL approvals on cables, but not necessarily 
other international safety certifications for HDMI, USB and other data 
cables. The LVD would not apply to an HDMI cable sold on its own as it 
is below the lower voltage limit of the scope.


Generally, if the cable is bundled with a product, the cable does not 
need the CE marking. If the cable is sold on its own, the CE mark is 
required for RoHS. See pages 15 and 16 in the European Commission 
guidance document.


http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf

Ted Eckert

Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those 
of my employer.


*From:*Scott Douglas [mailto:sdouglas...@gmail.com]
*Sent:* Thursday, January 4, 2018 6:42 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] CE Marking HDMI Cables

My opinion is only the RoHS Directive should apply. But my last email 
from the ODM tonight says the cables have UL Approvals too, on the 
cable, on the connector and then flammability on the assembly. So they 
think that there must be some safety directive that applies (and was 
not tested for). They are checking with their factory (again).


On 1/4/2018 6:27 PM, Brent DeWitt wrote:

Hi Scott,

Which Directives do you think should apply?

*From:* Scott Douglas [mailto:sdouglas...@gmail.com]
*Sent:* Thursday, January 04, 2018 7:00 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
*Subject:* [PSES] CE Marking HDMI Cables

I am going around with an ODM making a HDMI cable for us. Standard
cable just has our brand logo molded in the connector shell. Cable
is to be used with Category 4 (ITE) Equipment and is sold separately.

The question is CE Marked or not CE Marked. I say it must be CE
Marked and they say not required. I have been through the
directives and FAQ more than a few times and it seems black and
white to me.

They say they talked to three different compliance labs, at least
one of which is familiar to a lot of us on the west coast, and all
say not required. They say their compliance engineers all went to
the required training and they all say not required.

Am I the only one that thinks these HDMI cables need to be CE
Marked? Or am I missing something? Like maybe not required today
but required to be marked at some future date like 2019 maybe?

Last, assuming I am not on some good psychedelics and CE Marking
is required on or for HDMI cables, can I get away with putting the
CE Mark on the single unit package, like a label on the poly bag
it is sealed in?

I thank everybody that helps answer the question and keeps me from
consuming more of those pink pills.

Happy New Year to all.

Scott

-


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 mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at:
http://www.ieee-pses.org/emc-pstc.html

<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fwww.ieee-pses.org%2Femc-pstc.html&data=02%7C01%7Cted.eckert%40microsoft.com%7C5298df1371204836252f08d553e5e1bb%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636507169162758291&sdata=eRGq%2Blo5fYBMBYx9sxc4AR%2FIl%2BWRqNJK2KbtS4LQSk8%3D&reserved=0>

Attachments are not permitted but the IEEE PSES Online Communities
site at http://product-compliance.oc.ieee.org/

<https://na01.safelinks.protection.outlook.com/?url=http%3A%2F%2Fproduct-compliance.oc.ieee.org%2F&data=02%7C01%7Cted.eckert%40microsoft.com%7C5298df1371204836252f08d553e5e1bb%7C72f988bf86f141af91ab2d7cd011db47%7C1%7C0%7C636507169162758291&sdata=kh6BA5LGr1c62UBrdmh9JgKyhTu7RXZEWzaXzX4KJZU%3D&reserved=0>
can be used for graphics (in well-used formats), large fi

Re: [PSES] CE Marking HDMI Cables

[Scott Xe]

Scott,

LVD is not applicable to the cable due to low operating voltage but RoHS
requires to be marked CE as the compliance.

Regards,

Scott

On 5 January 2018 at 08:00, Scott Douglas  wrote:

>
> I am going around with an ODM making a HDMI cable for us. Standard cable
> just has our brand logo molded in the connector shell. Cable is to be used
> with Category 4 (ITE) Equipment and is sold separately.
>
> The question is CE Marked or not CE Marked. I say it must be CE Marked and
> they say not required. I have been through the directives and FAQ more than
> a few times and it seems black and white to me.
>
> They say they talked to three different compliance labs, at least one of
> which is familiar to a lot of us on the west coast, and all say not
> required. They say their compliance engineers all went to the required
> training and they all say not required.
>
>
> Am I the only one that thinks these HDMI cables need to be CE Marked? Or
> am I missing something? Like maybe not required today but required to be
> marked at some future date like 2019 maybe?
>
> Last, assuming I am not on some good psychedelics and CE Marking is
> required on or for HDMI cables, can I get away with putting the CE Mark on
> the single unit package, like a label on the poly bag it is sealed in?
>
> I thank everybody that helps answer the question and keeps me from
> consuming more of those pink pills.
>
> Happy New Year to all.
> Scott
>
> -
> 
>
> 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) <http://www.ieee-pses.org/list.html>
> 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 


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 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] CE Marking HDMI Cables

[Ted Eckert]

Hello Scott,

There are U.S. and Canadian national differences to many safety standards that 
mandates flame resistance for cables such as this. Cables under 3.05 meter in 
length must be VW-1 or FT-1 or better in flame rating. (Longer cables are 
subject to stricter requirements.) This is why you can find UL approvals on 
cables, but not necessarily other international safety certifications for HDMI, 
USB and other data cables. The LVD would not apply to an HDMI cable sold on its 
own as it is below the lower voltage limit of the scope.

Generally, if the cable is bundled with a product, the cable does not need the 
CE marking. If the cable is sold on its own, the CE mark is required for RoHS. 
See pages 15 and 16 in the European Commission guidance document.
http://ec.europa.eu/environment/waste/rohs_eee/pdf/faq.pdf

Ted Eckert
Microsoft Corporation

The opinions expressed are my own and do not necessarily reflect those of my 
employer.


From: Scott Douglas [mailto:sdouglas...@gmail.com]
Sent: Thursday, January 4, 2018 6:42 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking HDMI Cables

My opinion is only the RoHS Directive should apply. But my last email from the 
ODM tonight says the cables have UL Approvals too, on the cable, on the 
connector and then flammability on the assembly. So they think that there must 
be some safety directive that applies (and was not tested for). They are 
checking with their factory (again).
On 1/4/2018 6:27 PM, Brent DeWitt wrote:
Hi Scott,

Which Directives do you think should apply?

From: Scott Douglas [mailto:sdouglas...@gmail.com]
Sent: Thursday, January 04, 2018 7:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] CE Marking HDMI Cables


I am going around with an ODM making a HDMI cable for us. Standard cable just 
has our brand logo molded in the connector shell. Cable is to be used with 
Category 4 (ITE) Equipment and is sold separately.

The question is CE Marked or not CE Marked. I say it must be CE Marked and they 
say not required. I have been through the directives and FAQ more than a few 
times and it seems black and white to me.

They say they talked to three different compliance labs, at least one of which 
is familiar to a lot of us on the west coast, and all say not required. They 
say their compliance engineers all went to the required training and they all 
say not required.


Am I the only one that thinks these HDMI cables need to be CE Marked? Or am I 
missing something? Like maybe not required today but required to be marked at 
some future date like 2019 maybe?

Last, assuming I am not on some good psychedelics and CE Marking is required on 
or for HDMI cables, can I get away with putting the CE Mark on the single unit 
package, like a label on the poly bag it is sealed in?

I thank everybody that helps answer the question and keeps me from consuming 
more of those pink pills.

Happy New Year to all.
Scott

-


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discussion list. To post a message to the list, send your e-mail to 
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 can be used for graphics (in well-used formats), large files, etc.

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Re: [PSES] CE Marking HDMI Cables

[Scott Douglas]

My opinion is only the RoHS Directive should apply. But my last email 
from the ODM tonight says the cables have UL Approvals too, on the 
cable, on the connector and then flammability on the assembly. So they 
think that there must be some safety directive that applies (and was not 
tested for). They are checking with their factory (again).


On 1/4/2018 6:27 PM, Brent DeWitt wrote:


Hi Scott,

Which Directives do you think should apply?

*From:* Scott Douglas [mailto:sdouglas...@gmail.com]
*Sent:* Thursday, January 04, 2018 7:00 PM
*To:* EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* [PSES] CE Marking HDMI Cables

I am going around with an ODM making a HDMI cable for us. Standard 
cable just has our brand logo molded in the connector shell. Cable is 
to be used with Category 4 (ITE) Equipment and is sold separately.


The question is CE Marked or not CE Marked. I say it must be CE Marked 
and they say not required. I have been through the directives and FAQ 
more than a few times and it seems black and white to me.


They say they talked to three different compliance labs, at least one 
of which is familiar to a lot of us on the west coast, and all say not 
required. They say their compliance engineers all went to the required 
training and they all say not required.


Am I the only one that thinks these HDMI cables need to be CE Marked? 
Or am I missing something? Like maybe not required today but required 
to be marked at some future date like 2019 maybe?


Last, assuming I am not on some good psychedelics and CE Marking is 
required on or for HDMI cables, can I get away with putting the CE 
Mark on the single unit package, like a label on the poly bag it is 
sealed in?


I thank everybody that helps answer the question and keeps me from 
consuming more of those pink pills.


Happy New Year to all.

Scott

-


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emc-pstc discussion list. To post a message to the list, send your 
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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.


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list. To post a message to the list, send your e-mail to 

All emc-pstc postings are archived and searchable on the web at:
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http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Re: [PSES] CE Marking HDMI Cables

[Brent DeWitt]

Hi Scott,

 

Which Directives do you think should apply?

 

From: Scott Douglas [mailto:sdouglas...@gmail.com] 
Sent: Thursday, January 04, 2018 7:00 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE Marking HDMI Cables

 

 

I am going around with an ODM making a HDMI cable for us. Standard cable just 
has our brand logo molded in the connector shell. Cable is to be used with 
Category 4 (ITE) Equipment and is sold separately.

 

The question is CE Marked or not CE Marked. I say it must be CE Marked and they 
say not required. I have been through the directives and FAQ more than a few 
times and it seems black and white to me.

 

They say they talked to three different compliance labs, at least one of which 
is familiar to a lot of us on the west coast, and all say not required. They 
say their compliance engineers all went to the required training and they all 
say not required.

 

 

Am I the only one that thinks these HDMI cables need to be CE Marked? Or am I 
missing something? Like maybe not required today but required to be marked at 
some future date like 2019 maybe?

 

Last, assuming I am not on some good psychedelics and CE Marking is required on 
or for HDMI cables, can I get away with putting the CE Mark on the single unit 
package, like a label on the poly bag it is sealed in?

 

I thank everybody that helps answer the question and keeps me from consuming 
more of those pink pills.

 

Happy New Year to all.

Scott

 

-


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discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org> >

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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 
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<http://www.ieee-pses.org/list.html> 
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For help, send mail to the list administrators:
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For policy questions, send mail to:
Jim Bacher mailto:j.bac...@ieee.org> >
David Heald mailto:dhe...@gmail.com> > 


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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 


All emc-pstc postings are archived and searchable on the web at:
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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 
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Website:  http://www.ieee-pses.org/
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For help, send mail to the list administrators:
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Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

[PSES] CE Marking HDMI Cables

[Scott Douglas]

I am going around with an ODM making a HDMI cable for us. Standard cable
just has our brand logo molded in the connector shell. Cable is to be used
with Category 4 (ITE) Equipment and is sold separately.

The question is CE Marked or not CE Marked. I say it must be CE Marked and
they say not required. I have been through the directives and FAQ more than
a few times and it seems black and white to me.

They say they talked to three different compliance labs, at least one of
which is familiar to a lot of us on the west coast, and all say not
required. They say their compliance engineers all went to the required
training and they all say not required.


Am I the only one that thinks these HDMI cables need to be CE Marked? Or am
I missing something? Like maybe not required today but required to be
marked at some future date like 2019 maybe?

Last, assuming I am not on some good psychedelics and CE Marking is
required on or for HDMI cables, can I get away with putting the CE Mark on
the single unit package, like a label on the poly bag it is sealed in?

I thank everybody that helps answer the question and keeps me from
consuming more of those pink pills.

Happy New Year to all.
Scott

-

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 


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/
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David Heald: 

[PSES] looking for CE Marking and Consultation for user guide/Manual, packaging

[Chris]

We are looking for CE Marking and Consultation services for CE 
products.Consultant services can be in US or Europe.
Our products are Wifi AP and switch, RF expertise for CE products is preferred, 
User manual, Label, warning statements.
for more info you can find on https://www.ubnt.com/products/
Please get in touch with me offline to discuss further.
regards
Christopher
christopher.saleem@ubnt.comFCC Compliance ManagerSan Jose, CA 95128



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Re: [PSES] Address requirement of Product Label for CE Marking

[Inken Green]

Philip,

 

the „blue guide 2016“ states the following in this case:

 

“The address must indicate a single point at which the manufacturer can be 
contacted, in particular by market surveillance authorities. The legal text 
obliges the manufacturer to put a single contact point on the product. Only one 
single contact point in each product is allowed. This is not necessarily the 
address where the manufacturer is actually established. This address can for 
example be the one of the authorised representative or of the customer services.

 

The single contact point does not need to be in every Member State where the 
product is made available. The manufacturer may however put other addresses 
provided that it is clear which one is the single contact point. The latter is 
then to be indicated on the product/documentation as the ‘single contact 
point’. The address or the country does not necessarily have to be translated 
into the language of the Member State where the product is made available on 
the market but the characters of the language used must allow identifying the 
origin and the name of the company.” (see 4.2.2.1) 

 

The requirement to indicate the postal address on the product is traceability. 
The market surveillance authorities need a contact address of the manufacturer. 
  

 

I hope to have helped you with this.

 

Regards,

 

Inken Green
Volljuristin

Product Compliance
 
Globalnorm GmbH

Kurfürstenstr. 112

10787 Berlin

 

Büro Hamburg

Phone +49 40 84206535

Mail inken.gr...@globalnorm.de <mailto:inken.gr...@globalnorm.de> 

 

 <http://www.globalnorm.de/> » globalnorm.de

 <http://www.globalnorm.de/service/newsletter.html> » Jetzt anmelden zum 
GLOBALNORM Product Compliance Newsletter.

 

Globalnorm GmbH, Sitz der Gesellschaft: Kurfürstenstr. 112, 10787 Berlin

Geschäftsführer: Dipl.-Ing. Michael Loerzer

Amtsgericht Berlin-Charlottenburg HRB 105204 B, USt-ID-Nummer: DE251654448

 

 

 

From: Philip Stevenson [mailto:pw...@hotmail.co.uk] 
Sent: Tuesday, January 24, 2017 12:27 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] Address requirement of Product Label for CE Marking

 



Sent from my iPad


Begin forwarded message:

From: STEVENSON Philip mailto:philip.steven...@uk.thalesgroup.com> >
Date: 23 January 2017 14:56:13 GMT
To: "'EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> '" 
mailto:EMC-PSTC@listserv.ieee.org> >
Cc: STEVENSON Philip mailto:philip.steven...@uk.thalesgroup.com> >, "pw...@hotmail.co.uk 
<mailto:pw...@hotmail.co.uk> " mailto:pw...@hotmail.co.uk> >
Subject: Address requirement of Product Label for CE Marking 

Dear Members

 

I am writing to ask for your advice on what address should be listed on a 
Product label for CE Marking. The EMC Directive now states that “Manufacturers 
shall indicate, on the apparatus, their name, registered trade name or 
registered trade mark and the postal address at which they can be contacted  
etc.”.

 

I work a large organisation, which has a large number of divisions covering a 
various range of products. So is it the overall company’s “registered” address 
that should be placed on the product label or can it be the address of the 
division where it is manufactured, as this is where the Technical File is held. 

 

I would be grateful for the members help. If you would prefer to contact 
directly instead of via the listing my work Email address is 
philip.steven...@uk.thalesgroup.com 
<mailto:philip.steven...@uk.thalesgroup.com>  or my personal Hotmail address 
pw...@hotmail.co.uk <mailto:pw...@hotmail.co.uk>  .

 

 

 

Regards

 

Philip Stevenson
Senior Specialist Engineer - Electronics, Advanced Weapons, Belfast

Thales

Land & Air Systems
Alanbrooke Road, Belfast, Northern Ireland, BT6 9HB

 <http://www.thalesgroup.com/uk> www.thalesgroup.com/uk

Tel: +44 (0)28 90465665
e-mail: philip.steven...@uk.thalesgroup.com 
<mailto:philip.steven...@uk.thalesgroup.com> 

 

Please consider the environment before printing a hard copy of this email.

 

The information contained in this e-mail is confidential. It is intended only 
for the stated addressee(s) and access to it by any other person is 
unauthorised. If you are not an addressee, you must not disclose, copy, 
circulate or in any other way use or rely on the information contained in this 
e-mail. Such unauthorised use may be unlawful. If you have received this e-mail 
in error, please inform us immediately on +44 (0) [28 905200] and delete it and 
all copies from your system.

 

Thales UK Limited. A company registered in England and Wales. Registered 
Office: 2 Dashwood Lang Road, The Bourne Business Park, Addlestone, Weybridge, 
Surrey KT15 2NX. Registered Number: 868273

 

 

-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discuss

[PSES] Address requirement of Product Label for CE Marking

[Philip Stevenson]

Sent from my iPad

Begin forwarded message:

From: STEVENSON Philip 
mailto:philip.steven...@uk.thalesgroup.com>>
Date: 23 January 2017 14:56:13 GMT
To: "'EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>'" 
mailto:EMC-PSTC@listserv.ieee.org>>
Cc: STEVENSON Philip 
mailto:philip.steven...@uk.thalesgroup.com>>,
 "pw...@hotmail.co.uk<mailto:pw...@hotmail.co.uk>" 
mailto:pw...@hotmail.co.uk>>
Subject: Address requirement of Product Label for CE Marking

Dear Members

I am writing to ask for your advice on what address should be listed on a 
Product label for CE Marking. The EMC Directive now states that “Manufacturers 
shall indicate, on the apparatus, their name, registered trade name or 
registered trade mark and the postal address at which they can be contacted  
etc.”.

I work a large organisation, which has a large number of divisions covering a 
various range of products. So is it the overall company’s “registered” address 
that should be placed on the product label or can it be the address of the 
division where it is manufactured, as this is where the Technical File is held.

I would be grateful for the members help. If you would prefer to contact 
directly instead of via the listing my work Email address is 
philip.steven...@uk.thalesgroup.com<mailto:philip.steven...@uk.thalesgroup.com> 
or my personal Hotmail address pw...@hotmail.co.uk<mailto:pw...@hotmail.co.uk> .



Regards

Philip Stevenson
Senior Specialist Engineer - Electronics, Advanced Weapons, Belfast

Thales
Land & Air Systems
Alanbrooke Road, Belfast, Northern Ireland, BT6 9HB
www.thalesgroup.com/uk<http://www.thalesgroup.com/uk>

Tel: +44 (0)28 90465665
e-mail: 
philip.steven...@uk.thalesgroup.com<mailto:philip.steven...@uk.thalesgroup.com>
 

Please consider the environment before printing a hard copy of this email.

The information contained in this e-mail is confidential. It is intended only 
for the stated addressee(s) and access to it by any other person is 
unauthorised. If you are not an addressee, you must not disclose, copy, 
circulate or in any other way use or rely on the information contained in this 
e-mail. Such unauthorised use may be unlawful. If you have received this e-mail 
in error, please inform us immediately on +44 (0) [28 905200] and delete it and 
all copies from your system.

Thales UK Limited. A company registered in England and Wales. Registered 
Office: 2 Dashwood Lang Road, The Bourne Business Park, Addlestone, Weybridge, 
Surrey KT15 2NX. Registered Number: 868273



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[PSES] CE Marking on Inkjet Cartridge

[Jim Hulbert]

All - It is my understanding that an inkjet cartridge that contains an 
electronic chip is considered EEE and is therefore subject to RoHS and WEEE 
(and of course REACH).
1. Is my statement above regarding RoHS/WEEE correct?
2. Is it also considered "apparatus" under the EMC Directive?  I'm thinking no 
because it has no function on its own.
3. Does it require its own CE marking and Declaration of Conformity (at least 
for RoHS) if it provided exclusively as a consumable for use with professional 
equipment and is  not available on the general consumer market?  The user of 
the professional equipment obviously orders replacement cartridges as needed.

Your thoughts are appreciated.

Thanks.

Jim Hulbert




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http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
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Re: [PSES] EU Enforcement of CE Marking Directives

[Nick Williams]

http://ec.europa.eu/consumers/consumers_safety/safety_products/rapex/index_en.htm

> On 25 Aug 2016, at 21:45, Jim Hulbert  wrote:
> 
> Hi,
>  
> I am interested in understanding how stringent the enforcement of CE marking 
> directives is within the EU.  Is there someplace where we can find 
> enforcement actions that have been taken against companies for placing 
> products on the market that don’t fully meet the applicable Directives?   I 
> am most interested in the EMC, LVD, MD, and R&TTE Directives.
>  
> Thank you.
>  
> Jim Hulbert
>  
> 
> 

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Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] EU Enforcement of CE Marking Directives

[Charlie Blackham]

Jim

I'm not aware of any EU wide database other than Nando, but you can find 
details of UK Health & Safety Executive prosecutions at 
http://news.hse.gov.uk/category/about-hse/prosecution/ and a number of these 
include reference to non-compliance with the Machinery Directive.

You can find EU wide Market Surveillance reports for R&TTE on 
http://ec.europa.eu/growth/sectors/electrical-engineering/rtte-directive_en

Regards
Charlie

From: Jim Hulbert [mailto:jim.hulb...@pb.com]
Sent: 25 August 2016 21:46
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU Enforcement of CE Marking Directives

Hi,

I am interested in understanding how stringent the enforcement of CE marking 
directives is within the EU.  Is there someplace where we can find enforcement 
actions that have been taken against companies for placing products on the 
market that don't fully meet the applicable Directives?   I am most interested 
in the EMC, LVD, MD, and R&TTE Directives.

Thank you.

Jim Hulbert




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Re: [PSES] EU Enforcement of CE Marking Directives

[Chuck August-McDowell]

You might try the EU rapex database of products with removal / recalled from 
market (do not meet Directive requirements).
http://ec.europa.eu/consumers/consumers_safety/safety_products/rapex/alerts/main/?event=main.search#

Chuck McDowell
Compliance Specialist
Meyer Sound Laboratories Inc.
Direct: 510-540-4670

From: John Woodgate [mailto:jmw1...@btinternet.com]
Sent: Thursday, August 25, 2016 2:55 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU Enforcement of CE Marking Directives

The stringency, and the enforcement procedures, vary in the different Member 
States. For example, in Britain, prosecution is a last resort, because it is 
very costly and the outcome may be uncertain. But the authorities can be VERY 
persuasive. Non-compliant products are confiscated, and the thought of a future 
involving a watch on every new product introduction easily convinces 
manufacturers and importers that co-operation is the best policy.

With best wishes DESIGN IT IN! OOO - Own Opinions Only
www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk/> J M Woodgate and Associates 
Rayleigh England

Sylvae in aeternum manent.

From: Jim Hulbert [mailto:jim.hulb...@pb.com]
Sent: Thursday, August 25, 2016 9:46 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] EU Enforcement of CE Marking Directives

Hi,

I am interested in understanding how stringent the enforcement of CE marking 
directives is within the EU.  Is there someplace where we can find enforcement 
actions that have been taken against companies for placing products on the 
market that don't fully meet the applicable Directives?   I am most interested 
in the EMC, LVD, MD, and R&TTE Directives.

Thank you.

Jim Hulbert




-


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NOTICE: This email may contain confidential information.  Please see 
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Re: [PSES] EU Enforcement of CE Marking Directives

[John Woodgate]

The stringency, and the enforcement procedures, vary in the different Member
States. For example, in Britain, prosecution is a last resort, because it is
very costly and the outcome may be uncertain. But the authorities can be
VERY persuasive. Non-compliant products are confiscated, and the thought of
a future involving a watch on every new product introduction easily
convinces manufacturers and importers that co-operation is the best policy.
 
With best wishes DESIGN IT IN! OOO - Own Opinions Only
 <http://www.jmwa.demon.co.uk/> www.jmwa.demon.co.uk J M Woodgate and
Associates Rayleigh England
 
Sylvae in aeternum manent.
 
From: Jim Hulbert [mailto:jim.hulb...@pb.com] 
Sent: Thursday, August 25, 2016 9:46 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU Enforcement of CE Marking Directives
 
Hi,
 
I am interested in understanding how stringent the enforcement of CE marking
directives is within the EU.  Is there someplace where we can find
enforcement actions that have been taken against companies for placing
products on the market that don't fully meet the applicable Directives?   I
am most interested in the EMC, LVD, MD, and R&TTE Directives.
 
Thank you.
 
Jim Hulbert
 
 
  _  

 
-

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discussion list. To post a message to the list, send your e-mail to
mailto:emc-p...@ieee.org> >
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Attachments are not permitted but the IEEE PSES Online Communities site at
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formats), large files, etc.

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[PSES] EU Enforcement of CE Marking Directives

[Jim Hulbert]

Hi,

I am interested in understanding how stringent the enforcement of CE marking 
directives is within the EU.  Is there someplace where we can find enforcement 
actions that have been taken against companies for placing products on the 
market that don't fully meet the applicable Directives?   I am most interested 
in the EMC, LVD, MD, and R&TTE Directives.

Thank you.

Jim Hulbert





-

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discussion list. To post a message to the list, send your e-mail to 


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http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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Re: [PSES] CE Marking on Packaging of Assembly Components

[Carl Newton]

Thanks to all who responded to my post.  They've been very helpful.

Carl

On Thu, 27 Aug 2015 08:39:13 -0400, Carl Newton  wrote:


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



--
Using Opera's mail client: http://www.opera.com/mail/

-

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list. To post a message to the list, send your e-mail to 

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Re: [PSES] CE Marking on Packaging of Assembly Components

[Carl Newton]

Good feedback John.  Thanks very much.

Carl

On Thu, 27 Aug 2015 13:56:05 -0400, John Allen  
 wrote:



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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discussion list. To post a message to the list, send your e-mail to


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at

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For help, s

Re: [PSES] CE Marking on Packaging of Assembly Components

[Mark Schmidt]

I never said they did not need to be compliant. That wasn't the question or was 
it?

-Original Message-
From: John Woodgate [mailto:j...@jmwa.demon.co.uk] 
Sent: Thursday, August 27, 2015 2:03 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE Marking on Packaging of Assembly Components

In message <119fa9545c6e264b830c4582886d1190c534d...@quimby.dw.local>,
dated Thu, 27 Aug 2015, Mark Schmidt 
writes:

>In regard to your statement "Another package may include plastic panels 
>with no inherent standalone function" In this case there are no 
>harmonized standards that I am aware of for plastics so I will further 
>assume that no CE Mark is required.

But they are part of a finished product which may well have strength and other 
requirements for panels. So no need for a CE mark, but they need to be 
compliant with the product requirements.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk When I turn 
my back on the sun, it's to look for a rainbow John Woodgate, J M Woodgate and 
Associates, Rayleigh, Essex UK

-

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Re: [PSES] CE Marking on Packaging of Assembly Components

[John Woodgate]

In message <119fa9545c6e264b830c4582886d1190c534d...@quimby.dw.local>, 
dated Thu, 27 Aug 2015, Mark Schmidt  
writes:


In regard to your statement "Another package may include plastic panels 
with no inherent standalone function" In this case there are no 
harmonized standards that I am aware of for plastics so I will further 
assume that no CE Mark is required.


But they are part of a finished product which may well have strength and 
other requirements for panels. So no need for a CE mark, but they need 
to be compliant with the product requirements.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

-

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 

All emc-pstc postings are archived and searchable on the web at:
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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/
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Scott Douglas 
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For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] CE Marking on Packaging of Assembly Components

[John Allen]

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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Re: [PSES] CE Marking on Packaging of Assembly Components

[Mark Schmidt]

Carl,

In regard to your statement "Another package may include plastic panels with no 
inherent standalone function" In this case there are no harmonized standards 
that I am aware of for plastics so I will further assume that no CE Mark is 
required.

Mark Schmidt

-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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discussion list. To post a message to the list, send your e-mail to 


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formats), large files, etc.

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Re: [PSES] CE Marking on Packaging of Assembly Components

[Chuck McDowell]

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

-

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discussion list. To post a message to the list, send your e-mail to 


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http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used 
formats), large files, etc.

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NOTICE: This email may contain confidential information.  Please see 
http://www.meyersound.com/confidential/ for our complete policy.

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This m

Re: [PSES] CE Marking on Packaging of Assembly Components

[Nyffenegger, Dave]

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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discussion list. To post a message to the list, send your e-mail to 


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formats), large files, etc.

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Re: [PSES] CE Marking on Packaging of Assembly Components

[John Woodgate]

In message , dated Thu, 27 Aug 2015, Carl 
Newton  writes:


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?


At one time it was held that applying the CE mark to goods not requiring 
it was an offence, but I have not seen that cited recently, and it may 
be that it was a bit of 'gold plating' - something added in a particular 
Member State's implementation of the Directive -, or a misunderstanding.


You could consider putting on the package, 'These goods do not require 
the CE mark' (not using the stylized 'CE').

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] CE Marking on Packaging of Assembly Components

[Carl Newton]

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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Re: [PSES] Applicability of EU CE Marking Directive requirements on "free issue" Development Electrical Hardware

[John Woodgate]

In message 
<00f7c5386a83a3458bdbe29afca36358d83b3da...@thsonep02cmb01p.one-02-priv.g
rp>, dated Tue, 25 Aug 2015, STEVENSON Philip 
 writes:




So my question is, does the supplying ?development versions of a 
?product? to another UK company who also are working on the same 
contract to produce a final product for a UK customer outside the scope 
of the CE Marking directive or not? That is does it have to be CE 
Marked or not?


None of these items, including the control box, are 'placed on the 
market' but they are 'taken into service'. However, IF they do not cross 
any Member State borders, I can't see the authorities even knowing about 
them UNLESS an interference incident occurs. So I suggest you attend to 
the emissions and not be too concerned about formal marking.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
When I turn my back on the sun, it's to look for a rainbow
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] Applicability of EU CE Marking Directive requirements on "free issue" Development Electrical Hardware

[STEVENSON Philip]

Dear List Members

I am looking your guidance on whether the EU CE Marking Directive requirements 
are applicable or not to "products" build during the development lifecycle for 
its the design verification and qualification testing. These "development 
versions of the "product" will not be put on to the market place but will be 
supplied a partner company in the UK "free of charge" as an assembly for 
integration into the complete system to allow the qualification testing of the 
complete system to be carried out. The development complete system "will also 
not be put on to the marketplace" in the same context that is only to be used 
for design qualification testing purposes.

So my question is, does the supplying "development versions of a "product" to 
another UK company who also are working on the same contract to produce a final 
product for a UK customer outside the scope of the CE Marking directive or not? 
That is does it have to be CE Marked or not?

As part of our design process a safety assessment of "development versions of 
the "product"" is undertaken and the assessment documented. This assessment has 
to done and approved before it can be supplied to the partner company. The 
product being supplied has been assessed for CE Marking and only falls within 
the scope of the EMC Directive.

It is the intention for the production standard version of this  "product" to 
be CE Marked in accordance with the EU CE Marking Directive. That is before it 
is supplied to the customer.

To push my luck a bit further with getting advice from the membership I have a 
secondary question relating to simple "Control Box" that will only be supplied 
and used with "early development versions of a "product"" described above to 
control its operation during initial development testing. The "Control Box" 
consists of a Die-cast box with an input connector, output connector, two 
toggle switches and internal wiring. The "Control Box" simply receives a 24V dc 
input and connects this supply to the product. The Toggle Switches switch the 
24Vdc to control inputs on the product to control its mode of operation. As the 
"Control Box" as no "active" components I believe it can be considered as being 
"EMC Benign" and therefore outside the scope of the EMC directive. Therefore it 
doesn't need to be CE Marked. Does the membership agree with my assessment or 
not?
PS The 24Vdc supply is provided from COTS (CE Marked) Bench DC Power Supply.

All help and guidance will be greatly appreciated.


Regards

Philip Stevenson
Senior Specialist Engineer - Electronics, Advanced Weapons, Belfast

Thales
Land & Air Systems
Alanbrooke Road, Belfast, Northern Ireland, BT6 9HB
www.thalesgroup.com/uk<http://www.thalesgroup.com/uk>

Tel: +44 (0)28 90465665
e-mail: 
philip.steven...@uk.thalesgroup.com<mailto:philip.steven...@uk.thalesgroup.com>



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Re: [PSES] CE marking for handheld powered tools

[Mike Sherman ----- Original Message -----]

61029 might also be worth a look. TC 116 is also working on a similar 62841 series. MikeSent from Xfinity Connect Mobile App-- Original Message --From: Ted EckertTo: EMC-PSTC@LISTSERV.IEEE.ORGSent: June 5, 2015 at 3:46 PMSubject: Re: [PSES] CE marking for handheld powered tools



Hello Pete,
 
Hand-held power tools would fall under the 2006/42/EC Machinery Directive for safety. IEC 60745-1 and the associated part 2 standards are the harmonized standards for hand-held electric power tools under this Directive. Pneumatic hand-held
 tools should be covered by EN ISO 11148 series standards, also harmonized under the Machinery Directive. You will also want to look at EN ISO 28927 which covers vibration of hand-held power tools. The EMC Directive should still apply to the electric tools.
 (I am presuming that these are not fancy tools with Bluetooth or other radios.)
 
Regards,
Ted Eckert
Compliance Engineer
Microsoft Corporation
ted.eck...@microsoft.com
 
The opinions expressed are my own and do not necessarily reflect those of my employer.
 
-Original Message-
From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org] 
Sent: Friday, June 5, 2015 11:14 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE marking for handheld powered tools
 
PSNetters:
 
    Looking to clarify the CE marking requirements for handheld powered tools - such as I've seen roofers use for nailing down shingles.  Could be either electrical or pneumatic powered but hand positioned then triggered
 to work.  
 
    Thanx in advance for your comments.  

 
:>) br, Pete

Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201 fone/fax
p.perk...@ieee.org

 
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Re: [PSES] CE marking for handheld powered tools

[Ted Eckert]

Hello Pete,



Hand-held power tools would fall under the 2006/42/EC Machinery Directive for 
safety. IEC 60745-1 and the associated part 2 standards are the harmonized 
standards for hand-held electric power tools under this Directive. Pneumatic 
hand-held tools should be covered by EN ISO 11148 series standards, also 
harmonized under the Machinery Directive. You will also want to look at EN ISO 
28927 which covers vibration of hand-held power tools. The EMC Directive should 
still apply to the electric tools. (I am presuming that these are not fancy 
tools with Bluetooth or other radios.)



Regards,
Ted Eckert
Compliance Engineer
Microsoft Corporation
ted.eck...@microsoft.com<mailto:ted.eck...@microsoft.com>

The opinions expressed are my own and do not necessarily reflect those of my 
employer.


-Original Message-
From: Pete Perkins [mailto:0061f3f32d0c-dmarc-requ...@ieee.org]
Sent: Friday, June 5, 2015 11:14 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE marking for handheld powered tools



PSNetters:



Looking to clarify the CE marking requirements for handheld 
powered tools - such as I've seen roofers use for nailing down shingles.  Could 
be either electrical or pneumatic powered but hand positioned then triggered to 
work.



Thanx in advance for your comments.



:>) br, Pete

Peter E Perkins, PE

Principal Product Safety Engineer

PO Box 23427

Tigard, ORe  97281-3427

503/452-1201 fone/fax

p.perk...@ieee.org<mailto:p.perk...@ieee.org>



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[PSES] CE marking for handheld powered tools

[Pete Perkins]

PSNetters:

Looking to clarify the CE marking requirements for handheld powered
tools - such as I've seen roofers use for nailing down shingles.  Could be
either electrical or pneumatic powered but hand positioned then triggered to
work.  

Thanx in advance for your comments.  

:>) br, Pete
 
Peter E Perkins, PE
Principal Product Safety Engineer
PO Box 23427
Tigard, ORe  97281-3427
 
503/452-1201 fone/fax
p.perk...@ieee.org
 

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Re: [PSES] Next basic standards for CE marking?

[John Woodgate]

In message <00c701cff1c3$0a8ca560$1fa5f020$@westin-emission.no>, dated 
Mon, 27 Oct 2014, Amund Westin  writes:


Today, the basic standards 61000-4-2, -3, -4, -5, -6, -8, -11 are 
referred to in Cenelec generic standards or various product standards. 
But, there exist a range of other basic standards for other EMC 
phenomena.


Anybody who knows which will be the next standard to be included for CE 
marking?


The Generics have only recently been revised, so no change is likely 
there. This practically means no new emission standards. For immunity 
standards, it is up to individual product committees to call up new 
immunity standards in the EMC clauses of their product standards or in 
their stand-alone EMC standards, if they think it's necessary.


For example, TC34 has just produced IEC TR 61547-1 Ed. 1: Equipment for 
general lighting purposes – EMC immunity - Part 1:

An objective voltage fluctuation immunity test method

Of course, it's a TR on a method of measurement, not setting immunity 
requirements, and thus cannot be notified in the OJ under the EMC 
Directive. But a new standard with requirements could be.

--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Quid faciamus nisi sit?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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[PSES] Next basic standards for CE marking?

[Amund Westin]

Today, the basic standards 61000-4-2, -3, -4, -5, -6, -8, -11 are referred
to in Cenelec generic standards or various product standards.
But, there exist a range of other basic standards for other EMC phenomena.

Anybody who knows which will be the next standard to be included for CE
marking?

#Amund

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[PSES] Article on CE Marking Wire and Cable products

[Douglas Nix]

Colleagues,

I just published a couple of new articles on the Machinery Safety 101 blog on 
CE Marking of wire and cable products. Thanks go to those that contributed to 
the research on this topic. As always comments, questions and corrections are 
welcomed!

http://machinerysafety101.com/2013/12/20/five-things-you-need-to-know-about-ce-marked-wire-and-cable/
http://machinerysafety101.com/2013/12/20/ce-marking-wire-and-cable-necessity-or-luxury/

Happy Holidays to all, and a Prosperous New Year for 2014!

Doug Nix
d...@ieee.org
+1 (519) 729-5704

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