RE: Application of CE Mark
How about printing a picture, on the box, of your product, with a close-up of the CE marking as it was placed on the product? That way the "CE" could appear prominently on the packaging, but it shouldn't be confused with referring to compliance of the packaging itself. Ed Ed Price ed.pr...@cubic.com Electromagnetic Compatibility Lab Cubic Defense Systems San Diego, CA. USA 858-505-2780 (Voice) 858-505-1583 (Fax) Military & Avionics EMC Services Is Our Specialty Shake-Bake-Shock - Metrology - Reliability Analysis -Original Message- From: CE-test - Ing. Gert Gremmen - ce-marking and more... [mailto:cet...@cetest.nl] Sent: Friday, December 15, 2000 11:35 AM To: Lou Guerin; wo...@sensormatic.com; emc-p...@majordomo.ieee.org Subject: RE: Application of CE Mark Exactly, this was a hypothetical discussion anyway. Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === >>-Original Message- >>From: Lou Guerin [mailto:lgue...@littlefeet-inc.com] >>Sent: Friday, December 15, 2000 6:35 PM >>To: 'CE-test - Ing. Gert Gremmen - ce-marking and more...'; >>wo...@sensormatic.com; emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >> >>I just finished reading through the proposed new EMC Directive >>(EMCD 2000.5) >>and it says under Annex II, CE conformity marking, >>"The CE marking must be affixed to the product or to its data >>plate, unless >>it is not possible under reasonable technical conditions. Additionally it >>must be affixed to the packaging, if any, and to the accompanying >>documents." >> >>So, once the new EMC Directive is released, you will need to have the CE >>mark on the packaging. You might as well start now since it is not >>forbidden. >>Just my two cents worth. >>Lou Guerin >>Agency Approvals Manager >>Littlefeet, Inc. >> >>Normal disclaimers absolving my employer from responsibility for >>my remarks. >> >> -Original Message- >>From: CE-test - Ing. Gert Gremmen - ce-marking and more... >>[mailto:cet...@cetest.nl] >>Sent: Friday, December 15, 2000 6:22 AM >>To: wo...@sensormatic.com; emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >> << File: Gert Gremmen.vcf >> Hello Richard, Cyril and group, >> >>Simply: there is no directive allowing the use of ce to boxes. >> >>The statement in the EMC-directive is: >> >>The manufacturer or his authorized representative established within the >>Community shall also affix the EC conformity mark to the apparatus or else >>to the packaging, instructions for use or guarantee certificate. >> >>It's written "or else" which implies that if the product is marked, the >>packaging et al may not. >>or else >>if the box is marked , the product may not ! >> >>Further more is says: THE packaging only, not A packaging, which limits >>the application to a specific box, contains the apparatus. >> >>In practice, wherever no misunderstanding is possible, ce marking all kind >>of >>packaging is tolerated, and can be helpful in customs procedures. >> >>I agree that this is a trivial thing, but what would the judge say ?? >> >>What would you read if it said: >> >>One of these guys will be president of the USA : Bush or else Al Gore ? >>Would you elect both for president ? (you almost did , isn't it? :<)) >> >>Regards, >> >>Gert Gremmen, (Ing) >> >>ce-test, qualified testing >> >>=== >>Web presence http://www.cetest.nl >>CE-shop http://www.cetest.nl/ce_shop.htm >>/-/ Compliance testing is our core business /-/ >>=== >> >> >>>>-Original Message- >>>>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf >>>>Of wo...@sensormatic.com >>>>Sent: Friday, December 15, 2000 2:25 PM >>>>To: emc-p...@majordomo.ieee.org >>>>Subject: RE: Application of CE Mark >>>> >>>> >>>> >>>>It is news to me that placing the CE marking on packaging is >>forbidden if >>>>the directive does not specify the marking? Where did you find this >>>>information? >>>> >>>>Richard Woods >>&
RE: Application of CE Mark
Exactly, this was a hypothetical discussion anyway. Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === >>-Original Message- >>From: Lou Guerin [mailto:lgue...@littlefeet-inc.com] >>Sent: Friday, December 15, 2000 6:35 PM >>To: 'CE-test - Ing. Gert Gremmen - ce-marking and more...'; >>wo...@sensormatic.com; emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >> >>I just finished reading through the proposed new EMC Directive >>(EMCD 2000.5) >>and it says under Annex II, CE conformity marking, >>"The CE marking must be affixed to the product or to its data >>plate, unless >>it is not possible under reasonable technical conditions. Additionally it >>must be affixed to the packaging, if any, and to the accompanying >>documents." >> >>So, once the new EMC Directive is released, you will need to have the CE >>mark on the packaging. You might as well start now since it is not >>forbidden. >>Just my two cents worth. >>Lou Guerin >>Agency Approvals Manager >>Littlefeet, Inc. >> >>Normal disclaimers absolving my employer from responsibility for >>my remarks. >> >> -Original Message- >>From: CE-test - Ing. Gert Gremmen - ce-marking and more... >>[mailto:cet...@cetest.nl] >>Sent: Friday, December 15, 2000 6:22 AM >>To: wo...@sensormatic.com; emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >> << File: Gert Gremmen.vcf >> Hello Richard, Cyril and group, >> >>Simply: there is no directive allowing the use of ce to boxes. >> >>The statement in the EMC-directive is: >> >>The manufacturer or his authorized representative established within the >>Community shall also affix the EC conformity mark to the apparatus or else >>to the packaging, instructions for use or guarantee certificate. >> >>It's written "or else" which implies that if the product is marked, the >>packaging et al may not. >>or else >>if the box is marked , the product may not ! >> >>Further more is says: THE packaging only, not A packaging, which limits >>the application to a specific box, contains the apparatus. >> >>In practice, wherever no misunderstanding is possible, ce marking all kind >>of >>packaging is tolerated, and can be helpful in customs procedures. >> >>I agree that this is a trivial thing, but what would the judge say ?? >> >>What would you read if it said: >> >>One of these guys will be president of the USA : Bush or else Al Gore ? >>Would you elect both for president ? (you almost did , isn't it? :<)) >> >>Regards, >> >>Gert Gremmen, (Ing) >> >>ce-test, qualified testing >> >>======= >>Web presence http://www.cetest.nl >>CE-shop http://www.cetest.nl/ce_shop.htm >>/-/ Compliance testing is our core business /-/ >>=== >> >> >>>>-Original Message- >>>>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf >>>>Of wo...@sensormatic.com >>>>Sent: Friday, December 15, 2000 2:25 PM >>>>To: emc-p...@majordomo.ieee.org >>>>Subject: RE: Application of CE Mark >>>> >>>> >>>> >>>>It is news to me that placing the CE marking on packaging is >>forbidden if >>>>the directive does not specify the marking? Where did you find this >>>>information? >>>> >>>>Richard Woods >>>> >>>>-- >>>>From: CE-test - Ing. Gert Gremmen - ce-marking and more... >>>>[SMTP:cet...@cetest.nl] >>>>Sent: Friday, December 15, 2000 2:21 AM >>>>To: Praveen Rao; 'Nick Williams'; binno...@ems-t.com >>>>Cc: emc-p...@majordomo.ieee.org >>>>Subject: RE: Application of CE Mark >>>> >>>>Hi Praveen, >>>> >>>>I would even attenuate that last statement. Officially the >>>>application of ce >>>>on boxes is forbidden so affixing "ce" would be just an invitation to >>>>search into the boxes >>>>:<)) >>>> >>>>I think it should make just no difference to customs if you do or do not >>>>affix the sign, but >>>>as they are human too. >>>> >>>>Regards, >>>> >>>>Gert Gremmen, (Ing) >>>> >>>>ce-test, qualified testing >>>> >>>> >>>> >>>> >>>>--- >>>>This message is from the IEEE EMC Society Product Safety >>>>Technical Committee emc-pstc discussion list. >>>> >>>>To cancel your subscription, send mail to: >>>> majord...@ieee.org >>>>with the single line: >>>> unsubscribe emc-pstc >>>> >>>>For help, send mail to the list administrators: >>>> Jim Bacher: jim_bac...@mail.monarch.com >>>> Michael Garretson:pstc_ad...@garretson.org >>>> >>>>For policy questions, send mail to: >>>> Richard Nute: ri...@ieee.org >>>> >>>> >> <>
RE: Application of CE Mark
The R&TTE directive as interpreted by the notified bodies requires CE marking on the product, the installation instructions, AND (not OR) the carton. David -Original Message- From: Maxwell, Chris [mailto:chr...@gnlp.com] Sent: Friday, December 15, 2000 11:54 AM To: 'wo...@sensormatic.com'; emc-p...@majordomo.ieee.org Subject: RE: Application of CE Mark Let's look at this from the point of view of a customs officer. Would I trust a box just because it has a CE mark on it? If I were a customs officer and I trusted every box that came through with a CE mark on it, I would be inviting smuggling. People could be smugglling God knows what into my country simply by using a CE marked box. So, if we put CE marks on all of our packages, I don't think that it guarantees that they won't be opened.I would assume that if customs officials were doing their jobs, they would be spot checking CE marked boxes and non-CE marked boxes. Maybe there is a lower probability of checking a CE marked box? If I were a customs officer and I opened a package. I would want to be able to clearly tell that the CE mark that I see applies to the product in the package. After all, couldn't somebody be simply re-using a CE marked box to ship something else? Even so, Chapter 12 of my version of The Guidelines on the Application of The EMC Directive state that the CE mark must be affixed on the product, if possible. If that isn't possible it allows the PACKAGING, instructions for use and the guarantee certificate in that order of priority. So, while CE marking boxes may not be forbidden (for the EMC Directive anyway), it certainly may be ineffective for the reasons that I mentioned above. Deciding where to mark should be applied in a case by case basis using common sense to figure out the best way to associate the CE mark with the product that it applies to. It seems that CENELEC already thought of this and that's why they gave us options listed in the guidelines document. Consider a basketball shipped in the typical three sided box. It may be CE marked on its "box" effectively because a customs official could see the CE mark on the package and see the product all without opening the "box". (For those unfamiliar with basketball packaging, they usually arrive in the store in a box with one-side partially open so the customer can see the ball.) Now consider a large box labelled as a handheld medical device. It's a great big, closed box with CE marks all over it, yet it smells like marijuana. (I myself wouldn't have the faintest idea what it smells like :-). If I was a customs official, maybe I'd decide to take a peek. If I opened the box only to find a bunch of marijuana, would I assume that this is alright to ship just because the box was CE marked? Happy holidays! Chris > -Original Message- > From: wo...@sensormatic.com [SMTP:wo...@sensormatic.com] > Sent: Friday, December 15, 2000 8:25 AM > To: emc-p...@majordomo.ieee.org > Subject: RE: Application of CE Mark > > > It is news to me that placing the CE marking on packaging is forbidden if > the directive does not specify the marking? Where did you find this > information? > > Richard Woods > > -- > From: CE-test - Ing. Gert Gremmen - ce-marking and more... > [SMTP:cet...@cetest.nl] > Sent: Friday, December 15, 2000 2:21 AM > To: Praveen Rao; 'Nick Williams'; binno...@ems-t.com > Cc: emc-p...@majordomo.ieee.org > Subject: RE: Application of CE Mark > > Hi Praveen, > > I would even attenuate that last statement. Officially the application of > ce > on boxes is forbidden so affixing "ce" would be just an invitation to > search into the boxes > :<)) > > I think it should make just no difference to customs if you do or do not > affix the sign, but > as they are human too. > > Regards, > > Gert Gremmen, (Ing) > > ce-test, qualified testing > > > > > --- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > To cancel your subscription, send mail to: > majord...@ieee.org > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Jim Bacher: jim_bac...@mail.monarch.com > Michael Garretson:pstc_ad...@garretson.org > > For policy questions, send mail to: > Richard Nute: ri...@ieee.org > --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single
RE: Application of CE Mark
I just finished reading through the proposed new EMC Directive (EMCD 2000.5) and it says under Annex II, CE conformity marking, "The CE marking must be affixed to the product or to its data plate, unless it is not possible under reasonable technical conditions. Additionally it must be affixed to the packaging, if any, and to the accompanying documents." So, once the new EMC Directive is released, you will need to have the CE mark on the packaging. You might as well start now since it is not forbidden. Just my two cents worth. Lou Guerin Agency Approvals Manager Littlefeet, Inc. Normal disclaimers absolving my employer from responsibility for my remarks. -Original Message- From: CE-test - Ing. Gert Gremmen - ce-marking and more... [mailto:cet...@cetest.nl] Sent: Friday, December 15, 2000 6:22 AM To: wo...@sensormatic.com; emc-p...@majordomo.ieee.org Subject: RE: Application of CE Mark << File: Gert Gremmen.vcf >> Hello Richard, Cyril and group, Simply: there is no directive allowing the use of ce to boxes. The statement in the EMC-directive is: The manufacturer or his authorized representative established within the Community shall also affix the EC conformity mark to the apparatus or else to the packaging, instructions for use or guarantee certificate. It's written "or else" which implies that if the product is marked, the packaging et al may not. or else if the box is marked , the product may not ! Further more is says: THE packaging only, not A packaging, which limits the application to a specific box, contains the apparatus. In practice, wherever no misunderstanding is possible, ce marking all kind of packaging is tolerated, and can be helpful in customs procedures. I agree that this is a trivial thing, but what would the judge say ?? What would you read if it said: One of these guys will be president of the USA : Bush or else Al Gore ? Would you elect both for president ? (you almost did , isn't it? :<)) Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === >>-Original Message- >>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf >>Of wo...@sensormatic.com >>Sent: Friday, December 15, 2000 2:25 PM >>To: emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >> >> >>It is news to me that placing the CE marking on packaging is forbidden if >>the directive does not specify the marking? Where did you find this >>information? >> >>Richard Woods >> >>-- >>From: CE-test - Ing. Gert Gremmen - ce-marking and more... >>[SMTP:cet...@cetest.nl] >>Sent: Friday, December 15, 2000 2:21 AM >>To: Praveen Rao; 'Nick Williams'; binno...@ems-t.com >>Cc: emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >>Hi Praveen, >> >>I would even attenuate that last statement. Officially the >>application of ce >>on boxes is forbidden so affixing "ce" would be just an invitation to >>search into the boxes >>:<)) >> >>I think it should make just no difference to customs if you do or do not >>affix the sign, but >>as they are human too. >> >>Regards, >> >>Gert Gremmen, (Ing) >> >>ce-test, qualified testing >> >> >> >> >>--- >>This message is from the IEEE EMC Society Product Safety >>Technical Committee emc-pstc discussion list. >> >>To cancel your subscription, send mail to: >> majord...@ieee.org >>with the single line: >> unsubscribe emc-pstc >> >>For help, send mail to the list administrators: >> Jim Bacher: jim_bac...@mail.monarch.com >> Michael Garretson:pstc_ad...@garretson.org >> >>For policy questions, send mail to: >> Richard Nute: ri...@ieee.org >> >> --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Application of CE Mark
Let's look at this from the point of view of a customs officer. Would I trust a box just because it has a CE mark on it? If I were a customs officer and I trusted every box that came through with a CE mark on it, I would be inviting smuggling. People could be smugglling God knows what into my country simply by using a CE marked box. So, if we put CE marks on all of our packages, I don't think that it guarantees that they won't be opened.I would assume that if customs officials were doing their jobs, they would be spot checking CE marked boxes and non-CE marked boxes. Maybe there is a lower probability of checking a CE marked box? If I were a customs officer and I opened a package. I would want to be able to clearly tell that the CE mark that I see applies to the product in the package. After all, couldn't somebody be simply re-using a CE marked box to ship something else? Even so, Chapter 12 of my version of The Guidelines on the Application of The EMC Directive state that the CE mark must be affixed on the product, if possible. If that isn't possible it allows the PACKAGING, instructions for use and the guarantee certificate in that order of priority. So, while CE marking boxes may not be forbidden (for the EMC Directive anyway), it certainly may be ineffective for the reasons that I mentioned above. Deciding where to mark should be applied in a case by case basis using common sense to figure out the best way to associate the CE mark with the product that it applies to. It seems that CENELEC already thought of this and that's why they gave us options listed in the guidelines document. Consider a basketball shipped in the typical three sided box. It may be CE marked on its "box" effectively because a customs official could see the CE mark on the package and see the product all without opening the "box". (For those unfamiliar with basketball packaging, they usually arrive in the store in a box with one-side partially open so the customer can see the ball.) Now consider a large box labelled as a handheld medical device. It's a great big, closed box with CE marks all over it, yet it smells like marijuana. (I myself wouldn't have the faintest idea what it smells like :-). If I was a customs official, maybe I'd decide to take a peek. If I opened the box only to find a bunch of marijuana, would I assume that this is alright to ship just because the box was CE marked? Happy holidays! Chris > -Original Message- > From: wo...@sensormatic.com [SMTP:wo...@sensormatic.com] > Sent: Friday, December 15, 2000 8:25 AM > To: emc-p...@majordomo.ieee.org > Subject: RE: Application of CE Mark > > > It is news to me that placing the CE marking on packaging is forbidden if > the directive does not specify the marking? Where did you find this > information? > > Richard Woods > > -- > From: CE-test - Ing. Gert Gremmen - ce-marking and more... > [SMTP:cet...@cetest.nl] > Sent: Friday, December 15, 2000 2:21 AM > To: Praveen Rao; 'Nick Williams'; binno...@ems-t.com > Cc: emc-p...@majordomo.ieee.org > Subject: RE: Application of CE Mark > > Hi Praveen, > > I would even attenuate that last statement. Officially the application of > ce > on boxes is forbidden so affixing "ce" would be just an invitation to > search into the boxes > :<)) > > I think it should make just no difference to customs if you do or do not > affix the sign, but > as they are human too. > > Regards, > > Gert Gremmen, (Ing) > > ce-test, qualified testing > > > > > --- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > To cancel your subscription, send mail to: > majord...@ieee.org > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Jim Bacher: jim_bac...@mail.monarch.com > Michael Garretson:pstc_ad...@garretson.org > > For policy questions, send mail to: > Richard Nute: ri...@ieee.org > --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Application of CE Mark
Hello group! Since some test houses supply DoCs with the CE marking on them, it made me wonder why they would recommend a marking in at least two places (device and DoC) if it were forbidden. I referenced the EMCD Application Guidelines. While I realize this is not the last word on the law, it seems clear to me that markings on boxes are not only appropriate, but encouraged. Section 12 is included in its entirety for your edification. 12 APPARATUS MARKING All apparatus covered by the Directive in accordance with the protection requirements and accompanied by one of the means of certification provided for in Article 10 must bear the CE marking. The CE marking is affixed by the manufacturer or his authorised representative established within the EEA to the apparatus or, if this is not possible, to the packaging, instructions for use or guarantee certificate, in that order of priority . Where the apparatus is covered by other Directives providing for the CE marking, application of the CE marking also indicates that the apparatus conforms to the provisions of the other Directives applicable to it. The CE marking is to be affixed visibly, legibly and indelibly. It is prohibited to affix any marks or inscriptions that are likely to mislead third parties as to the verbal or pictorial significance of the CE conformity marking. It would be sensible, but it is not mandatory, to more readily facilitate free movement to affix the CE marking to more than one place, for example, marking the outer packaging, as well as the apparatus inside can be ascertained without opening the package. There is nothing in the Directive to prevent this. Regards, Fabian Spadaccini TA Instruments-Waters LLC (p) 302-427-4189 (f) 302-427-4081 fspadacc...@tainst.com www.tainst.com -Original Message- From: CE-test - Ing. Gert Gremmen - ce-marking and more... [mailto:cet...@cetest.nl] Sent: Friday, December 15, 2000 9:22 AM To: wo...@sensormatic.com; emc-p...@majordomo.ieee.org Subject: RE: Application of CE Mark Hello Richard, Cyril and group, Simply: there is no directive allowing the use of ce to boxes. The statement in the EMC-directive is: The manufacturer or his authorized representative established within the Community shall also affix the EC conformity mark to the apparatus or else to the packaging, instructions for use or guarantee certificate. It's written "or else" which implies that if the product is marked, the packaging et al may not. or else if the box is marked , the product may not ! Further more is says: THE packaging only, not A packaging, which limits the application to a specific box, contains the apparatus. In practice, wherever no misunderstanding is possible, ce marking all kind of packaging is tolerated, and can be helpful in customs procedures. I agree that this is a trivial thing, but what would the judge say ?? What would you read if it said: One of these guys will be president of the USA : Bush or else Al Gore ? Would you elect both for president ? (you almost did , isn't it? :<)) Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === >>-Original Message- >>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf >>Of wo...@sensormatic.com >>Sent: Friday, December 15, 2000 2:25 PM >>To: emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >> >> >>It is news to me that placing the CE marking on packaging is forbidden if >>the directive does not specify the marking? Where did you find this >>information? >> >>Richard Woods >> >>-- >>From: CE-test - Ing. Gert Gremmen - ce-marking and more... >>[SMTP:cet...@cetest.nl] >>Sent: Friday, December 15, 2000 2:21 AM >>To: Praveen Rao; 'Nick Williams'; binno...@ems-t.com >>Cc: emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >>Hi Praveen, >> >>I would even attenuate that last statement. Officially the >>application of ce >>on boxes is forbidden so affixing "ce" would be just an invitation to >>search into the boxes >>:<)) >> >>I think it should make just no difference to customs if you do or do not >>affix the sign, but >>as they are human too. >> >>Regards, >> >>Gert Gremmen, (Ing) >> >>ce-test, qualified testing >> >> >> >> >>--- >>This message is from the IEEE EMC Society Product Safety >>Technical Committee emc-pstc discussion list. >>
RE: Application of CE Mark
I see absolutely no reason why both box and product can't be marked. I suspect this is just poor use of language in the directive. As for judges, look what the judge said in Florida. Hey, let's put this one to the vote.. I demand a recount before we start. Chris -Original Message- From: CE-test - Ing. Gert Gremmen - ce-marking and more... [mailto:cet...@cetest.nl] Sent: 15 December 2000 14:22 To: wo...@sensormatic.com; emc-p...@majordomo.ieee.org Subject: RE: Application of CE Mark Hello Richard, Cyril and group, Simply: there is no directive allowing the use of ce to boxes. The statement in the EMC-directive is: The manufacturer or his authorized representative established within the Community shall also affix the EC conformity mark to the apparatus or else to the packaging, instructions for use or guarantee certificate. It's written "or else" which implies that if the product is marked, the packaging et al may not. or else if the box is marked , the product may not ! Further more is says: THE packaging only, not A packaging, which limits the application to a specific box, contains the apparatus. In practice, wherever no misunderstanding is possible, ce marking all kind of packaging is tolerated, and can be helpful in customs procedures. I agree that this is a trivial thing, but what would the judge say ?? What would you read if it said: One of these guys will be president of the USA : Bush or else Al Gore ? Would you elect both for president ? (you almost did , isn't it? :<)) Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === >>-Original Message- >>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf >>Of wo...@sensormatic.com >>Sent: Friday, December 15, 2000 2:25 PM >>To: emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >> >> >>It is news to me that placing the CE marking on packaging is forbidden if >>the directive does not specify the marking? Where did you find this >>information? >> >>Richard Woods >> >>-- >>From: CE-test - Ing. Gert Gremmen - ce-marking and more... >>[SMTP:cet...@cetest.nl] >>Sent: Friday, December 15, 2000 2:21 AM >>To: Praveen Rao; 'Nick Williams'; binno...@ems-t.com >>Cc: emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >>Hi Praveen, >> >>I would even attenuate that last statement. Officially the >>application of ce >>on boxes is forbidden so affixing "ce" would be just an invitation to >>search into the boxes >>:<)) >> >>I think it should make just no difference to customs if you do or do not >>affix the sign, but >>as they are human too. >> >>Regards, >> >>Gert Gremmen, (Ing) >> >>ce-test, qualified testing >> >> >> >> >>--- >>This message is from the IEEE EMC Society Product Safety >>Technical Committee emc-pstc discussion list. >> >>To cancel your subscription, send mail to: >> majord...@ieee.org >>with the single line: >> unsubscribe emc-pstc >> >>For help, send mail to the list administrators: >> Jim Bacher: jim_bac...@mail.monarch.com >> Michael Garretson:pstc_ad...@garretson.org >> >>For policy questions, send mail to: >> Richard Nute: ri...@ieee.org >> >> --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Application of CE Mark
... in the beginning it was actively encouraged to mark the packaging with CE. In addition if your product is too small to CE mark then marking the packaging is the correct method of marking.. Chris James -Original Message- From: wo...@sensormatic.com [mailto:wo...@sensormatic.com] Sent: 15 December 2000 13:25 To: emc-p...@majordomo.ieee.org Subject: RE: Application of CE Mark It is news to me that placing the CE marking on packaging is forbidden if the directive does not specify the marking? Where did you find this information? Richard Woods -- From: CE-test - Ing. Gert Gremmen - ce-marking and more... [SMTP:cet...@cetest.nl] Sent: Friday, December 15, 2000 2:21 AM To: Praveen Rao; 'Nick Williams'; binno...@ems-t.com Cc: emc-p...@majordomo.ieee.org Subject: RE: Application of CE Mark Hi Praveen, I would even attenuate that last statement. Officially the application of ce on boxes is forbidden so affixing "ce" would be just an invitation to search into the boxes :<)) I think it should make just no difference to customs if you do or do not affix the sign, but as they are human too. Regards, Gert Gremmen, (Ing) ce-test, qualified testing --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Application of CE Mark
Hello Richard, Cyril and group, Simply: there is no directive allowing the use of ce to boxes. The statement in the EMC-directive is: The manufacturer or his authorized representative established within the Community shall also affix the EC conformity mark to the apparatus or else to the packaging, instructions for use or guarantee certificate. It's written "or else" which implies that if the product is marked, the packaging et al may not. or else if the box is marked , the product may not ! Further more is says: THE packaging only, not A packaging, which limits the application to a specific box, contains the apparatus. In practice, wherever no misunderstanding is possible, ce marking all kind of packaging is tolerated, and can be helpful in customs procedures. I agree that this is a trivial thing, but what would the judge say ?? What would you read if it said: One of these guys will be president of the USA : Bush or else Al Gore ? Would you elect both for president ? (you almost did , isn't it? :<)) Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === >>-Original Message- >>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf >>Of wo...@sensormatic.com >>Sent: Friday, December 15, 2000 2:25 PM >>To: emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >> >> >>It is news to me that placing the CE marking on packaging is forbidden if >>the directive does not specify the marking? Where did you find this >>information? >> >>Richard Woods >> >>-- >>From: CE-test - Ing. Gert Gremmen - ce-marking and more... >>[SMTP:cet...@cetest.nl] >>Sent: Friday, December 15, 2000 2:21 AM >>To: Praveen Rao; 'Nick Williams'; binno...@ems-t.com >>Cc: emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >>Hi Praveen, >> >>I would even attenuate that last statement. Officially the >>application of ce >>on boxes is forbidden so affixing "ce" would be just an invitation to >>search into the boxes >>:<)) >> >>I think it should make just no difference to customs if you do or do not >>affix the sign, but >>as they are human too. >> >>Regards, >> >>Gert Gremmen, (Ing) >> >>ce-test, qualified testing >> >> >> >> >>--- >>This message is from the IEEE EMC Society Product Safety >>Technical Committee emc-pstc discussion list. >> >>To cancel your subscription, send mail to: >> majord...@ieee.org >>with the single line: >> unsubscribe emc-pstc >> >>For help, send mail to the list administrators: >> Jim Bacher: jim_bac...@mail.monarch.com >> Michael Garretson:pstc_ad...@garretson.org >> >>For policy questions, send mail to: >> Richard Nute: ri...@ieee.org >> >> <>
RE: Application of CE Mark
It is news to me that placing the CE marking on packaging is forbidden if the directive does not specify the marking? Where did you find this information? Richard Woods -- From: CE-test - Ing. Gert Gremmen - ce-marking and more... [SMTP:cet...@cetest.nl] Sent: Friday, December 15, 2000 2:21 AM To: Praveen Rao; 'Nick Williams'; binno...@ems-t.com Cc: emc-p...@majordomo.ieee.org Subject: RE: Application of CE Mark Hi Praveen, I would even attenuate that last statement. Officially the application of ce on boxes is forbidden so affixing "ce" would be just an invitation to search into the boxes :<)) I think it should make just no difference to customs if you do or do not affix the sign, but as they are human too. Regards, Gert Gremmen, (Ing) ce-test, qualified testing --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Application of CE Mark
Hi Praveen, I would even attenuate that last statement. Officially the application of ce on boxes is forbidden so affixing "ce" would be just an invitation to search into the boxes :<)) I think it should make just no difference to customs if you do or do not affix the sign, but as they are human too. Regards, Gert Gremmen, (Ing) ce-test, qualified testing === Web presence http://www.cetest.nl CE-shop http://www.cetest.nl/ce_shop.htm /-/ Compliance testing is our core business /-/ === >>-Original Message- >>From: owner-emc-p...@ieee.org [mailto:owner-emc-p...@ieee.org]On Behalf >>Of Praveen Rao >>Sent: Friday, December 15, 2000 4:40 AM >>To: 'Nick Williams'; 'binno...@ems-t.com' >>Cc: 'emc-p...@majordomo.ieee.org' >>Subject: RE: Application of CE Mark >> >> >> >>Hi Nick, >>I totally agree with you. They may still open the cases for every other >>reasons, but their reason cannot be for verifying "CE" marks. >>Labelling the >>packaging and accessible DOC will be one reason less for getting into the >>boxes. >>--Praveen >> >> >> >> >>-Original Message- >>From: Nick Williams [mailto:nick.willi...@conformance.co.uk] >>Sent: Friday, 15 December 2000 9:56 AM >>To: Praveen Rao >>Cc: 'Binnom, Cyril A'; emc-p...@majordomo.ieee.org >>Subject: RE: Application of CE Mark >> >> >> >>I think this might be being a bit optimistic. In my experience, >>customs officials have every right to do exactly what they damn well >>please. Certainly, in the UK, Her Majesty's Customs and Excise >>officers have powers to stop, search and confiscate which far exceed >>those of the normal police. >> >>Rgds >> >>Nick. >> >>At 10:57 +1100 12/12/2000, Praveen Rao wrote: >>>Cyril, >>>"CE" marking the packaging is hassle free transportation of goods within >>>Europe. >>>As you say, this will prevent the toll gate officials from tampering your >>>packs. >>>If your packaging has "CE" marks and also a copy of DOC (preferrably in a >>>plastic bag affixed to your packaging)the officials have no right to open >>>your packs to verify compliance. This means that your packaging remains >>>intact and your products remain safe. >>> >> >>--- >>This message is from the IEEE EMC Society Product Safety >>Technical Committee emc-pstc discussion list. >> >>To cancel your subscription, send mail to: >> majord...@ieee.org >>with the single line: >> unsubscribe emc-pstc >> >>For help, send mail to the list administrators: >> Jim Bacher: jim_bac...@mail.monarch.com >> Michael Garretson:pstc_ad...@garretson.org >> >>For policy questions, send mail to: >> Richard Nute: ri...@ieee.org >> >> >>--- >>This message is from the IEEE EMC Society Product Safety >>Technical Committee emc-pstc discussion list. >> >>To cancel your subscription, send mail to: >> majord...@ieee.org >>with the single line: >> unsubscribe emc-pstc >> >>For help, send mail to the list administrators: >> Jim Bacher: jim_bac...@mail.monarch.com >> Michael Garretson:pstc_ad...@garretson.org >> >>For policy questions, send mail to: >> Richard Nute: ri...@ieee.org >> >> <>
RE: Application of CE Mark
Hi Nick, I totally agree with you. They may still open the cases for every other reasons, but their reason cannot be for verifying "CE" marks. Labelling the packaging and accessible DOC will be one reason less for getting into the boxes. --Praveen -Original Message- From: Nick Williams [mailto:nick.willi...@conformance.co.uk] Sent: Friday, 15 December 2000 9:56 AM To: Praveen Rao Cc: 'Binnom, Cyril A'; emc-p...@majordomo.ieee.org Subject: RE: Application of CE Mark I think this might be being a bit optimistic. In my experience, customs officials have every right to do exactly what they damn well please. Certainly, in the UK, Her Majesty's Customs and Excise officers have powers to stop, search and confiscate which far exceed those of the normal police. Rgds Nick. At 10:57 +1100 12/12/2000, Praveen Rao wrote: >Cyril, >"CE" marking the packaging is hassle free transportation of goods within >Europe. >As you say, this will prevent the toll gate officials from tampering your >packs. >If your packaging has "CE" marks and also a copy of DOC (preferrably in a >plastic bag affixed to your packaging)the officials have no right to open >your packs to verify compliance. This means that your packaging remains >intact and your products remain safe. > --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Application of CE Mark
I think this might be being a bit optimistic. In my experience, customs officials have every right to do exactly what they damn well please. Certainly, in the UK, Her Majesty's Customs and Excise officers have powers to stop, search and confiscate which far exceed those of the normal police. Rgds Nick. At 10:57 +1100 12/12/2000, Praveen Rao wrote: Cyril, "CE" marking the packaging is hassle free transportation of goods within Europe. As you say, this will prevent the toll gate officials from tampering your packs. If your packaging has "CE" marks and also a copy of DOC (preferrably in a plastic bag affixed to your packaging)the officials have no right to open your packs to verify compliance. This means that your packaging remains intact and your products remain safe. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Application of CE Mark
Cyril, "CE" marking the packaging is hassle free transportation of goods within Europe. As you say, this will prevent the toll gate officials from tampering your packs. If your packaging has "CE" marks and also a copy of DOC (preferrably in a plastic bag affixed to your packaging)the officials have no right to open your packs to verify compliance. This means that your packaging remains intact and your products remain safe. Praveen Rao -Original Message- From: Binnom, Cyril A [mailto:binno...@ems-t.com] Sent: Tuesday, 12 December 2000 6:50 AM To: emc-pstc Subject: Application of CE Mark Group, I am currently debating about recommending that our company affix the CE mark to all packaging (boxes etc.) slated to be shipped to the European Communities. We currently only affix the mark to the compliant apparatus and from my research (89/336/EEC Article 10(1) I have not found it to be applicable anywhere else other than the apparatus. With the growing talk of enforcement, is it conceivable to believe that marking the packaging along with the apparatus and instructions will aid in preventing future shipments from being tampered with or spot checked while entering the EC? Does the CE mark on the packaging aid in marketing of the apparatus? Thanks in advance for any and all help. Cyril A. Binnom Jr. EMI/EMC Approvals Engineer LXE, Inc. (770) 447-4224 Ext. 3240 (770) 447-6928 Fax --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org
RE: Application of CE Mark
We have placed the CE marking onto our external packaging for the very same reason. We have been doing this for 21/2 years and no issues have been raised. I can not assure you that this will minimize the chances of the local custom officials from opening the carton and assuring that he device is marked also. -Original Message- From: Binnom, Cyril A [mailto:binno...@ems-t.com] Sent: Monday, December 11, 2000 1:50 PM To: emc-pstc Subject: Application of CE Mark Group, I am currently debating about recommending that our company affix the CE mark to all packaging (boxes etc.) slated to be shipped to the European Communities. We currently only affix the mark to the compliant apparatus and from my research (89/336/EEC Article 10(1) I have not found it to be applicable anywhere else other than the apparatus. With the growing talk of enforcement, is it conceivable to believe that marking the packaging along with the apparatus and instructions will aid in preventing future shipments from being tampered with or spot checked while entering the EC? Does the CE mark on the packaging aid in marketing of the apparatus? Thanks in advance for any and all help. Cyril A. Binnom Jr. EMI/EMC Approvals Engineer LXE, Inc. (770) 447-4224 Ext. 3240 (770) 447-6928 Fax --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Jim Bacher: jim_bac...@mail.monarch.com Michael Garretson:pstc_ad...@garretson.org For policy questions, send mail to: Richard Nute: ri...@ieee.org