We manufacture application specific subassemblies (keyboards) that are used 
on special computer systems, workstations etc.  We typically do not place 
these goods on the market, as they are designed specifically for a 
particular system, and  have no intrinsic functions of their own.  Sometimes 
our customers who are the system integrators will ask for the CE Mark or FCC 
certification.  We explain that this is really putting the cart before the 
horse as the "system" is what must be tested and CE Marked or FCC certified. 


I have noticed that desktop computer subassemblies are often CE Marked, even 
when the same manufactuerer logo is on the whole system.  I would assume 
that  these subassemblies (i.e. keyboards) can be used with several systems, 
and are consequently tested with a few "representative" systems and then 
marked.  Do the "representative" systems need to be noted on the Declaration 
of Conformity?  If I test my subassembly with System A and B, can System C 
claim they are compliant because they have a similar product and are using 
my CE Marked subassembly?

There seems to be the potential for  marketing games to be played by 
suppliers of components and subassemblies by promoting the CE mark to the 
end user (or potential customer), with the promise of "use all CE Marked 
parts and your end product will be compliant".   If nothing else, it  looks 
like there may be a lot of redundancy in testing of products.

Darrell Locke
Advanced Input Devices

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