Rob,
At my company we have a lot of difficulty interpreting this issue as it
applies to our customers. We make electronic equipment which is
incorporated into a larger machine. As such our equipment falls under the
Machinery Directive (MD). Since our product is a component of the Machine
we are often told that the CE mark is not allowed on our products.
However in the MD chapter I, article 1, paragraph 5 states "Where, for
machinery, the risks are mainly of electrical origin, such machinery shall
be covered exclusively by Council Directive 73/23/EEC of 19 February 1973 on
the harmonization of the laws of the Member States relating to electrical
equipment design for use within certain voltage limits" (LVD).
As a harmonized directive the LVD also requires CE marking regardless of the
exclusions contained in the MD. Let me suggest some methods to determine
marking of a product:
1) If your product is a Machine and you reference the MD on your
Declaration of Conformity (DoC) then the CE mark needs to be applied.
2) If your product is covered by paragraph "5" and you reference the LVD on
your DoC then the CE mark needs to be applied except
3) When your product is designed for incorporation into a machine, has no
intrinsic function of its own (becomes useful after installation in a
machine) and you do not provide a DoC, rather a Declaration of
Incorporation, then the CE mark may not be applied to the product. This
applies whenever the safety of your product can be realized only after it
has been safety integrated into a machine or other LVD product.
You should note that the EMC Directive probably applies but you may not
apply the CE mark solely for compliance with EMC. Also, once you are in
compliance with the LVD, technically you are in compliance with the MD.
{soapbox mode on}
Part of the confusion has been brought about by "component" manufacturers CE
marking their products. For example one manufacturer perceiving a marketing
advantage applied the CE mark to their terminal blocks and declared
compliance with the EMC Directive during 1996. Their competitors as a
result felt the loss of business and also began applying the mark. Similar
things are going on with circuit breaker, contactor and EMI filter
companies. The CE mark is appropriate for products which have intrinsic
function and are to be place on the European market. No one would attempt
to place a CE mark on a resistor or transistor as they only find function
when they are incorporated into a larger product and compliance is
determined by the application. Of course a resistor is a simplistic device
but it certainly conveys the idea.
{soapbox mode off}
BOTTOM LINE: for components that are to be used in the EC it is still
appropriate to place a regulatory agency component mark, such as VDE, SEV,
SEMKO, NEMKO, DEMKO, etc. - - NOT THE CE MARK!
Sorry for the long dissertation but this topic has been a sensitive one
around here. I hope this helps to clarify a little.
If anyone else in the group has comments please speak up. I am sure that I
have not yet learned everything there is to this problem and if anyone has
more information or experiences to relate I would like to hear.
Doug Powell
Advanced Energy Industries, Inc.
[email protected]
===================================================
CE mark
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From: [email protected]
To: [email protected]
Subject: Low Voltage Directive/IEC950
List-Post: [email protected]
Date: Monday, June 09, 1997 2:04PM
There is much confusion regarding when/if IEC license information for
specific components within CE marked assemblies is required to comply
with the Low Voltage Directive, or country specific requirements.
I have heard everything from no requirements, to only certain
countries/agencies require them, to only specific notified bodies
within specific countries state the requirement.
Can someone help clear up my confusion on this?
Thanks
Rob Zielske
Quality Program Manager
Advanced Fibre Communications
