Cortland,

I suspect that your bike inner tube complies with the Toy Directive. 
Or could it be the Machinery Directive? (grin) - it may have been 
assessed as having moving parts! Would be very interesting to 
obtain the DoC.

Regards, Peter


> 
> What an interesting discussion!
> 
> As many others, I suspect, I believed that the CE mark was extended to
> cover the LVD (and possibly other safety requirements) in order to permit
> use of a  harmonized standard rather than various national ones.
> 
> Well, I've been wrong before, so it would be no surprise to be wrong again.
> 
> The only excuse I can produce is not being a safety engineer, but a poor,
> struggling (sob) EMI troll, wrapped in layers of copper tape, given the
> (EMI) finger at every opportunity, and isolated in a corporate bureaucratic
> morass designed to make sure nothing actually gets done.
> 
> Ahem (wiping eyes). Sorry.
> 
> With regard to the END ITEM equipment, I do remember hearing at a former
> employer that we could include the CE mark as evidence that we had met the
> requirements of the LVD and the machinery directive, and thus eliminate
> multiple overlapping approvals on it. Logically, this is the way to go. But
> what method could be used to show compliance if there is no pan-European
> mark, for components? I can't believe the intent of the CE mark was to
> require the continued application of national marks.
> 
> Hr. Ingr. Gremmen has, I think, hit the target with his observation that
> one who uses the CE mark assumes all liability which may accrue from later
> performance,and it may indeed be that this consideration, rather than
> inapplicability, is to blame for not wishing to use the CE mark on filters.
> 
> Let's not forget that a CE mark does not have to mean compliance with
> obviously inapplicable standards. I have a bicycle inner-tube whose box
> carries the CE mark and I am pretty sure it doesn't comply with EITHER the
> LVD or the EMI directives. (grin)
> 
> What an interesting avalanche!
> 
> Cortland
> 
> 
> 
> ====================== Original Message Follows ====================
> 
>  >> Date:  14-Jun-99 09:30:29  MsgID: 1068-75575  ToID: 72146,373
> From:  "Peter E. Perkins" >INTERNET:[email protected]
> Subj:  more Line filter certification remarks
> Chrg:  $0.00   Imp: Norm   Sens: Std    Receipt: No    Parts: 1
> 
> 
> 
> 
> PSNet
> 
>         Since I don't agree with Cortland, I'll put my U$ 0.02 worth in
> here...  
> 
>         CE marking is intended for completed equipment (or major
> components, not small components).  The best explanation of marking of
> components is included in the Machinery Directive.  Unfortunately, this
> level of detail has not been carried into the other major directives.  
> 
>         From this, it is clear that small components are not supposed to be
> CE marked (in spite of the intense marketing pressure on the part of both
> equipment and component manufacturers to use the CE marking to get rid of
> dealing with Euro Labs).  This differentation was part of an undocumented
> settlement between the EUrocrats and the Euro test houses about 1989.  This
> was intended to leave the certification of componets for the test houses,
> rather than driving them out of business.  
> 
>         As an aside, the MD specifies that safety components which are CE
> marked must have a Notified Body involved in the process.  I do not yet see
> any NB reference to CE markings on circuit breakers and other safety
> devices (I'll accept correction from cb mfgrs who use a NB in their
> process).  
> 
>         From this background I always demand a Euro certification on any
> component used in CE marked equipment that I work with.  I ask for, and get
> a copy of the component manufacturers Certificate(s) for the Euro marks
> claimed.  It all boils down to - who sez so...  and I want component
> manufacturers to have someone looking over their shoulder on all of this...
>  There are some component manufacturers who are moving away from Euro lab
> marks and I discourage the use of their components in certified equipment. 
> 
> 
>         Finally, I'd like the EU folks clear this up and get the MD
> clarifications spread thruout the other Directives, which could be done
> very much in the same manner as the marks information was clarified in a
> single Directive.  
> 
>         
>         - - - - -
> 
>         Peter E Perkins
>         Principal Product Safety Consultant
>         Tigard, ORe  97281-3427
> 
>         +1/503/452-1201 phone/fax
> 
>         [email protected]      email
> 
>         visit our website:
> 
>                 http://ourworld.compuserve.com/homepages/peperkins
> 
>         - - - - -       
> 
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> 
> 
> **Primary Recipient:
>   Cortland Richmond 72146,373
> 
> ====================== End of Original Message =====================
> 
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> 


PETER S. MERGUERIAN
MANAGING DIRECTOR
PRODUCT TESTING DIVISION
I.T.L. (PRODUCT TESTING) LTD.
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