Group EMC-ers

About the time I thought I was starting to understand the CE
requirements, I'm more baffled than ever.  I have a
reoccuring situation that I would greatly value any opinions
on.

We routinely ship a variety of small digital (ITE) devices
to Europe (specifically Ireland). Along with the CE marked
digital devices, there are also items such as cables and
books. Some devices may be considered components and not
marked.  The cables are also not CE marked.  This mix of
items is packed in a single box.  There is no external
indication on the box that things are CE marked. Each
digital product has the CE mark, and its DoC is included in
the products documentation. This has been going on for years
without any known problems.

Now, some of these products arrive at a dealer in Ireland
for resale into the EU. Other products may be destined for
resale outside the EU into countries who's EMC requirements
may or may not have been addressed (those are handled on a
case by case basis).  I am told by a NB in Ireland that the
CE mark is required if the products are to be 'placed on the
market' in an EU member country. My question/concern is how
do 'they' know which products need the mark, and who is
'they'.

I have assumed that there is some sort of checking or
enforcement in place, but so far can't find anyone in that
country that is aware of it.  So I'm left with shipping
cartons into Ireland with a posible mix of CE and non-CE
marked products.  What is the risk of doing this? I had
assumed that at some stage in the import process, someone
may examine packaging or documentation for CE mark, and
possibly reject the carton if it wasn't found.

Can anyone clear up what I am supposed to be doing? Some of
these items cannot be CE marked for practical reasons, but
they will still be going into Ireland on route to their
final (non EU) destination. All items need to be in a common
carton to keep shipping costs reasonable.

What I am starting to assume, is that there is no practical
way to enforce the CE mark requirements so enforcement is
not attempted at the import stage. I'm sure this varies
somewhat by country and may change with time. If this is the
case, then I could sleep easier knowing that we are
practicing 'due diligence' in CE marking all products placed
on the EU market, even though some non CE products are
imported though the EU.

Can anyone offer any insight?

Best regards,

Mike Fahrion
[email protected]




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