Bonjour de Montreal,

I was aware of the "catch anything" Directives of the European Union and
there was always another question to arise from them. Let say you have a
product which requires the CE marking because of the EMC and Low voltage
directive. That's fine, you meet the standards associated with the
Directives, produce a report, make a Declaration of Conformity and put the
CE Mark.

But what about these other Directives. Even if there is no standard should
we reference those in our Declaration of Conformity ?

Another sub-question.

Let say you have a product which meets the EMC Directive when it is brand
new. But the galvanic effects were not check properly during the design and
after 6 months its shielding effectiveness is gone and it is producing
interferences that cause an accident. My understanding of it is that you
can be brought to court following the prescription of the Liability
Directive because of the error in the design.

Is it how it is working ?

Thanks for your help,

BenoƮt Nadeau




At 08:36 AM 4/5/2000 +0100, John Allen wrote:
>
>George
>
>I generally agree with most of what you say - except the possible 
>implication in the 3rd paragraph where the use of the word "applicable" 
>could be be misconstrued as INCLUDING that the GPSD would apply in the 
>absence of any SPECIFICALLY applicable directives.
>
>I believe that a better definition is that "the CE marking is required on 
>all products covered by European Directives that apply to it AND that 
>require the marking". This definition then excludes the GPSD, Product 
>Liability Directive and multitudinous other directives which exist - but 
>which (at least currently!) no mention at all of CE marking.
>
>With many of the "non-specific" directives it would actually be very 
>difficult to lay down a set of rules under which the CE Marking could be 
>applied - since, in many cases, product standards and means of verifying 
>conformity do not exist. To require the CE Marking in such circumstances 
>would result in a similar - but FAR worse -situation  that we encountered 
>in the early 90's with the advent of the EMC Directive but with far fewer 
>standards etc., to support it!
>
>I hope that I have not stated the obvious but I  encounter people who are 
>under the impression that the CE marking means that a product complies with 
>ALL European directives that apply to it.
>
>John Allen
>Racal Defence Electronics Ltd.
>
>----------
>From:  [email protected][SMTP:[email protected]]
>Sent:  04 April 2000 19:01
>To:    [email protected]
>Subject:       GPSD Discussion
>
>
>Several comments were made relative to the evolving General
>Product Safety Directive (92/59/EEC) and CE marking that may
>have given an inaccurate view.  Here is my understanding:
>
>The EU now requires "CE" marking on a broad variety of imported
>products as a condition of entering the EU.
>
>The display of the "CE" marking means that the product complies with
>all "applicable" EU Directives for that product.
>
>The required EU Declaration of Conformity (DoC) for each "CE" marked
>product states the Directives to which the product conforms, and often
>the standards or method by which conformity was verified.
>
>As a result of the above, you can find the "CE" marking on household
>kitchen appliances, electric razors, stuffed animals, etc.  In other words,
>"CE" is not just for electrical equipment.
>
>The GPSD appears to be aimed at many consumer products for which
>there is now no specific Directive or EU legislation.  However, since this
>1992 Directive is not well understood by even members of the EU, recent
>Commission discussions are with the intent of clarifying this Directive,
>possibly replacing it with a new version.
>
>Although no specific product examples are cited, there are references to
>"food products".  There are also references to the following Union death
>rates in 1996:
>
>workplace deaths                                    6000
>traffic accidents                                      45000
>home and leisure accidents              83000
>
>This explains the emphasis on consumer products and services.
>
>Although the langauge sounds like it was written by a committee of
>lawyers, I think it implies that where products conform to existing product
>safety Directives/legislation, the GPSD does not apply.
>
>These are merely my opinions on a very complex document....
>
>George Alspaugh
>
>
>
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Gerant du Groupe Conformite (Conformity Group Manager)
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