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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