Brian,
I don't think it matters, if you are selling the equipment to your
customers you bear the obligations EMC and everything else. It certainly gives
you the right to eliminate a failing vendor from your qualified vendor list,
but you can't just pass the problem on the client and say its not your fault.
Even if the EU didn't care, I suspect your customer is not going to go after
your suppliers if he runs into a problem. You're the one he paid money to in
order to meet some need of theirs, and I expect they will insist that you
deliver what you said you would.
Gary
-----Original Message-----
From: brian_ku...@leco.com [mailto:brian_ku...@leco.com]
Sent: Friday, November 22, 2002 9:29 AM
To: emc-p...@majordomo.ieee.org
Subject: ReIssue: RE: When CE doesn't pass
Thanks to everyone who responded to my earlier email. After reading the
replies, I wanted to rephrase and clarify our situation to see if it matters.
We design, manufacture, and market stand-a-lone Product A. But some of our
customers want a complete turn-key system. So we purchase and re-sell Products
B, C, and D. Each are individually marketed by their manufacturer and has the CE
marking. We sell and setup this turn-key system for our customers. This might
be seen as CE+CE+CE+CE should equal CE.
Our company always wants to do what's right, so we test this turn-key system for
CE. During the EMC testing, Product D causes the system to fail. Additional
investigation finds that Product D fails all by itself, independent of the rest
of the system. When the manufacturer of Product D is contacted, they reply
with, "it passes when we test it". Another problem is that we do not have
enough buying power to force them to look into the problem and threatening them
with turning them in won't help us ship product.
Is there any train of thought, loophole, or documentation trail that will allow
us to market and sell this turn-key system? How do we become liable for a CE
labeled product that someone else's makes? I know we don't want to sell a
non-compliant system, but what are we to do?
Some suggest fixing the product yourself. If it can't be done externally, as
soon as we open up the unit don't we become responsible for it including
safety? I don't think we want to do that.
Thanks to all again,
Brian Kunde
LECO
____________________Reply Separator____________________
Subject: RE: When CE doesn't pass
Author: neil.bar...@e2vtechnologies.com
List-Post: emc-pstc@listserv.ieee.org
Date: 11/22/02 4:25 AM
No, you can't. If you are placing the system on the market as a single
commercial unit then you must issue a Declaration of Conformity for the
system. However, if you place the system on the market without the
peripheral then you could claim conformity for that system as a unit. If you
also sold the peripheral, acting purely as a distributor for the
manufacturer of the peripheral, then the legal responsibility for that
peripheral would lie with the other manufacturer. However, do you really
want your system to be associated with a non-compliant product? Personally,
I would inform the manufacturer of the peripheral of the problem and look
elsewhere for an alternative unless he took action to make it compliant.
To relate this to another thread that is running at present, this is a prime
example of CE + CE does NOT make CE!
Best regards,
Neil R. Barker
Compliance Engineering Manager
E2V Technologies
Waterhouse Lane
Chelmsford
Essex
CM1 2QU
U.K.
Tel: +44 (01245) 453616
Fax: +44 (01245) 453410
E-mail: neil.bar...@e2vtechnologies.com
> -----Original Message-----
> From: brian_ku...@leco.com [mailto:brian_ku...@leco.com]
> Sent: 21 November 2002 19:41
> To: emc-p...@majordomo.ieee.org
> Subject: When CE doesn't pass
> > > > Has this ever happened to you?
> > We manufacture analysis instrumentation equipment. The part > we make is
> > usually
> part of a complex system made up of other CE marked equipment > from many
> different suppliers. Sometimes when we have a system tested > for CE
> (emissions
> and immunity), one of the other companies pieces of equipment > will cause the
> "system" to fail. > > I have seen some test labs identify the failing piece
> of > equipment, write it up
> in the report and say it is not our problem because our > equipment passes
> AND it
> is not contributing to the failure. But, what if we are > selling the
> "system"
> including the CE Marked products that failed when we had it tested?
> > It doesn't always do us much good to go to the manufacturer > of the failing
> equipment because they will usually say that it passes when > they tests it.
> If
> we were a PC manufacturer and had trouble with a printer or a > monitor we
> could
> just find another one, but the equipment in our systems are > more unique.
> There
> may only be 1 or 2 manufacturers of such a device and we > don't have much of
> a
> choice.
> > So here is my question. Can we sell a "system" that includes > a CE marked
> peripheral that we have no design control over, that fails > when WE have it
> tested?
> > Please advise and Thank you in advance.
> Brian Kunde
> LECO Corp.
> > > > > > > -------------------------------------------
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