Hi Alkexandru,


There are several spects to this. I will elaborate on the
specifications for a power supply (SMPS).

Components and power supplies used to be incorporated into
equipment are not subject to ce marking. This you concluded
yourself.
Now for safety you will need a declaration of conformity according
to a EN/IEC standard compatible WITH YOUR END PRODUCT, probably issued by
an European test house such as VDE NEMKO KEMA or other.
For a PC supply you will need a EN 60950 compliance statement
and for medical equipment you will need a EN 60601 compliant supply.
Ask your manufacturer for a (partial)copy of the test report that
list out the conditions under what the supply needs to be incorporated
to fulfill safety requirements. This is very important as an
open Frame power supply could NEVER meet the full requirements of
EN 60950 f.a. , but incorperated in an open end product may inhibit
approval of your end product. If your equipment enclosure fulfills
fire enclosure requirements, then that would be no problem.
Pay especially attention to terminals , open/closed enclosures
en insulation class between mains and secondary. It needs to
be compatible with your end product. It will not be easy
to obtain such a copy as manufacturers are reluctant to give them.

Now for EMC, the supply needs to be compatible with the EMC directive
itself. This is what you will find in general in the datasheets.
of course , here compatibility of the specs with your end product
is required too. Most of the time a compliant power supply will not
produce problems in itself for the approval of your end product
(by it's proper emissions f.a.)
The attenuation however, for emission currents originating from your
proper electronics and transferred by the power supply to the mains
supply may however, be unspecified as there exist no requirement for such.
Most of the time they ARE unspecified, and may varie widely among
supplies having virtually the same approval data.
May even vary among different batches of the same product.


Now what you really need is statements of compatibility (liability)
with suitable standards (compatible with your end product).
Most of the time these are IEC standard possibly in an EN variant.
These statements are civil liability statements between you and the
manufacturer
 and  have no legal meaning in (EC) public right and are therefore (within
national
limitations) valuable all over the world.

Then you will have to create THE Declaration of Conformity according to
public law
for Europe, based on the TCF for your product.
 Note the differences between civil and public legal aspects.
if you are not familiar with it, ask a specialist.

Due to the arguments earlier mentioned a private compatibility
statement with suitable standards needs to be completed with
additional purchase requirements, such as not modifying the product
in such a way that it might impact the compliance of your
end product (or at least don't allow to do that without notice)
For this you need to specify what properties of
the supply you are relying on for compliance of the end product.
In order to correctly design the implementation you will probably
need a copy of the test reports.


Other OEM products may be easier to specify, however.

Gert Gremmen
ce-test, qualified testing


-----Original Message-----
From: [email protected]
[mailto:[email protected]]On Behalf Of Alexandru Guidea
Sent: Wednesday, September 25, 2002 9:56 PM
To: [email protected]
Subject: subcontracted parts - compliance with EN's
Importance: Low



Dear colleagues,

This questions might have been asked before. Still looking for answers...

Our company purchases power distribution equipment designed per our specs.
This equipment is not put on the market, but integrated in our products, and
does safety/EMC functions(EMI filtering, protection, emergency stop) among
other things, in accordance to the EC Directives applicable to our product.
We believe there is no point to have it CE marked but only compliant with
the standards we need. The text of the EMC Directive reads "the manufacturer
may subcontract certain operations, e.g., apparatus design or production,
provided that he retains overall control and responsibility for the
apparatus as a whole. By the same token, he may use ready-made items or
components, CE marked or not, to produce the apparatus without losing his
status as a manufacturer."

We follow the Technical Construction File route for CE marking.  What's the
documentation required from our sub-contractors that proves compliance with
the EN standards we indicate? Do we need complete copies of test reports,
technical description, analysis, or just a statement of compliance would do
the job? What's the legal value of such a paper in North-America? As we
don't control their production (parts, quality, etc,) what's the
documentation we shall request to ensure all production units are compliant?
What's the industry/your practice in this case?


Alexandru Guidea
CAE Inc.
Montreal, CANADA





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