http://www.ieee-pses.org/symposium http://www.emc2004.org/
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John K
You said
"I thought that ANY product, from ANY industry, has to be CE-marked for sale
in the EU. Period. So how can something NOT be CE-marked? I didn't think this
could even be an option."
That is not true (thank goodness - do you really need a CE Mark on a hair
comb, etc.?).
The CE Marking has to be applied to an equipment to indicate that the
manufacturer declares that it meets all relevant European Directives that both:
a) Apply to that equipment;
AND
b) Require the Marking to be applied
(see this page http://www.era.co.uk/Docs/ECS/JA/CE_Means.pps on our website
http://www.era.co.uk/services/rcm.asp)
So if your product is not subject to ANY Directive that requires the CE
Marking then you don't need to apply the marking - and you really should not
even do it anyway because misapplication of the mark is a criminal offence.
Therefore the issue of applying a mark to a "component" or sub-assembly is
very "debateable", although your customers might expect it.
This is principally why the Machinery Directive requires such items to have a
Declaration of Incorporation (DoI)which references the intended application
and required installation conditions, but prohibits the use of the CE Marking
on those components. Unfortunately this approach is not taken in other New
Approach Directives.
The relationship between a component with a DoI and an equipment with a DoC
and CE Marking is conceptually very similar to that between a UL Recognised
Component and a UL Listed equipment.
Personally, I think this concept should also be applied under other Directives
such as the LVD, and that Europe could usefully have an actual marking for
components that still require to be correctly installed -(A CE "recognised
component" marking maybe?).
That would satisfy the practical need to identify a component which is claimed
to meet certain relevant EU requirements, but which still requires correct
installation in another piece of equipment in order to be considered compliant
to the relevant Directive(s).
John Allen,
Technical Consultant
EMC and Safety Engineering
ERA Technology Ltd.
Cleeve Road
Leatherhead
Surrey KT22 7SA
UK
Tel: +44-1372-367025 (Direct)
+44-1372-367000 (Switchboard)
Fax: +44-1372-367102
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