I believe that I see where the confusion arises. Whereas the Low Voltage Directive applies to equipment, and hence would not include an enclosure within its scope, the list of harmonised standards under the LVD includes many standards for components and materials, among them EN 50298:1998 which applies to enclosures. Now, if an enclosure is assessed to this standard does it thus conform to the LVD, and should it therefore be CE marked? I would say not on the grounds of my first statement about scope, but can understand why many enclosure manufacturers would want to apply the CE marking in the hope of appearing to have greater safety or other desirable characteristics than the enclosure that is not marked. We really have nobody to blame for this situation but ourselves for allowing component standards to be harmonised and listed along with equipment standards. What is really required is a primary and secondary list of standards, whereby the primary standards apply to equipment and invoke CE marking, and the secondary standards apply to components that are thereby presumed to conform to requirements when addressed within the safety assessment of equipment, but which do not themselves require CE marking. Personal opinions only. Best regards
Neil R. Barker CEng MIET FSEE MIEEE Manager Quality Engineering e2v technologies (uk) ltd 106 Waterhouse Lane Chelmsford Essex CM1 2QU UK Tel: (+44) 1245 453616 Fax: (+44) 1245 453571 Mob: (+44) 7801 723735 From: Grace Lin [mailto:[email protected]] Sent: 23 October 2006 12:44 To: JOHN ALLEN Cc: [email protected] Subject: Re: CE Questions John, Thank you so much for your comments and John Woodgate's. My colleague, who initiated the questions, told me last Friday (after reading John Woodgate's comments) that a lab said that CE (and test) was required for an enclosure. I asked him to find out the Directive and test standards (from the lab) that applied to an enclosure. Since I am not a Safety expert, I don't give Safety related comments to my colleagues and rely on members' support and help. I will let you know if I hear a response from the lab. Best regards, Grace On 10/21/06, JOHN ALLEN <[email protected]> wrote: Grace For questions 1 & 3, the answers are both basically NO, because in cases like these the FINAL equipment configuration designer / manufacturer is responsible for compliance with all the relevant Directives. He must make the final determination and apply the Marking (and do everything else that that requires). CE + CE = CE does not work because a) The law does not require that components should not be marked anyway (and some Directives actually prohibit the marking on components - though most do'nt) although many manufacturers do this because their customers ask for it. b) Only at the final equipment design stage can you assess compliance to the overall equipment standard. Personally, in most instances ( I nearly used the word "cases"!) I would not recommend a case manufacturer to apply the mark for the sake of his own (or his EU importers') protection. If his/their name is on the unit with the CE Marking and the final manufacturer assembler does not do a proper job, then it is possible that the case manufacturer/importer could be incorrectly indentified as the "guilty party" and legal action be taken against them (erroniously!). Hope someone else can answer Q2. Regards John Allen From: [email protected] <mailto:[email protected]> [mailto:[email protected]] On Behalf Of Grace Lin Sent: 19 October 2006 06:29 To: [email protected] Subject: CE Questions Dear Members, Question 1: Does an enclosure need to be CE marked for the EU market? My employer sells enclosures for lighting modules. For enclosure alone (such as the one at <http://www.crestron.com/products/show_ roducts.asp?type=commercial&cat=14&subcat=1072&id=1063> http://www.crestron.com/products/show_p oducts.asp?type=commercial&cat=14&subcat=1072&id=1063), I cannot tell which Directive an enclosure applies to from the list of New Approach directives <http://ec.europa.eu/enterprise/newapp oach/standardization/harmstds/reflist.html> http://ec.europa.eu/enterprise/newappro ch/standardization/harmstds/reflist.html ). Question 2: What is the safety standard applying to a dimmer module like the one at <http://www.crestron.com/products/show_ roducts.asp?type=commercial&cat=14&subcat=1007&id=1077> http://www.crestron.com/products/show_p oducts.asp?type=commercial&cat=14&subcat=1007&id=1077? I assume (please correct me if I am wrong) EN55015 and EN61547 are the EMC test standards. Question 3: IF a CE mark applies to an enclosure from Question 1 and a lighting module is CE marked, can I say the lighting module(s) in an enclosure is CE marked ( i.e., CE+CE=CE?). Question 4: Does everything selling to the Europe needs CE marked? Thank you very much for your time and look forward to your help. Best regards, Grace Lin Sr. Compliance Engineer Crestron Electronics, Inc. 6 Volvo Drive Rockleigh, NJ 07920 <http://www.crestron.com/> www.crestron.com - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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