Peter, The Machinery Directive Guide gives excellent guidance on these sorts of questions à http://www.cen.eu/cen/Sect rs/Sectors/Machinery/Documents/guide_ap lication_directive_2006-42-ec-2nd_edit_6-2010_en.pdf
Search on “established outside the EU”. It can be a tricky point, but a company outside the EU is not really within reach of the directive. Whoever is importing your products is more directly on the hook. And DEPENDING ON THE DIRECTIVE IN QUESTION CE marking and DoC’ing may not be relevant for B2B sales. If your company is not actually planning on placing your items directly on the EU market or putting them directly into service, i.e. if they are truly B2B components, you may not need to do much at all except assure your customers via contract terms that your products have been designed such that when your customers integrate them, they will not hinder the compliance of the larger product. There is no requirement in any directive I know of, that a product be composed of components that are CE Marked, except for some of the tricky ErP implementing measures. Caveats galore – as various customs authorities are playing by their own rule books regarding component import rules, many people in the game speak >from “common sense” rather than reading each directive in detail, and there is still no RoHS II guidance to state with certainty that component EEE is out of scope. -- Lauren Crane (mr.) Product Regulatory Analyst | Corporate Product EHS | Applied Materials Office 512.272.6540 | Mobile 512.736.7201 | America - Europe - Asia -external use- This is my own opinion only and not necessarily that of my employer. ** Save paper and trees! Please consider the environment before printing this e-mail. From: [email protected] [mailto:[email protected]] On Behalf Of [email protected] Sent: Friday, August 26, 2011 3:06 PM To: [email protected] Subject: CE mark Hello group, We are a US based manufacturer that sells our products to global customer and some of these individual customers are requesting that we CE mark our products so that they can integrate them into their system for EU. I have everything done including my DoC (Declaration of conformity) but we don't have any importer or sales office in EU and therefore don't know what address I should use on my DoC. How can a US manufacturer CE complete the DoC and affix the CE mark on the product when they don't have any present in the EU? Thanks Peter - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://product-compliance.oc.ieee.org/ http://product-compliance.oc.ieee.org/> Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]> ________________________________ - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://product-compliance.oc.ieee.org/ Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]> Mike Cantwell <[email protected]> For policy questions, send mail to: Jim Bacher <[email protected]> David Heald <[email protected]>
