John, The primary responsibility is for the essential requirements in applicable CE marking directives. The use of a standard that has been listed for a particular directive in the Official Journal of the European Union allows you to presume conformance with the particular essential requirements of the directive as listed in the standard in an annex (appendix). It is important to note that the use of standards is not mandated by the directives (though it may well be mandated by custom in your industry or by your customers directly), and that a single standard might not cover all of the essential requirements in an applicable directive.
There are many CE marking directives these days that could be applicable, such as energy efficiency requirements (for fans, standby modes, etc..) and the newly recast RoHS directive (not yet officially published, expected in April). Presuming your are exporting into EU, the person or company importing the item into the EU is ultimately responsible for conformance. This could well be a company affiliated with yours (i.e. the EU branch of your company), or an "Authorized Representative" in the EU could take responsibility if they have a written mandate from your company to do so. Regarding conformance after modifications, this can be tricky depending on the details of contracts and what you say in your documentation about additions to your system. Typically the owner of a system is responsible for conformance after they change the system unless, perhaps. the equipment supplier suggests in their documentation/communicaitons the changes are acceptable (e.g. adding expansion cards to a computer). If the system is a machine, the Machinery Directive has particular treatment for so-called 'partly completed machinery.' Regards, -- Lauren Crane (mr.) Product Regulatory Analyst | Corporate Product EHS | Applied Materials Office 512.272.6540 | Mobile 512.736.7201 | America - Europe - Asia -external use- ** Save paper and trees! Please consider the environment before printing this e-mail. From: John Cochran <[email protected]> To: "[email protected]" <[email protected]> List-Post: [email protected] Date: 02/04/2011 12:45 PM Subject: CE marking responsibilities Sent by: [email protected] ________________________________ I don’t think I have ever really been clear on what a manufacturer’s responsibilities are with applying a CE mark. We manufacture computer stations inside an enclosure for harsh environments. If a customer needs a CE mark on the system, to what standards are we responsible to test this system? This especially becomes murky when the customer is requesting an incomplete system, without a computer or some other components. Do we just supply a Declaration of Conformity with the standards that we do know the system complies with, then put the CE mark on the system? What if the components that are installed later, have problems with immunity to EMI or radiate outside of the limits in the standard? Are we as the manufacturer, responsible for improper application of the CE mark on our system? Of course, I know CE is a self-certification, but the manufacturer is responsible for compliance to the appropriate standards, if we mark the system with CE. I appreciate any and all opinions on this subject. Thanks, John - ---------------------------------------------------------------- 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] <mailto:[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/ <http://www.ieee-pses.org/> Instructions: http://listserv.ieee.org/request/user-guide.html <http://listserv.ieee.org/request/user-guide.html> List rules: http://www.ieee-pses.org/listrules.html <http://www.ieee-pses.org/listrules.html> For help, send mail to the list administrators: Scott Douglas <[email protected] <mailto:[email protected]> > Mike Cantwell <[email protected] <mailto:[email protected]> > For policy questions, send mail to: Jim Bacher <[email protected] <mailto:[email protected]> > David Heald <[email protected] <mailto:[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]>
