Must power cables imported and sold in Europe have a CE mark and manufacturer's name & address starting 3 January 2013 in accordance with the recast RoHS Directive 2011/65/EU? Similarly, must the power cable have its own declaration of conformity (DOC)?

It appears that AC power cables shipped in separate boxes would meet the definition of EEE in article 3 definition (1) as the AC power cable is "/equipment for the ... transfer ... of such currents and fields and designed for use with a voltage rating not exceeding 1 000 volts for alternating current/".

For companies that sell worldwide, many ship the power cables alone in their own boxes separate from the system products since their products are sold worldwide and the correct power cable must be selected for each order as applicable for each customer's country. Usually, the power cable is imported in the same shipment as the system, but there are other times when the power cable is imported alone either to replace a damaged power cable (field replacement unit) or sold to support moving a product already in Europe to change plug types (different plugs used for moves to other countries within Europe or to different power distribution units). Hence, it would appear that power cables would need to comply with the European rules individually for compliance instead of depending on the system product (like a server) for the CE marking.

As a result, it appears that power cables will now require a CE mark, be labeled with the manufacturer's name & address, and have its own DOC by 3 January 2013.

Note: All opinions given in this e-mail are purely my own and do not necessarily reflect the positions of any company I work for.

Thanks.

Monrad Monsen
+1.303.272.9612


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