Gary AFIK none of the CE marking directives address replacement parts explicitly (with a couple exceptions). Several of the directives have established in their guidance materials that the directives apply only to so-called "finished products" - which can be loosely defined (sometimes just by context) as a product intended for direct use by and end user. The machinery directive guidance makes clear the MD does not apply to 'components'. The new RoHS FAQ makes clear RoHS2 (CE, and maybe safety) does not apply to replacement parts for out of scope equipment, but watch out because RoHS2 does name "spare parts". The old WEEE (not CE, and not safety) had a nice turn of phrase that exempted components incorporated in other equipment. The many ERP regulations (CE, but not safety) scope as 'XYZ on their own and incorporated in other products' - which probably brings in replacement parts that are themselves XYZ. REACH (not CE, maybe safety) doesn't care about products and spare parts and only sees "articles", so everything is in scope.
It's a real mixed bag. I've heard the old Blue Guide is under revision. Maybe they will help clarify your question in it. Regards, Lauren Crane KLA-Tencor From: McInturff, Gary [mailto:[email protected]] Sent: Thursday, June 13, 2013 3:24 PM To: [email protected] Subject: [PSES] Pointer please. Where in the safety directives are the instructions for spare parts or service parts. We manufacture a device for an end customer but don't do the safety approvals - we are just designated as a factory. I haven't seen any activity in getting this device approved under the new edition of the standard and am concerned that it has fallen through the cracks by the customer. I don't believe it's a current production system but they are maintaining the systems already in the field, meaning that this are service parts I believe, but I don't know exactly what allows them to continue importing them into Europe. The real issue is that some of the plastic that had been used in the past isn't going to be available but it is described as a critical component in the safety files by manufacturers name. model type. We can replace the material with the same flame rating but the raw material is from a different supplier. Even if spare parts are allowed for a system with an out of date harmonized safety standard I don't think one can just change the components without some activity, but exactly what and how, add some notes to the technical file? I've tried discussing the issue with the customer but can't get through the purchasers to the compliance people, to insure that this isn't just slipping through the cracks. Esterline Interface Technologies Featuring ADVANCED INPUT, GAMESMAN, LRE MEDICAL, and MEMTRON products 600 W. Wilbur Avenue Coeur d'Alene, ID 83815-9496 Toll Free: 800-444-5923 X1XXX Tel: (208) 635-8 Fax: (208) 635-8 www.esterline.com/interfacetechnologies<http://www.esterline.com/interfacetechnologies> Technology, Innovation, Performance... "Information in or attached to this e-mail message may be subject to export control restrictions of the International Traffic in Arms Regulations (ITAR) (22 CFR pts. 120-130) or the Export Administration Regulations (EAR) (15 CFR pts. 730-774). Before exporting this information outside the United States or releasing it to a foreign person in the United States, you need to determine whether a license under the EAR or the ITAR is required to do so. If you have any questions about this obligation, please contact me." Click here<http://www.esterline.com/governance/email_disclaimer/tabid/1532/Default.aspx> to read disclaimer - ---------------------------------------------------------------- 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://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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]<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://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. 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]>
