Carl,

In regard to your statement "Another package may include plastic panels with no 
inherent standalone function" In this case there are no harmonized standards 
that I am aware of for plastics so I will further assume that no CE Mark is 
required.

Mark Schmidt

-----Original Message-----
From: Carl Newton [mailto:[email protected]] 
Sent: Thursday, August 27, 2015 8:39 AM
To: [email protected]
Subject: [PSES] CE Marking on Packaging of Assembly Components

Group,

I'm dealing with a scenario in which a storage assembly that includes some 
electronic functionality is assembled on-site by end-users.  Various  
elements of this storage product are shipped from different factories.   
One package may include the electronic subassembly that has the product label 
attached.  Another package may include plastic panels with no inherent 
standalone function (RoHS does not apply at this time).  The set of component 
packages that comprise the product are imported into the EU  from the USA.  The 
UK distributor has asked that all packages have the CE Marking on the box.  I'm 
reluctant to sign-up to this procedure in view of the fact that the CE Marking 
should not be applied to most sub-assemblies.

I've reviewed the 2014 Blue Guide, Regulation (EC) No 765/2008, and 768/2008/E 
seeking guidance on this scenario but find nothing.  Is anybody within the 
group aware of some form of legal guidance that applies?

Thanks,

Carl

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