Carl Personally, I would:
- Decide what is the most major part of the product which has a visible external surface which be carrying all the other product identification marking, and then put the CE marking on that part; - Make sure that the product documentation going to the customers clearly states that the product will only be compliant with all relevant "CE Directives" and the DoC when assembled and installed according to the detailed instructions you provide. - Before making the final decisions, take a look at the recently updated Commission "Blue Guide" - and particularly Chp 2 Section 2.1 "Product Coverage" and the para beginning "A combination of products..." on Page 18 and Chp 4 Section 4.2.2.3 "Identification element" on Page 49. John Allen W.London, UK -----Original Message----- From: Chuck McDowell [mailto:[email protected]] Sent: 27 August 2015 17:52 To: [email protected] Subject: Re: [PSES] CE Marking on Packaging of Assembly Components I can across this European Commission document on spare parts this week. It maybe of interest. I believe it states that for EMC Directive OEM parts do not require a DoC ergo no CE mark. Google "APPLICATION OF EMC DIRECTIVE AND/OR EMC VEHICLE DIRECTIVE TO AFTERMARKET EQUIPMENT" http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=1&cad=rja&uact= 8&ved=0CB4QFjAAahUKEwjfy73C2MnHAhUQRYgKHWphDz4&url=http%3A%2F%2Fec.europa.eu %2FDocsRoom%2Fdocuments%2F4543%2Fattachments%2F1%2Ftranslations%2Fen%2Frendi tions%2Fnative&ei=7zvfVZ-YL5CKoQTqwr3wAw&usg=AFQjCNHmvmnYBItTKhMu7bZUXyC2ols YGA See if category B applies to you sub-assemblies? Chuck McDowell Compliance Specialist Meyer Sound Laboratories Inc. -----Original Message----- From: Nyffenegger, Dave [mailto:[email protected]] Sent: Thursday, August 27, 2015 8:28 AM To: [email protected] Subject: Re: [PSES] CE Marking on Packaging of Assembly Components It depends on which directives apply to the product/components. The Machinery Direct is clear that partly complete machinery is not to carry a CE mark to avoid confusion when it's integrated with the complete system. Partly completed machinery should be accompanied by a DoI. However if your items are not machinery but instead fall under the LVD for example and you are going to provide a separate DoC for those items then it would make sense that they be marked. If you are not providing a separate DoC/DoI for these items because they have not been assessed as individual products then perhaps provide documentation/statement that they are part of the larger system to be integrated and provide a copy of the DoC of the complete system but do not CE mark the items/shipping container itself. I wouldn't put a CE mark on a component that falls under MD or LVD without having a DoC/DoI and technical file to back it up. -Dave -----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 - ---------------------------------------------------------------- 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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://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://www.ieee-pses.org/list.html (including how to unsubscribe) 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]> NOTICE: This email may contain confidential information. Please see http://www.meyersound.com/confidential/ for our complete policy. - ---------------------------------------------------------------- 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://www.ieee-pses.org/list.html (including how to unsubscribe) 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://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://www.ieee-pses.org/list.html (including how to unsubscribe) 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]>
