Comments inserted below.
Best wishes
John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK
On 2019-02-22 16:59, Kunde, Brian wrote:
Please help me to understand the “Marking” of equipment requirements
for systems made up of multiple components. I’m going to cross
categories for the purpose of the examples, so don’t get confused by that.
Example 1: I buy a PC. It comes in a large box. Inside I get a PC
tower, mouse, keyboard, speakers with power cube, and maybe a printer
with external power supply. Each of the individual pieces I listed
has its own Nameplate Label with Manufacturer’s name, model, serial, a
CE marking, blah blah blah. The manual has a page that looks like a
Declaration of Conformity and it identifies the PC. The DoC may also
have a statement that says something like, “includes all options and
configurations”.
Questions: Since each component has its own CE marking, shouldn’t each
component have its own DOC? If the model number on the PC and on the
provided DoC only covers the PC, how are products made up of many EE
identified and documented for CE? Should there be another label added
with a Model Number that encompasses the entire system and that number
be listed on the DoC? And if so, how do you know what components are
included with that model?
/JMW: PC, mouse and keyboard could be covered by one DoC. But the others
should have their own DoCs because they are testable separately, unless
the manufacturer claims that the package is a 'system', i.e. all parts
tested together, in which case the DoC must list the specific parts, not
just the PC or a general 'inclusion' statement./
Example 2: Laboratory equipment system made up many components such
as analyzers, heaters, sample loaders, ovens, external vacuum pumps,
power supplies, PCs, monitors, keyboards, mouse, robot arm,
measurement equipment, all interconnected and sold as a System with
integrated software. Each major component has its own Rating Label
(Nameplate Label). The manufacturer of the System sells it as a Model
SuperXYZ. Though this number is advertised and used to sell/order the
system, the number does not appear anywhere on the product. Should it
appear on the product? If so, where do you put it? What do you put on
your DoC? Does the manufacturer of the system have to provide DoCs for
every component?
/JMW: Again, it's a 'system', so the requirements are the same as above.
The system name 'Model XYZ' probably only need be on the packaging and
the documentation./
Example Last: In the above example, a USA company designs a builds a
small box that gets mounted on the back of one of the components
purchased from another company. A nameplate label is added to the box
with all the normal information including “Made in USA”. However,
when the combined product was shipped to another country, they were
told they couldn’t list the “Made in USA” because the larger component
it was attached to is made in a different country. I do not
understand the issue because the two are separate assemblies; each
having their own Nameplate label and power cord.
/JMW: 'Country of Origin' rules differ between countries, but I think
that in most countries the labelling you describe is correct, unless the
USA box is hard-wired into the larger unit. That is a 'manufacturing
operation' and that means that the whole thing has to be treated as
originating in the country where that happens./
Help me to understand.
Thanks,
The Other Brian
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