Regarding upgrade, it might be feasible to look at it this way, depending on the fine point details.
If the customer buys your upgrade parts in a B2B transaction (i.e. they essentially hire you to provide parts that will upgrade equipment they already own). Then the upgrade hardware is just components the customer is purchasing to expanding the functionality of a product they already own. Components intended for further incorporation in to a final product tend not to be directly in scope of many/most/all CE marking directives. The Customer, then, is on the hook for re-assessing their new product to applicable directives, and creating a new DoC. You, as a helpful supplier, can anticipate their needs and do much of the work for them. If you are marketing an upgrade kit that any J.Q. Public can purchase as an "expansion option" for their product, the situation is different. Then the item is more of an "accessory" an probably has to be CE marked etc.. on its own. Regards, Lauren Crane Tokyo Electron From: John Woodgate <[email protected]> Sent: Monday, August 12, 2019 2:06 PM To: [email protected] Subject: Re: [PSES] CE Marking and DoC for Multi Device Product That is what used to be called a 'system', although the term seems to have been dropped now. Each piece should be CE marked, otherwise the surveillance authorities won't know it's legitimate. You don't need a DoC for each bit, only for the system, but each bit needs an identifier, which could be a part number, but could also be something less nerdy. For example, if the whole system is called 'E-Box One', the bits could be marked 'EB1a', 'EB1b'... . Upgrade bits can refer to the system DoC provided they are explicitly included in it. They need the CE mark and the identifier. Supplying a replacement part IS officially 'marketing' in Europe. That is, in my opinion, the simplest solution. You might be able to claim that, as an add-on has no function on its own, other rules apply, but I think this is just adding a needless complication. However you describe the bits, they have to meet all applicable Directives and Regulations. There is no escape. Best wishes John Woodgate OOO-Own Opinions Only J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk> Rayleigh, Essex UK On 2019-08-12 19:31, Brian Kunde wrote: If I have an electronic product that I want to place on the market in Europe, and the product is made up of several individual electronic devices each powered by AC mains (packaged and sold together), do I place the CE marking on only one of the devices or all devices? And if the answer is "all devices", then do I need a DoC for each device or will one DoC be ok? If each device has its own identifier, can I just list all identifiers on the DoC? OR can I simply list what the devices are instead of their specific part numbers? In the same train of thought, If my product is called "E-box One", for example, AND the product is made up of many individual electronic devices each with their own identifying part number, does the marketing name "E-box One" have to be on at least one of the devices that make it up OR does it have to be on every one of the devices? How do we handle the case were say two years down the road a customer with a 4-device system wants to expand to a 5-device system? Individually these devices are nothing and could be viewed as an upgrade kit. Does this "kit" have to have its own CE Marking and DoC? What if the "kit" is not officially marketed; just the customer ordered a kit similar to ordering a replacement part? How should these be handled? Thanks, The Other Brian - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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