Greetings.

I know this email is similar to Ragan's recent email, but I just had a
similar encounter. I could really use your help and wisdom.

Our company self declares to the CE requirements in Europe.  We also sell
products in the United States without NRLT certification but will obtain an
NRLT field evaluation upon request of our customer.  I manage a top-notch
corporate EMC and Product Safety Test laboratory where we perform all the
required examinations for CE.

We perform annual production audits.  The products received are nearly
completely assembled but lacking some components that may get broken during
shipment. These parts and some external components are shipped in separate
boxes called Component Packs.  We use some, but not all of the parts in
these packs to complete the assembly of the Product Under Test, and then
perform all of the required examination tests as part of the over-all
Conformity Assessment. The remaining parts we examine if necessary.  When
we are done with the product, we unassemble it to the state in which we
receive it and ship it back to where the product goes through re-testing
prior to shipping to the customer. The Component Packs have to be gone
through to ensure all the parts are still there and not broken.

Here is the problem.

Our shipping department does not want to have to re-count and re-pack the
Component Packs.  They have endlessly tried to convince management that we
do not need the packs or need every part in the packs. They want us to
either store the parts necessary to assemble the product for testing so
they don't have to send us any packs or we have to give them a list on only
the parts we need, which is a huge waste of our time.

So I'm looking for a clear or precise Examination or Conformity Assessment
Procedure that calls out that I have to get the Entire or Complete Product.

The closest thing I can find is in the 768/2008 document under Module B,
EC-Type Examination, section 2 where it states "examination of a
specimen, representative of the production envisaged, of the *complete
product.*  Unfortunately, this refers to the testing performed by a
Notified Body.

Is there any document that specified the requirements in detail of a
Conformity Assessment and Examination performed by the Manufacturer Test
Lab?

Thanks for any help.

The OTher Brian

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