I think you are vulnerable using the procedure you describe. I think the
expectation of the Directive is that a test house receives a complete
product from the manufacturer and test it 'as is'. The test house should
not assemble parts (such as a selection of plug-in modules) to an
incomplete product. The manufacturer (not the test house) can perhaps
justify this procedure in its EMC assessment, but that would have to be
a deliberate act.
This applies in gold-plated spades if safety testing is involved.
On 2020-01-15 22:11, Brian Kunde wrote:
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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