Hi Lauren -

I believe you are on the right track, and fortunately the EU does not seem
to be as concerned ("up tight"? anal?) about replacement parts as China;
however, I strongly recommend working closely with your Marketing group -
and keeping an eye on them.  My experience has been that carefully crafted
regulatory compliance procedures can be upended in a moment by Marketing
inspirations, and worse, their "minor" changes may not be reported to you.

As you considered, how the replacement parts are "put on the market" is a
central concern.  Are they only available through your Service group?  Can
customers - and only customers - order them directly?  Can anyone order
them (maybe online) although they are INTENDED only to be used in your
machine as replacement parts?  You need to know to plan your strategy.

Are they only components (such as circuit breakers or supplementary
protectors) that cannot be broken down to a lower level?  Or are they sold
as kits or assemblies, or possibly even "partly completed machinery"?
Those distinctions will affect labeling AND what shows up on shipping
invoices - which Customs will see.  Your supply chain may have weird and
wonderful twists and turns that are not entirely visible to you.

Of course, once you set up and verify the regulatorily compliant procedure
for this product, no doubt other products will need a similar treatment -
labeling, documentation, instructions for installers, etc.  Very important
also to check the procedure is being used correctly and maintained (things
can drift, I've found).  And we haven't even touched on "field upgrades"!

Good luck!

Best regards,
John McBain


On Wed, Sep 28, 2022 at 9:36 AM Lauren Crane <
00001afd08519f18-dmarc-requ...@listserv.ieee.org> wrote:

> Hello Experts,
>
>
>
> I am looking for help puzzling through a question – thinking in the
> context of large industrial machines – a total machine product that
> operates from LVD-voltages is out of scope of the LVD per se, but I am
> wondering about the LVD-voltage components.
>
>
>
> I am confident/certain the LVD-voltage components (e.g. circuit breakers,
> controllers, lighting) that enter the EU as a component of the machinery do
> not need to be CE marked for the LVD because, in that scenario, they are
> not products placed separately on the EU market.
>
>
>
> However, I am less confident about replacement parts for those same
> LVD-voltage components – they will be placed separately on the EU market.
> However, they are placed not for ‘general’ sale to the public, but with the
> intention of becoming, in effect, the component of a machine. My current
> thinking is that these components also do not need to be CE marked for the
> LVD, but it might smooth Custom’s clearance if they travel with a notice
> indicating they are replacement parts and not for ‘general’ sale.
>
>
>
> Does this seem to be sound logic?
>
>
>
> Best Regards,
>
> -Lauren
>
>
>
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