Me again 😊

The opening sentence tells you to tread carefully:

The CE mark is a certification mark that indicates conformity with health, 
safety, and environmental protection standards for products sold within the 
European Economic Area (EEA


  *   It’s not a “certification” mark
  *   Not all CE marking Directives cover safety or health
  *   There are no CE marking Directives that cover environmental protection
  *   The rules don’t apply to products “sold”, they apply to products “placed 
on the market” – there doesn’t need to be a monetary exchange, and the lack of 
one does not put you out of scope

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: rmm.priv...@gmail.com <rmm.priv...@gmail.com>
Sent: Sunday, October 8, 2023 4:56 PM
To: Charlie Blackham <char...@sulisconsultants.com>
Cc: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: RE: [PSES] AW: [PSES] Directives that require the CE Marking

I agree that tools like ChatGPT have a long way to go before their response can 
be trusted without question, but the response below is from the free version.  
The $20 a month version might provide a clearer answer.  I use ChatGPT as a 
starting point for topics I have some familiarity with, then I drill down on 
the details.

I asked ChatGPT “under what conditions should I not apply the CE Mark ?”, and 
it answered:

=====================================================================================
The CE mark is a certification mark that indicates conformity with health, 
safety, and environmental protection standards for products sold within the 
European Economic Area (EEA).  It demonstrates that a product complies with the 
relevant EU directives and regulations. However, there are certain conditions 
or situations where you should not apply the CE mark:

  1.  Non-conforming products: If your product does not meet the essential 
requirements or standards specified by the relevant EU directives or 
regulations, you should not apply the CE mark. It is essential to ensure that 
your product complies with all applicable requirements before affixing the CE 
mark.
  2.  Non-covered products: Some products or product categories may not be 
covered by specific EU directives or regulations, and therefore, the CE mark 
may not be applicable to them. Always check whether your product falls under 
any relevant EU legislation before considering the CE mark.
  3.  Self-declaration without applicable legislation: In some cases, a 
manufacturer may incorrectly self-declare conformity and affix the CE mark to a 
product without any applicable EU directive or regulation. This is not allowed, 
and the CE mark should only be applied when there is clear and relevant 
legislation to comply with.
  4.  Non-EEA sales: The CE mark is primarily intended for products intended 
for sale within the EEA. If your product is not intended for the EEA market, 
applying the CE mark may not be necessary. However, you should comply with the 
regulatory requirements of the specific market where you intend to sell your 
product.
  5.  Unauthorized use: The CE mark should only be applied by manufacturers or 
authorized representatives who have fulfilled the necessary conformity 
assessment procedures and legal obligations. Unauthorized use of the CE mark is 
not allowed and can result in legal consequences.
  6.  False or misleading information: Providing false or misleading 
information, documentation, or test results to obtain the CE mark is illegal 
and should not be done under any circumstances.

It's crucial to consult with regulatory authorities, experts, or legal counsel 
knowledgeable about the specific product and its applicable regulations to 
ensure compliance with CE marking requirements. Incorrectly applying the CE 
mark can lead to legal consequences, including fines and product recalls.
==================================================================================

Ralph

From: Charlie Blackham 
<char...@sulisconsultants.com<mailto:char...@sulisconsultants.com>>
Sent: Saturday, October 7, 2023 1:17 AM
To: rmm.priv...@gmail.com<mailto:rmm.priv...@gmail.com>; 
EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: RE: [PSES] AW: [PSES] Directives that require the CE Marking

A nice example of why ChatGPT won’t put us all out of a job just yet 😊

Point 9 is wrong – you may not use the CE mark to demonstrate compliance with a 
“non CE marking” Directive, that is one that does not contain the provision for 
CE marking within its Articles or Annexes

Point 3 does not make it clear that the Directive also includes products that 
are “likely, under reasonably foreseeable conditions, to be used by consumers 
even if not intended for them” – an example of this would be something like a 
corporate branded battery pack phone charger which is supplied only on a B2B 
basis, but is likely to be taken home by the recipient

Best regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: https://sulisconsultants.com/
Registered in England and Wales, number 05466247

From: Ralph McDiarmid <rmm.priv...@gmail.com<mailto:rmm.priv...@gmail.com>>
Sent: Friday, October 6, 2023 10:59 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] AW: [PSES] Directives that require the CE Marking

Here’s what ChatGPT told me about this directive:

The General Product Safety Directive (2001/95/EC) in the European Union (EU) is 
a legal framework designed to ensure the safety of consumer products placed on 
the EU market. It sets out general requirements for the safety of products, 
regardless of whether specific product safety regulations exist for them. Here 
are key aspects of the General Product Safety Directive (GPSD):

  1.  Scope: The GPSD applies to all consumer products, excluding food, 
pharmaceuticals, medical devices, cosmetics, and chemicals, which are covered 
by other specific regulations.
  2.  Safety Requirement: The primary objective of the GPSD is to ensure that 
products placed on the market are safe for consumers when used under normal or 
reasonably foreseeable conditions. Manufacturers and distributors have an 
obligation to provide safe products.
  3.  Definition of Consumer Products: The directive defines "consumer 
products" broadly to encompass any product intended for consumers, including 
both new and second-hand products.
  4.  Obligations of Economic Operators: Economic operators, including 
manufacturers, importers, and distributors, must ensure that products they 
place on the market are safe. They are responsible for assessing and managing 
risks, monitoring product safety, and taking corrective actions if safety 
issues arise.
  5.  Traceability: Economic operators must be able to trace the origin of the 
products they handle and, if necessary, inform the relevant authorities and 
consumers about safety issues or recalls.
  6.  Rapid Alert System: The GPSD establishes a Rapid Alert System for 
Non-Food (RAPEX) to facilitate the rapid exchange of information about 
dangerous products among EU member states and the European Commission. This 
system helps to ensure that dangerous products are quickly removed from the 
market.
  7.  Market Surveillance: EU member states are responsible for carrying out 
market surveillance activities to ensure compliance with the GPSD. They can 
take measures such as conducting inspections, ordering recalls, or imposing 
fines for non-compliance.
  8.  Cooperation with Other EU Legislation: The GPSD complements other EU 
product safety regulations, such as the Toy Safety Directive or the Machinery 
Directive. In cases where specific product safety legislation exists, that 
legislation takes precedence.
  9.  CE Marking: While the GPSD does not require products to bear the CE 
marking (a conformity marking indicating compliance with EU safety standards), 
manufacturers may choose to use it to demonstrate compliance with the directive.
  10. Harmonized Standards: Manufacturers can use harmonized European standards 
to demonstrate compliance with the GPSD's safety requirements.
The General Product Safety Directive plays a crucial role in protecting 
consumers within the EU by establishing a baseline level of safety for a wide 
range of consumer products. It encourages manufacturers and other economic 
operators to ensure that their products are safe for use and allows for swift 
action in the event of safety concerns. It is important to note that the GPSD 
is subject to updates and amendments to align with changing safety requirements 
and technological advancements.

Ralph

From: Dürrer Bernd <bernd.duer...@wilo.com<mailto:bernd.duer...@wilo.com>>
Sent: Tuesday, September 19, 2023 6:44 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: [PSES] AW: [PSES] Directives that require the CE Marking

Hello Brian,

in lack of any more specific EU Directive, a product will be in the scope of 
the General Product Safety Directive 2001/95/EC (Consolidated TEXT: 32001L0095 
— EN — 01.01.2010 
(europa.eu)<https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:02001L0095-20100101#tocId3>)
 that covers any product intended for consumers. As far as I know, the GPSD 
does neither require a CE Declaration of Conformity, nor CE marking on the 
product. An overview of EU Directives and applicable harmonized standards may 
be found at Harmonised Standards 
(europa.eu)<https://single-market-economy.ec.europa.eu/single-market/european-standards/harmonised-standards_en>.

Is the product intended to be permanently connected to a potable water supply? 
If yes, national regulations of EU member countries may apply.

Kind regards,

Bernd

Von: Brian Kunde <bkundew...@gmail.com<mailto:bkundew...@gmail.com>>
Gesendet: Dienstag, 19. September 2023 15:31
An: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Betreff: [PSES] Directives that require the CE Marking

[EXTERNAL E-MAIL] This email originated from outside of the organization. Do 
not click links or open attachments unless you recognize the sender.
I have a non-electrical benchtop product that holds a piece of sandpaper while 
slowly running water over the sandpaper. The only connection to this product is 
a water supply at normal water supply pressure.  The User holds the item they 
want to sand in their hand and rubs it back and forth on the sandpaper.  It is 
as simple as that.

Is there an EU Directive that covers this type of product and if so, is the 
Directive part of the CE Scheme?  I don't think there is but I am not familiar 
with all of the EU Directives.


So why am I asking?  Believe it or not, some Sales and Marketing types like to 
see the CE Marking on products. They feel it makes things sell better and it 
avoids uneducated customers from asking why there is no CE marking on the 
product.

Thanks for any advice, ideas, information, or suggestions.
The Other Brian


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