Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

[Douglas E Powell]

There are other examples of exemptions.

My son works for a power conversion company in Colorado who deals with both
the US Military and NASA. There have been instances where their contract
specifically states you shall not use lead-free (RoHS) materials.
Apparently they are aware of the tin whisker problem and explicitly
prohibit the use of such materials.

Have a great weekend,

-Doug


Douglas E Powell
Laporte, Colorado USA
doug...@gmail.com
http://www.linkedin.com/in/dougp01

On Fri, Oct 22, 2021 at 4:35 AM Matthew Wilson | GBE <
matthew.wil...@gbelectronics.com> wrote:

> It’s old now but this article, written by someone working for TUV SUD, was
> handy for me when needing to deal with the ‘military exempt argument’ a
> while ago.
>
>
>
>
> https://www.newelectronics.co.uk/electronics-technology/the-military-ce-marking-conundrum/64803/
>
>
>
> It agrees with your stance, which I personally also agree with, FWIW.
>
>
>
> “They have informed us that there is a CE Marking Exemption for Military
> Equipment in France and Germany for these products”
>
>
>
> Why not ask them for documentary proof or some such of the exemption?
> They may well struggle!
>
>
>
> Good luck.
>
>
>
> Matthew Wilson,
>
> GB Electronics (UK) Ltd.
>
>
> Disclaimer:​ This email and any files transmitted with it are
> confidential and intended solely for the use of the individual or entity to
> whom they are addressed. If you have received this email in error please
> delete it from your system, do not use or disclose the information in any
> way and notify the sender immediately. The contents of this message may
> contain personal views which are not the views of the company, unless
> specifically stated.
> ​GB Electronics (UK) Ltd is a company registered in England and Wales
> under number 06210991.
> ​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea,
> West Sussex, BN12 4QY.
>
> *From:* Philip Stevenson 
> *Sent:* 21 October 2021 11:16
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] EU CE Marking Exemptions for Military Equipment Query
>
>
>
> Dear All
>
>
>
> I am contacting this forum for advice on whether there are any EU CE
> Marking Exemptions for Military Equipment in France and Germany?
>
>
>
> My reason for asking is that the manufacturers of Military off the shelf
> equipment (MOTS) who are based in France and Germany that we incorporate
> into some of our Military CE marked products which we manufacture. They
> have informed us that there is a CE Marking Exemption for Military
> Equipment in France and Germany for these products. These products are not
> covered by Article 296 and therefore not specifically exempt CE Marking.
> This equipment also falls within the scope of the EMC Directive.
>
>
>
> My view is that Military equipment not covered by Article 296 do not have
> a general exemption to CE marking EMC requirements and that exemptions for
> specific applications are contained within certain directives such as
> 2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other
> directives such as EMC and Low Voltage Directives do not contain any
> exemption.
>
>
>
> Is my assessment correct?
>
>
>
> If you prefer please contact me directly at my personal Email address
> below and I will not post these replies online.
>
>
>
> Regards
>
>
>
> Philip Stevenson
>
>
>
> Email: pw...@hotmail.co.uk
>
>
>
> -
> 
>
> This message is from the IEEE Product Safety Engineering Society emc-pstc
> discussion list. To post a message to the list, send your e-mail to <
> emc-p...@ieee.org>
>
> All emc-pstc postings are archived and searchable on the web at:
> http://www.ieee-pses.org/emc-pstc.html
> 
>
> Attachments are not permitted but the IEEE PSES Online Communities site at
> http://product-compliance.oc.ieee.org/
> 
> can be used for graphics (in well-used formats), large files, etc.
>
> Website: http://www.ieee-pses.org/
> 

Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

[Charlie Blackham]

Philip

> They have informed us that there is a CE Marking Exemption for Military 
> Equipment in France and Germany for these products

I suspect what they mean is “our customers in France and Germany are not asking 
for evidence of CE compliance”

That’s perfectly fine – the customer has nothing to do with it as the 
obligation to comply with EMCD and LVD is on he manufacturer and they cannot be 
exempted by a customer.

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: Matthew Wilson | GBE 
Sent: 22 October 2021 11:35
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

It’s old now but this article, written by someone working for TUV SUD, was 
handy for me when needing to deal with the ‘military exempt argument’ a while 
ago.

https://www.newelectronics.co.uk/electronics-technology/the-military-ce-marking-conundrum/64803/

It agrees with your stance, which I personally also agree with, FWIW.

“They have informed us that there is a CE Marking Exemption for Military 
Equipment in France and Germany for these products”

Why not ask them for documentary proof or some such of the exemption?  They may 
well struggle!

Good luck.

Matthew Wilson,
GB Electronics (UK) Ltd.

[cid:image001.png@01D7C73E.196331F0]
Disclaimer:​ This email and any files transmitted with it are confidential and 
intended solely for the use of the individual or entity to whom they are 
addressed. If you have received this email in error please delete it from your 
system, do not use or disclose the information in any way and notify the sender 
immediately. The contents of this message may contain personal views which are 
not the views of the company, unless specifically stated.
​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.
From: Philip Stevenson mailto:pw...@hotmail.co.uk>>
Sent: 21 October 2021 11:16
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU CE Marking Exemptions for Military Equipment Query

Dear All

I am contacting this forum for advice on whether there are any EU CE Marking 
Exemptions for Military Equipment in France and Germany?

My reason for asking is that the manufacturers of Military off the shelf 
equipment (MOTS) who are based in France and Germany that we incorporate into 
some of our Military CE marked products which we manufacture. They have 
informed us that there is a CE Marking Exemption for Military Equipment in 
France and Germany for these products. These products are not covered by 
Article 296 and therefore not specifically exempt CE Marking. This equipment 
also falls within the scope of the EMC Directive.

My view is that Military equipment not covered by Article 296 do not have a 
general exemption to CE marking EMC requirements and that exemptions for 
specific applications are contained within certain directives such as 
2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other directives 
such as EMC and Low Voltage Directives do not contain any exemption.

Is my assessment correct?

If you prefer please contact me directly at my personal Email address below and 
I will not post these replies online.

Regards

Philip Stevenson

Email: pw...@hotmail.co.uk

-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/
 can be used for graphics (in well-used formats), large files, etc.

Website: 

Re: [PSES] EU CE Marking Exemptions for Military Equipment Query

[Matthew Wilson | GBE]

It's old now but this article, written by someone working for TUV SUD, was 
handy for me when needing to deal with the 'military exempt argument' a while 
ago.

https://www.newelectronics.co.uk/electronics-technology/the-military-ce-marking-conundrum/64803/

It agrees with your stance, which I personally also agree with, FWIW.

"They have informed us that there is a CE Marking Exemption for Military 
Equipment in France and Germany for these products"

Why not ask them for documentary proof or some such of the exemption?  They may 
well struggle!

Good luck.

Matthew Wilson,
GB Electronics (UK) Ltd.


Matthew Wilson
Technical Director
GB Electronics (UK) Ltd
matthew.wil...@gbelectronics.com
https://gbelectronics.uk
+44 (0)1903 244 500
Ascot House//Mulberry Close//Woods Way
Goring-by-Sea//West Sussex//BN12 4QY//UK

Disclaimer: This email and any files transmitted with it are confidential and 
intended solely for the use of the individual or entity to whom they are 
addressed. If you have received this email in error please delete it from your 
system, do not use or disclose the information in any way and notify the sender 
immediately. The contents of this message may contain personal views which are 
not the views of the company, unless specifically stated.
​GB Electronics (UK) Ltd is a company registered in England and Wales under 
number 06210991.
​Registered office: Ascot House Mulberry Close, Woods Way, Goring By Sea, West 
Sussex, BN12 4QY.
From: Philip Stevenson 
Sent: 21 October 2021 11:16
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] EU CE Marking Exemptions for Military Equipment Query

Dear All

I am contacting this forum for advice on whether there are any EU CE Marking 
Exemptions for Military Equipment in France and Germany?

My reason for asking is that the manufacturers of Military off the shelf 
equipment (MOTS) who are based in France and Germany that we incorporate into 
some of our Military CE marked products which we manufacture. They have 
informed us that there is a CE Marking Exemption for Military Equipment in 
France and Germany for these products. These products are not covered by 
Article 296 and therefore not specifically exempt CE Marking. This equipment 
also falls within the scope of the EMC Directive.

My view is that Military equipment not covered by Article 296 do not have a 
general exemption to CE marking EMC requirements and that exemptions for 
specific applications are contained within certain directives such as 
2014/53/EU Radio Equipment and 2011/65/RoHS  Directives, but other directives 
such as EMC and Low Voltage Directives do not contain any exemption.

Is my assessment correct?

If you prefer please contact me directly at my personal Email address below and 
I will not post these replies online.

Regards

Philip Stevenson

Email: pw...@hotmail.co.uk

-


This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a message to the list, send your e-mail to 
mailto:emc-p...@ieee.org>>

All emc-pstc postings are archived and searchable on the web at: 
http://www.ieee-pses.org/emc-pstc.html

Attachments are not permitted but the IEEE PSES Online Communities site at 
http://product-compliance.oc.ieee.org/
 can be used for graphics (in well-used formats), large files, etc.

Website: 
http://www.ieee-pses.org/
Instructions: http://www.ieee-pses.org/list.html (including how to