Thank you all who responded to this thread. All inputs I got are generally in agreement, and in line with my opinions. Here are the conclusions. They are mainly applicable to custom design, but also extend to COTS equipment available on the market.
1. It is not relevant if subcontracted parts are CE marked or not. What's important is that they are compliant with the standards applicable to the end-product. We, as an integrator of the end-product, have to identify those standards and/or parts of them that are relevant to the purchased component. 2. The requested documentation shall be relevant for the public law (EU Directives/CE Marking) and the civil law (liability issues). 3. The needed documentation, for CE marking (under the public law), as we follow the TCF and/or the Standards route under various Directives, will consist of full copies of test reports/technical analysis/technical descriptions if the manufacturer is able to do all of these (audits might be required). If not, certificates from accredited labs are mandatory, and copies of test reports are needed if possible. 4. To cover eventual liability issues (civil law), the product integrator shall request a private compatibility statement (listing the suitable standards, product detailed description), and completed with additional purchase requirements, such as not allowing modification of the part in such a way that it might impact the compliance of the end product (or at least not allow to do that without notice). Alexandru Guidea CAE Inc. Montreal, CANADA >>>>Our company purchases power distribution equipment designed per our specs. This equipment is not put on the market, but integrated in our products, and does safety/EMC functions(EMI filtering, protection, emergency stop) among other things, in accordance to the EC Directives applicable to our product. We believe there is no point to have it CE marked but only compliant with the standards we need. The text of the EMC Directive reads "the manufacturer may subcontract certain operations, e.g., apparatus design or production, provided that he retains overall control and responsibility for the apparatus as a whole. By the same token, he may use ready-made items or components, CE marked or not, to produce the apparatus without losing his status as a manufacturer." We follow the Technical Construction File route for CE marking. What's the documentation required from our sub-contractors that proves compliance with the EN standards we indicate? Do we need complete copies of test reports, technical description, analysis, or just a statement of compliance would do the job? What's the legal value of such a paper in North-America? As we don't control their production (parts, quality, etc,) what's the documentation we shall request to ensure all production units are compliant? What's the industry/your practice in this case?>> ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Ron Pickard: emc-p...@hypercom.com Dave Heald: davehe...@attbi.com For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: http://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
