Re: [PSES] CE non-conformity statistics

[Regan Arndt]

Thanks everyone for your feedback and help. Greatly appreciated.
Perhaps someday AdCo, RAPEX and other surveillance authorities would have
their own blog and get some constructive feedback from the industry.
There is always room for improvement.

Regan

On Mon, Nov 5, 2018 at 8:06 AM Kunde, Brian  wrote:

> John,
>
>
>
> Exactly!!
>
>
>
> Even annex I of the Machinery Directive (EHSR) can only be applied to a
> product. Step 1 is for the manufacturer to make the determination of which
> sections of the EHSR apply to their product and which sections do not by
> means of the Risk Assessment. Only the manufacturer can make this
> determination, so how is a field inspector going to be able to evaluate a
> product without this information?  They just have to do the best they can
> and false non-compliances are going to be the result.
>
>
>
> The question is, are these false non-compliances making it into these
> annual reports?  If so, then the numbers may not be as meaningful as one
> might hope.
>
>
>
> *Brian Kunde*
>
> Manager • Compliance Engineering
>
> LECO Corp • Compliance Testing Center
>
>
>
> *From:* John Woodgate [mailto:j...@woodjohn.uk]
> *Sent:* Friday, November 02, 2018 5:43 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] CE non-conformity statistics
>
>
>
> There's more. The recommended format for EU DoCs, at least for electrical
> safety and EMC asserts conformity with Directives, not standards, and says
> it 'applies' standards, not conforms to them:
>
>
>
>
>
>
>
>
>
>
> *The object of the declaration described above is in conformity with the
> relevant Union harmonisation legislation: EMC Directive 2014/30/EU e.g. Low
> Voltage Directive (LVD) 2014/35/EU   The following harmonised standards and
> technical specifications have been applied:   Title, Date of
> standard/specification: e.g. EN 55014, aregearg + A1:2009 + A2:2011  *
>
> John Woodgate OOO-Own Opinions Only
>
> J M Woodgate and Associates www.woodjohn.uk
>
> Rayleigh, Essex UK
>
> On 2018-11-02 21:11, John Woodgate wrote:
>
> Your first paragraph states the problem, and 'technical violation - no
> action' is the way it's resolved.
>
> In a DoC, I wouldn't mention 'relevant' at all, particularly now the legal
> profession has got its hooks into the European compliance system. It really
> does look like a 'loophole creator', not only to a rabid regulator. The
> place to assert relevance/irrelevance is in the assessment document,
> whether for EMC or safety.
>
> John Woodgate OOO-Own Opinions Only
>
> J M Woodgate and Associates www.woodjohn.uk
>
> Rayleigh, Essex UK
>
> On 2018-11-02 20:38, Kunde, Brian wrote:
>
> John,
>
>
>
> I love your example of the Power Supply.  In this case, a “standard” says
> one thing, but the manufacturer did it a different way. The use of
> Standards to show compliance to a Directive is only voluntary.  In a Hazard
> Driven approach to safety, such a drop-dead requirement in a Standard
> should not be allowed unless you only look at standards as a guide to
> compliance, which they are.  In a Risk Assessment, if doing something one
> way over another would not cause an increase risk, then it would be
> considered compliant.
>
>
>
> But what about a Manufacturer’s Declaration of Compliance where they list
> standards? Do they have to abide by each of these standards to the letter
> to be compliant with the Directives? I don’t think so.  Many DoCs state
> this, “conforms with all relevant provisions of the following,” blah blah
> blah ….  to where a list of standards and technical specifications are
> listed.  But who is say what is relevant? The Manufacturer is given that
> authority in the NLF; not the inspector.
>
>
>
> This is all in fun and I’m not debating you on this.  The fact is, you can
> talk about “Hazard Driven” approach, or this or that, do lectures, write
> books, get your picture in CE Magazine, but what it all boils down to is
> making the inspectors happy.  Maybe we should call this “Inspector Driven”
> approach to Compliance.  Smile!!  Isn’t that what we do or try to do?
>
>
>
> The Other Brian
>
>
>
> *From:* John Woodgate [mailto:j...@woodjohn.uk ]
> *Sent:* Friday, November 02, 2018 2:53 PM
> *To:* Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] CE non-conformity statistics
>
>
>
> A typical technical non-compliance is incorrect marking of power supply
> data. Different standards have different requirements, and it's easy to
> mistakenly state, for example, the supply current when the standard
> requires the input power to be stated. Yes, the majority of repor

Re: [PSES] CE non-conformity statistics

[Kunde, Brian]

John,

Exactly!!

Even annex I of the Machinery Directive (EHSR) can only be applied to a 
product. Step 1 is for the manufacturer to make the determination of which 
sections of the EHSR apply to their product and which sections do not by means 
of the Risk Assessment. Only the manufacturer can make this determination, so 
how is a field inspector going to be able to evaluate a product without this 
information?  They just have to do the best they can and false non-compliances 
are going to be the result.

The question is, are these false non-compliances making it into these annual 
reports?  If so, then the numbers may not be as meaningful as one might hope.

Brian Kunde
Manager • Compliance Engineering
LECO Corp • Compliance Testing Center

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Friday, November 02, 2018 5:43 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics


There's more. The recommended format for EU DoCs, at least for electrical 
safety and EMC asserts conformity with Directives, not standards, and says it 
'applies' standards, not conforms to them:

The object of the declaration described above is in conformity with the 
relevant Union harmonisation legislation:
EMC Directive 2014/30/EU
e.g. Low Voltage Directive (LVD) 2014/35/EU


The following harmonised standards and technical specifications have been 
applied:

Title, Date of standard/specification:
e.g. EN 55014, aregearg + A1:2009 + A2:2011


John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-11-02 21:11, John Woodgate wrote:

Your first paragraph states the problem, and 'technical violation - no action' 
is the way it's resolved.

In a DoC, I wouldn't mention 'relevant' at all, particularly now the legal 
profession has got its hooks into the European compliance system. It really 
does look like a 'loophole creator', not only to a rabid regulator. The place 
to assert relevance/irrelevance is in the assessment document, whether for EMC 
or safety.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-11-02 20:38, Kunde, Brian wrote:
John,

I love your example of the Power Supply.  In this case, a “standard” says one 
thing, but the manufacturer did it a different way. The use of Standards to 
show compliance to a Directive is only voluntary.  In a Hazard Driven approach 
to safety, such a drop-dead requirement in a Standard should not be allowed 
unless you only look at standards as a guide to compliance, which they are.  In 
a Risk Assessment, if doing something one way over another would not cause an 
increase risk, then it would be considered compliant.

But what about a Manufacturer’s Declaration of Compliance where they list 
standards? Do they have to abide by each of these standards to the letter to be 
compliant with the Directives? I don’t think so.  Many DoCs state this, 
“conforms with all relevant provisions of the following,” blah blah blah ….  to 
where a list of standards and technical specifications are listed.  But who is 
say what is relevant? The Manufacturer is given that authority in the NLF; not 
the inspector.

This is all in fun and I’m not debating you on this.  The fact is, you can talk 
about “Hazard Driven” approach, or this or that, do lectures, write books, get 
your picture in CE Magazine, but what it all boils down to is making the 
inspectors happy.  Maybe we should call this “Inspector Driven” approach to 
Compliance.  Smile!!  Isn’t that what we do or try to do?

The Other Brian

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Friday, November 02, 2018 2:53 PM
To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] CE non-conformity statistics


A typical technical non-compliance is incorrect marking of power supply data. 
Different standards have different requirements, and it's easy to mistakenly 
state, for example, the supply current when the standard requires the input 
power to be stated. Yes, the majority of reported violations are minor and 
require no action, except that the manufacturer has to fix the issue for future 
production.

Another case, although I don't know if it would always be rated 'technical' is 
when the offending product is shown to have an unpredictable and random fault, 
which might well be caused by a component failure during early use, so that the 
product was probably compliant when new. I know of a case like that, where a 
ceramic capacitor fractured, which caused weak HF oscillation that was detected 
by an adjacent radio.

The issue of personal interpretations is embedded in the AHJ system and needs a 
total change of approach, which is not probable.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-11-02 18:31

Re: [PSES] CE non-conformity statistics

[John Woodgate]

There's more. The recommended format for EU DoCs, at least for 
electrical safety and EMC asserts conformity with Directives, not 
standards, and says it 'applies' standards, not conforms to them:


/The object of the declaration described above is in conformity with the 
relevant Union harmonisation legislation: //

//EMC Directive 2014/30/EU//
//e.g. Low Voltage Directive (LVD) 2014/35/EU //

//
//The following harmonised standards and technical specifications have 
been applied: //


//Title, Date of standard/specification://
//e.g. EN 55014, aregearg + A1:2009 + A2:2011 //
///

John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-11-02 21:11, John Woodgate wrote:


Your first paragraph states the problem, and 'technical violation - no 
action' is the way it's resolved.


In a DoC, I wouldn't mention 'relevant' at all, particularly now the 
legal profession has got its hooks into the European compliance 
system. It really does look like a 'loophole creator', not only to a 
rabid regulator. The place to assert relevance/irrelevance is in the 
assessment document, whether for EMC or safety.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk
Rayleigh, Essex UK
On 2018-11-02 20:38, Kunde, Brian wrote:


John,

I love your example of the Power Supply.  In this case, a “standard” 
says one thing, but the manufacturer did it a different way. The use 
of Standards to show compliance to a Directive is only voluntary.  In 
a Hazard Driven approach to safety, such a drop-dead requirement in a 
Standard should not be allowed unless you only look at standards as a 
guide to compliance, which they are.  In a Risk Assessment, if doing 
something one way over another would not cause an increase risk, then 
it would be considered compliant.


But what about a Manufacturer’s Declaration of Compliance where they 
list standards? Do they have to abide by each of these standards to 
the letter to be compliant with the Directives? I don’t think so.  
Many DoCs state this, “conforms with all relevant provisions of the 
following,” blah blah blah ….  to where a list of standards and 
technical specifications are listed.  But who is say what is 
relevant? The Manufacturer is given that authority in the NLF; not 
the inspector.


This is all in fun and I’m not debating you on this.  The fact is, 
you can talk about “Hazard Driven” approach, or this or that, do 
lectures, write books, get your picture in CE Magazine, but what it 
all boils down to is making the inspectors happy.  Maybe we should 
call this “Inspector Driven” approach to Compliance.  Smile!!  Isn’t 
that what we do or try to do?


The Other Brian

*From:*John Woodgate [mailto:j...@woodjohn.uk]
*Sent:* Friday, November 02, 2018 2:53 PM
*To:* Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] CE non-conformity statistics

A typical technical non-compliance is incorrect marking of power 
supply data. Different standards have different requirements, and 
it's easy to mistakenly state, for example, the supply current when 
the standard requires the input power to be stated. Yes, the majority 
of reported violations are minor and require no action, except that 
the manufacturer has to fix the issue for future production.


Another case, although I don't know if it would always be rated 
'technical' is when the offending product is shown to have an 
unpredictable and random fault, which might well be caused by a 
component failure during early use, so that the product was probably 
compliant when new. I know of a case like that, where a ceramic 
capacitor fractured, which caused weak HF oscillation that was 
detected by an adjacent radio.


The issue of personal interpretations is embedded in the AHJ system 
and needs a total change of approach, which is not probable.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-11-02 18:31, Kunde, Brian wrote:

Ok, I’ll pile on.

I have never been involved in a market surveillance inspection so
I really have no right to comment, but I am trying to understand
what constitutes itself as a Technical Non-Compliance.

Many of my products get inspected post-sale at our customer sites
by third-party labs or union inspectors doing a “Field
Evaluation”. Most inspections go very smoothly, but some
labs/inspectors write up every little thing they don’t understand
or cannot test in the field as a “Non-Compliance”.  Sometimes
they have their OWN interpretations of the rules and
documentation requirements.  Then our customer is placed in the
middle as we try to make the lab/inspector understand why the
product really is compliant.  I’m sure many of you have had
similar experiences.

When I see market surveillance reports with tens of thousands of
non-compliances listed but only a few dozen

Re: [PSES] CE non-conformity statistics

[John Woodgate]

Your first paragraph states the problem, and 'technical violation - no 
action' is the way it's resolved.


In a DoC, I wouldn't mention 'relevant' at all, particularly now the 
legal profession has got its hooks into the European compliance system. 
It really does look like a 'loophole creator', not only to a rabid 
regulator. The place to assert relevance/irrelevance is in the 
assessment document, whether for EMC or safety.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-11-02 20:38, Kunde, Brian wrote:


John,

I love your example of the Power Supply.  In this case, a “standard” 
says one thing, but the manufacturer did it a different way. The use 
of Standards to show compliance to a Directive is only voluntary.  In 
a Hazard Driven approach to safety, such a drop-dead requirement in a 
Standard should not be allowed unless you only look at standards as a 
guide to compliance, which they are.  In a Risk Assessment, if doing 
something one way over another would not cause an increase risk, then 
it would be considered compliant.


But what about a Manufacturer’s Declaration of Compliance where they 
list standards? Do they have to abide by each of these standards to 
the letter to be compliant with the Directives? I don’t think so.  
Many DoCs state this, “conforms with all relevant provisions of the 
following,” blah blah blah ….  to where a list of standards and 
technical specifications are listed.  But who is say what is relevant? 
The Manufacturer is given that authority in the NLF; not the inspector.


This is all in fun and I’m not debating you on this.  The fact is, you 
can talk about “Hazard Driven” approach, or this or that, do lectures, 
write books, get your picture in CE Magazine, but what it all boils 
down to is making the inspectors happy.  Maybe we should call this 
“Inspector Driven” approach to Compliance.  Smile!!  Isn’t that what 
we do or try to do?


The Other Brian

*From:*John Woodgate [mailto:j...@woodjohn.uk]
*Sent:* Friday, November 02, 2018 2:53 PM
*To:* Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG
*Subject:* Re: [PSES] CE non-conformity statistics

A typical technical non-compliance is incorrect marking of power 
supply data. Different standards have different requirements, and it's 
easy to mistakenly state, for example, the supply current when the 
standard requires the input power to be stated. Yes, the majority of 
reported violations are minor and require no action, except that the 
manufacturer has to fix the issue for future production.


Another case, although I don't know if it would always be rated 
'technical' is when the offending product is shown to have an 
unpredictable and random fault, which might well be caused by a 
component failure during early use, so that the product was probably 
compliant when new. I know of a case like that, where a ceramic 
capacitor fractured, which caused weak HF oscillation that was 
detected by an adjacent radio.


The issue of personal interpretations is embedded in the AHJ system 
and needs a total change of approach, which is not probable.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associateswww.woodjohn.uk <http://www.woodjohn.uk>
Rayleigh, Essex UK

On 2018-11-02 18:31, Kunde, Brian wrote:

Ok, I’ll pile on.

I have never been involved in a market surveillance inspection so
I really have no right to comment, but I am trying to understand
what constitutes itself as a Technical Non-Compliance.

Many of my products get inspected post-sale at our customer sites
by third-party labs or union inspectors doing a “Field
Evaluation”. Most inspections go very smoothly, but some
labs/inspectors write up every little thing they don’t understand
or cannot test in the field as a “Non-Compliance”.  Sometimes they
have their OWN interpretations of the rules and documentation
requirements.  Then our customer is placed in the middle as we try
to make the lab/inspector understand why the product really is
compliant.  I’m sure many of you have had similar experiences.

When I see market surveillance reports with tens of thousands of
non-compliances listed but only a few dozen cases where any kind
of real “action” is taken, the first thing I wonder is how
legitimate or serious are the bulk of the non-compliances in the
first place.  It makes me think that maybe the mass majority of
these cases are so minor that they simply become learning
experience for someone and only the rare and more serious
non-compliances result in fines or legal action.

Am I the only one who thinks this way?

Don’t get me wrong; I love these types of reports with big
numbers. If I want, I can use them to scare my superiors into
doing what I say.  I might even get more budget money to hire more
people or get more lab space.  But I really would like to know how
many of these non-compl

Re: [PSES] CE non-conformity statistics

[Kunde, Brian]

John,

I love your example of the Power Supply.  In this case, a “standard” says one 
thing, but the manufacturer did it a different way. The use of Standards to 
show compliance to a Directive is only voluntary.  In a Hazard Driven approach 
to safety, such a drop-dead requirement in a Standard should not be allowed 
unless you only look at standards as a guide to compliance, which they are.  In 
a Risk Assessment, if doing something one way over another would not cause an 
increase risk, then it would be considered compliant.

But what about a Manufacturer’s Declaration of Compliance where they list 
standards? Do they have to abide by each of these standards to the letter to be 
compliant with the Directives? I don’t think so.  Many DoCs state this, 
“conforms with all relevant provisions of the following,” blah blah blah ….  to 
where a list of standards and technical specifications are listed.  But who is 
say what is relevant? The Manufacturer is given that authority in the NLF; not 
the inspector.

This is all in fun and I’m not debating you on this.  The fact is, you can talk 
about “Hazard Driven” approach, or this or that, do lectures, write books, get 
your picture in CE Magazine, but what it all boils down to is making the 
inspectors happy.  Maybe we should call this “Inspector Driven” approach to 
Compliance.  Smile!!  Isn’t that what we do or try to do?

The Other Brian

From: John Woodgate [mailto:j...@woodjohn.uk]
Sent: Friday, November 02, 2018 2:53 PM
To: Kunde, Brian; EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics


A typical technical non-compliance is incorrect marking of power supply data. 
Different standards have different requirements, and it's easy to mistakenly 
state, for example, the supply current when the standard requires the input 
power to be stated. Yes, the majority of reported violations are minor and 
require no action, except that the manufacturer has to fix the issue for future 
production.

Another case, although I don't know if it would always be rated 'technical' is 
when the offending product is shown to have an unpredictable and random fault, 
which might well be caused by a component failure during early use, so that the 
product was probably compliant when new. I know of a case like that, where a 
ceramic capacitor fractured, which caused weak HF oscillation that was detected 
by an adjacent radio.

The issue of personal interpretations is embedded in the AHJ system and needs a 
total change of approach, which is not probable.

John Woodgate OOO-Own Opinions Only

J M Woodgate and Associates www.woodjohn.uk<http://www.woodjohn.uk>

Rayleigh, Essex UK
On 2018-11-02 18:31, Kunde, Brian wrote:
Ok, I’ll pile on.

I have never been involved in a market surveillance inspection so I really have 
no right to comment, but I am trying to understand what constitutes itself as a 
Technical Non-Compliance.

Many of my products get inspected post-sale at our customer sites by 
third-party labs or union inspectors doing a “Field Evaluation”. Most 
inspections go very smoothly, but some labs/inspectors write up every little 
thing they don’t understand or cannot test in the field as a “Non-Compliance”.  
Sometimes they have their OWN interpretations of the rules and documentation 
requirements.  Then our customer is placed in the middle as we try to make the 
lab/inspector understand why the product really is compliant.  I’m sure many of 
you have had similar experiences.

When I see market surveillance reports with tens of thousands of 
non-compliances listed but only a few dozen cases where any kind of real 
“action” is taken, the first thing I wonder is how legitimate or serious are 
the bulk of the non-compliances in the first place.  It makes me think that 
maybe the mass majority of these cases are so minor that they simply become 
learning experience for someone and only the rare and more serious 
non-compliances result in fines or legal action.

Am  I the only one who thinks this way?

Don’t get me wrong; I love these types of reports with big numbers. If I want, 
I can use them to scare my superiors into doing what I say.  I might even get 
more budget money to hire more people or get more lab space.  But I really 
would like to know how many of these non-compliances are really bad bad product 
verses barely failed product verses a poor execution of the difficult to 
interpret rules and regulations.

Please don’t beat me up too bad. When I’m bored my mind drifts down dark paths 
of no return.

The Other Brian




LECO Corporation Notice: This communication may contain confidential 
information intended for the named recipient(s) only. If you received this by 
mistake, please destroy it and notify us of the error. Thank you.

-

This message is from the IEEE Product Safety Engineering Society emc-pstc 
discussion list. To post a m

Re: [PSES] CE non-conformity statistics

[John Woodgate]

A typical technical non-compliance is incorrect marking of power supply 
data. Different standards have different requirements, and it's easy to 
mistakenly state, for example, the supply current when the standard 
requires the input power to be stated. Yes, the majority of reported 
violations are minor and require no action, except that the manufacturer 
has to fix the issue for future production.


Another case, although I don't know if it would always be rated 
'technical' is when the offending product is shown to have an 
unpredictable and random fault, which might well be caused by a 
component failure during early use, so that the product was probably 
compliant when new. I know of a case like that, where a ceramic 
capacitor fractured, which caused weak HF oscillation that was detected 
by an adjacent radio.


The issue of personal interpretations is embedded in the AHJ system and 
needs a total change of approach, which is not probable.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-11-02 18:31, Kunde, Brian wrote:


Ok, I’ll pile on.

I have never been involved in a market surveillance inspection so I 
really have no right to comment, but I am trying to understand what 
constitutes itself as a Technical Non-Compliance.


Many of my products get inspected post-sale at our customer sites by 
third-party labs or union inspectors doing a “Field Evaluation”. Most 
inspections go very smoothly, but some labs/inspectors write up every 
little thing they don’t understand or cannot test in the field as a 
“Non-Compliance”.  Sometimes they have their OWN interpretations of 
the rules and documentation requirements.  Then our customer is placed 
in the middle as we try to make the lab/inspector understand why the 
product really is compliant.  I’m sure many of you have had similar 
experiences.


When I see market surveillance reports with tens of thousands of 
non-compliances listed but only a few dozen cases where any kind of 
real “action” is taken, the first thing I wonder is how legitimate or 
serious are the bulk of the non-compliances in the first place.  It 
makes me think that maybe the mass majority of these cases are so 
minor that they simply become learning experience for someone and only 
the rare and more serious non-compliances result in fines or legal 
action.


Am I the only one who thinks this way?

Don’t get me wrong; I love these types of reports with big numbers. If 
I want, I can use them to scare my superiors into doing what I say.  I 
might even get more budget money to hire more people or get more lab 
space.  But I really would like to know how many of these 
non-compliances are really bad bad product verses barely failed 
product verses a poor execution of the difficult to interpret rules 
and regulations.


Please don’t beat me up too bad. When I’m bored my mind drifts down 
dark paths of no return.


The Other Brian





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Re: [PSES] CE non-conformity statistics

[Kunde, Brian]

Ok, I’ll pile on.

I have never been involved in a market surveillance inspection so I really have 
no right to comment, but I am trying to understand what constitutes itself as a 
Technical Non-Compliance.

Many of my products get inspected post-sale at our customer sites by 
third-party labs or union inspectors doing a “Field Evaluation”. Most 
inspections go very smoothly, but some labs/inspectors write up every little 
thing they don’t understand or cannot test in the field as a “Non-Compliance”.  
Sometimes they have their OWN interpretations of the rules and documentation 
requirements.  Then our customer is placed in the middle as we try to make the 
lab/inspector understand why the product really is compliant.  I’m sure many of 
you have had similar experiences.

When I see market surveillance reports with tens of thousands of 
non-compliances listed but only a few dozen cases where any kind of real 
“action” is taken, the first thing I wonder is how legitimate or serious are 
the bulk of the non-compliances in the first place.  It makes me think that 
maybe the mass majority of these cases are so minor that they simply become 
learning experience for someone and only the rare and more serious 
non-compliances result in fines or legal action.

Am  I the only one who thinks this way?

Don’t get me wrong; I love these types of reports with big numbers. If I want, 
I can use them to scare my superiors into doing what I say.  I might even get 
more budget money to hire more people or get more lab space.  But I really 
would like to know how many of these non-compliances are really bad bad product 
verses barely failed product verses a poor execution of the difficult to 
interpret rules and regulations.

Please don’t beat me up too bad. When I’m bored my mind drifts down dark paths 
of no return.

The Other Brian

From: Regan Arndt [mailto:reganar...@gmail.com]
Sent: Thursday, November 01, 2018 7:37 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

Hi Pete. Yes, it's a sad state of affairs. Our profession needs to do more or 
something different to turn this around.

I wish AdCo could release where these products originated from so we can focus 
our attention on improvements in these regions.

Anybody know of some examples of penalties/fines that have occurred recently?

I'm also surprised there was no cross-border market surveillance of just LVD or 
Machinery.   It appears they are just cherry picking the high profile 
products/categories.

On Thu, Nov 1, 2018 at 9:01 AM Pete Perkins 
mailto:peperkin...@cs.com>> wrote:
Regan,  Thanx for chasing down these statistics; very 
interesting.  For most of the folks on this forum the most interesting are the 
technical non-conformity issues.  The best/lowest is 14% for EMC and higher 
24%/25% for safety/radio.  Doesn’t speak well for our profession and influence 
on industry.  Yes, there are many others but most of them are Technical File 
paperwork issues.

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

IEEE Life Fellow
p.perk...@ieee.org<mailto:p.perk...@ieee.org>

From: Regan Arndt mailto:reganar...@gmail.com>>
Sent: Wednesday, October 31, 2018 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] CE non-conformity statistics

Thanks Charlie. I checked the latest on the RED. Below is an excerpt on the 
stats. Amazing. Wonder what the penalties were. h..

ADCO RED report to TCAM WG on market surveillance statistics for 2016

2. Results for 2016
Totally, 13,488 R equipment has been inspected by 25 market surveillance 
authorities in 2016: Austria, Cyprus, Denmark, Estonia, Finland, France, 
Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, Norway, 
Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, The 
Netherlands and United Kingdom. About 10391 equipment were been found 
non-compliant to the provisions of the R Directive. However, due to the 
fact that not all provisions were checked by all involved market surveillance 
authorities, the effective amount of non compliant equipment may be higher.

Summary of the results: • Overall : 10391 non compliant equipment (13488 
inspected equipment)

  *   Declaration of conformity : 9372 non compliant DoC (13224 inspected 
equipment)
  *   CE marking : 8307 non complaint CE marking (13371 inspected equipment)
  *   Geographical area for use : 3773 not compliances (11750 inspected 
equipment)
  *   Essential requirements : 579 technical non compliances (of 2131 measured 
equipment)
  *   Safety (art.3.1.a): 116 technical non compliances (of 488 measured 
equipment)
  *   EMC (art 3.1.b.): 84 technical non compliances (of 583 measured equipment)
  *   Radio (art.3.2.) : 434 technical non compliances (of 1755 measured 
equipment)
  *   T

Re: [PSES] CE non-conformity statistics

[Nyffenegger, Dave]

Most of the end users of our machinery in the EU have or hire their own 
consultant to do conformity assessment (MD/LVD) of new purchases as part of the 
procurement and acceptance process.  That sometimes gets interesting.

-Dave

From: Charlie Blackham [mailto:char...@sulisconsultants.com]
Sent: Friday, November 02, 2018 4:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

Many consumer items that fall under the LVD are dealt with under the GPSD are 
reported on RAPEX

Many machines don’t “freely move” about the EU and the Machinery Directive is 
enforced under national legislation – for example in the UK, the Health and 
Safety Executive enforce and prosecute using the Supply of Machinery 
Regulations 2008 and Provision of Work Equipment Regulations 1998 – however in 
many (perhaps all) cases, this is only done after someone has been injured, or 
worse, at work. However details of all prosecutions are released 
http://www.hse.gov.uk/press/press.htm which includes details of fines and 
imprisonment and 100’s of historical cases can be found at 
http://www.hse.gov.uk/prosecutions/default.asp

Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: Regan Arndt 
Sent: 01 November 2018 23:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

Hi Pete. Yes, it's a sad state of affairs. Our profession needs to do more or 
something different to turn this around.

I wish AdCo could release where these products originated from so we can focus 
our attention on improvements in these regions.

Anybody know of some examples of penalties/fines that have occurred recently?

I'm also surprised there was no cross-border market surveillance of just LVD or 
Machinery.   It appears they are just cherry picking the high profile 
products/categories.

On Thu, Nov 1, 2018 at 9:01 AM Pete Perkins 
mailto:peperkin...@cs.com>> wrote:
Regan,  Thanx for chasing down these statistics; very 
interesting.  For most of the folks on this forum the most interesting are the 
technical non-conformity issues.  The best/lowest is 14% for EMC and higher 
24%/25% for safety/radio.  Doesn’t speak well for our profession and influence 
on industry.  Yes, there are many others but most of them are Technical File 
paperwork issues.

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

IEEE Life Fellow
p.perk...@ieee.org<mailto:p.perk...@ieee.org>

From: Regan Arndt mailto:reganar...@gmail.com>>
Sent: Wednesday, October 31, 2018 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] CE non-conformity statistics

Thanks Charlie. I checked the latest on the RED. Below is an excerpt on the 
stats. Amazing. Wonder what the penalties were. h..

ADCO RED report to TCAM WG on market surveillance statistics for 2016

2. Results for 2016
Totally, 13,488 R equipment has been inspected by 25 market surveillance 
authorities in 2016: Austria, Cyprus, Denmark, Estonia, Finland, France, 
Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, Norway, 
Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, The 
Netherlands and United Kingdom. About 10391 equipment were been found 
non-compliant to the provisions of the R Directive. However, due to the 
fact that not all provisions were checked by all involved market surveillance 
authorities, the effective amount of non compliant equipment may be higher.

Summary of the results: • Overall : 10391 non compliant equipment (13488 
inspected equipment)

  *   Declaration of conformity : 9372 non compliant DoC (13224 inspected 
equipment)
  *   CE marking : 8307 non complaint CE marking (13371 inspected equipment)
  *   Geographical area for use : 3773 not compliances (11750 inspected 
equipment)
  *   Essential requirements : 579 technical non compliances (of 2131 measured 
equipment)
  *   Safety (art.3.1.a): 116 technical non compliances (of 488 measured 
equipment)
  *   EMC (art 3.1.b.): 84 technical non compliances (of 583 measured equipment)
  *   Radio (art.3.2.) : 434 technical non compliances (of 1755 measured 
equipment)
  *   Technical documentation: 276 non compliances (of 651 inspected equipment)
  *   Test reports: 236 non compliances (of 603 inspected equipment)
  *   Drawings and explanations: 47 non compliances (of 212 inspected equipment)
  *   Other elements: 79 non compliances (of 326 inspected equipment)
Regan

On Mon, Oct 29, 2018 at 4:47 PM Charlie Blackham 
mailto:char...@sulisconsultants.com>> wrote:
Regan

Market enforcement reports from the various “AdCos”, Admin

Re: [PSES] CE non-conformity statistics

[Kevin Robinson]

Here are a few more resources that attempt to compare rates of compliance 
between SDoC and 3rd party conformity assessment.
http://www.ifia-federation.org/content/wp-content/uploads/IFIA_CIPC_239_2014-2016_Market_survey_report.pdf

https://www.regulations.gov/document?D=OSHA-2008-0032-0099




Kevin

From: Charlie Blackham 
Sent: Friday, November 2, 2018 4:28:13 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

Many consumer items that fall under the LVD are dealt with under the GPSD are 
reported on RAPEX

Many machines don’t “freely move” about the EU and the Machinery Directive is 
enforced under national legislation – for example in the UK, the Health and 
Safety Executive enforce and prosecute using the Supply of Machinery 
Regulations 2008 and Provision of Work Equipment Regulations 1998 – however in 
many (perhaps all) cases, this is only done after someone has been injured, or 
worse, at work. However details of all prosecutions are released 
http://www.hse.gov.uk/press/press.htm which includes details of fines and 
imprisonment and 100’s of historical cases can be found at 
http://www.hse.gov.uk/prosecutions/default.asp

Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: Regan Arndt 
Sent: 01 November 2018 23:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

Hi Pete. Yes, it's a sad state of affairs. Our profession needs to do more or 
something different to turn this around.

I wish AdCo could release where these products originated from so we can focus 
our attention on improvements in these regions.

Anybody know of some examples of penalties/fines that have occurred recently?

I'm also surprised there was no cross-border market surveillance of just LVD or 
Machinery.   It appears they are just cherry picking the high profile 
products/categories.

On Thu, Nov 1, 2018 at 9:01 AM Pete Perkins 
mailto:peperkin...@cs.com>> wrote:
Regan,  Thanx for chasing down these statistics; very 
interesting.  For most of the folks on this forum the most interesting are the 
technical non-conformity issues.  The best/lowest is 14% for EMC and higher 
24%/25% for safety/radio.  Doesn’t speak well for our profession and influence 
on industry.  Yes, there are many others but most of them are Technical File 
paperwork issues.

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

IEEE Life Fellow
p.perk...@ieee.org<mailto:p.perk...@ieee.org>

From: Regan Arndt mailto:reganar...@gmail.com>>
Sent: Wednesday, October 31, 2018 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] CE non-conformity statistics

Thanks Charlie. I checked the latest on the RED. Below is an excerpt on the 
stats. Amazing. Wonder what the penalties were. h..

ADCO RED report to TCAM WG on market surveillance statistics for 2016

2. Results for 2016
Totally, 13,488 R equipment has been inspected by 25 market surveillance 
authorities in 2016: Austria, Cyprus, Denmark, Estonia, Finland, France, 
Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, Norway, 
Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, The 
Netherlands and United Kingdom. About 10391 equipment were been found 
non-compliant to the provisions of the R Directive. However, due to the 
fact that not all provisions were checked by all involved market surveillance 
authorities, the effective amount of non compliant equipment may be higher.

Summary of the results: • Overall : 10391 non compliant equipment (13488 
inspected equipment)

  *   Declaration of conformity : 9372 non compliant DoC (13224 inspected 
equipment)
  *   CE marking : 8307 non complaint CE marking (13371 inspected equipment)
  *   Geographical area for use : 3773 not compliances (11750 inspected 
equipment)
  *   Essential requirements : 579 technical non compliances (of 2131 measured 
equipment)
  *   Safety (art.3.1.a): 116 technical non compliances (of 488 measured 
equipment)
  *   EMC (art 3.1.b.): 84 technical non compliances (of 583 measured equipment)
  *   Radio (art.3.2.) : 434 technical non compliances (of 1755 measured 
equipment)
  *   Technical documentation: 276 non compliances (of 651 inspected equipment)
  *   Test reports: 236 non compliances (of 603 inspected equipment)
  *   Drawings and explanations: 47 non compliances (of 212 inspected equipment)
  *   Other elements: 79 non compliances (of 326 inspected equipment)
Regan

On Mon, Oct 29, 2018 at 4:47 PM Charlie Blackham 
mailto:char...@sulisconsultants.com>> wr

Re: [PSES] CE non-conformity statistics

[Charlie Blackham]

Many consumer items that fall under the LVD are dealt with under the GPSD are 
reported on RAPEX

Many machines don’t “freely move” about the EU and the Machinery Directive is 
enforced under national legislation – for example in the UK, the Health and 
Safety Executive enforce and prosecute using the Supply of Machinery 
Regulations 2008 and Provision of Work Equipment Regulations 1998 – however in 
many (perhaps all) cases, this is only done after someone has been injured, or 
worse, at work. However details of all prosecutions are released 
http://www.hse.gov.uk/press/press.htm which includes details of fines and 
imprisonment and 100’s of historical cases can be found at 
http://www.hse.gov.uk/prosecutions/default.asp

Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.sulisconsultants.com<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
Registered in England and Wales, number 05466247

From: Regan Arndt 
Sent: 01 November 2018 23:37
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

Hi Pete. Yes, it's a sad state of affairs. Our profession needs to do more or 
something different to turn this around.

I wish AdCo could release where these products originated from so we can focus 
our attention on improvements in these regions.

Anybody know of some examples of penalties/fines that have occurred recently?

I'm also surprised there was no cross-border market surveillance of just LVD or 
Machinery.   It appears they are just cherry picking the high profile 
products/categories.

On Thu, Nov 1, 2018 at 9:01 AM Pete Perkins 
mailto:peperkin...@cs.com>> wrote:
Regan,  Thanx for chasing down these statistics; very 
interesting.  For most of the folks on this forum the most interesting are the 
technical non-conformity issues.  The best/lowest is 14% for EMC and higher 
24%/25% for safety/radio.  Doesn’t speak well for our profession and influence 
on industry.  Yes, there are many others but most of them are Technical File 
paperwork issues.

:>) br,  Pete

Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe  97281-3427

503/452-1201

IEEE Life Fellow
p.perk...@ieee.org<mailto:p.perk...@ieee.org>

From: Regan Arndt mailto:reganar...@gmail.com>>
Sent: Wednesday, October 31, 2018 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>
Subject: Re: [PSES] CE non-conformity statistics

Thanks Charlie. I checked the latest on the RED. Below is an excerpt on the 
stats. Amazing. Wonder what the penalties were. h..

ADCO RED report to TCAM WG on market surveillance statistics for 2016

2. Results for 2016
Totally, 13,488 R equipment has been inspected by 25 market surveillance 
authorities in 2016: Austria, Cyprus, Denmark, Estonia, Finland, France, 
Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, Norway, 
Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, The 
Netherlands and United Kingdom. About 10391 equipment were been found 
non-compliant to the provisions of the R Directive. However, due to the 
fact that not all provisions were checked by all involved market surveillance 
authorities, the effective amount of non compliant equipment may be higher.

Summary of the results: • Overall : 10391 non compliant equipment (13488 
inspected equipment)

  *   Declaration of conformity : 9372 non compliant DoC (13224 inspected 
equipment)
  *   CE marking : 8307 non complaint CE marking (13371 inspected equipment)
  *   Geographical area for use : 3773 not compliances (11750 inspected 
equipment)
  *   Essential requirements : 579 technical non compliances (of 2131 measured 
equipment)
  *   Safety (art.3.1.a): 116 technical non compliances (of 488 measured 
equipment)
  *   EMC (art 3.1.b.): 84 technical non compliances (of 583 measured equipment)
  *   Radio (art.3.2.) : 434 technical non compliances (of 1755 measured 
equipment)
  *   Technical documentation: 276 non compliances (of 651 inspected equipment)
  *   Test reports: 236 non compliances (of 603 inspected equipment)
  *   Drawings and explanations: 47 non compliances (of 212 inspected equipment)
  *   Other elements: 79 non compliances (of 326 inspected equipment)
Regan

On Mon, Oct 29, 2018 at 4:47 PM Charlie Blackham 
mailto:char...@sulisconsultants.com>> wrote:
Regan

Market enforcement reports from the various “AdCos”, Administrative Cooperation 
Groups, can be found at 
http://ec.europa.eu/growth/single-market/goods/building-blocks/market-surveillance/organisation/administrative-cooperation-groups_en
 under the “Documents from the AdCo Groups)

As well as a number of reports on EMC, you may wish to look at the R/RED 
ones as well

Regards
Charlie

Charlie Blackham
Sulis Consultants Ltd
Tel: +44 (0)7946 624317
Web: 
www.suliscon

Re: [PSES] CE non-conformity statistics

[John Woodgate]

I think we have to be realistic. It is very costly to carry out 
technical assessments for EMC, which are the only way to detect 
violations. Safety is a bit different; violations can often simply be 
seen (or at least strongly suspected) by visual inspection, and 
laboratory testing may not be needed.


So for EMC, it's only economically viable to operate a complaint-driven 
approach, and we know that the proportion of cases of EMI that result in 
a complaint is low. In Britain, a government service continuously 
monitors the frequencies used by the emergency services, so protection 
of them is not complaint-driven. But CISPR is getting generalized 
complaints about potential interference with AM radio and amateur bands 
reception, which must have a lower priority.


Or we could all pay a lot more tax. You choose.

Of course, the profession can try to educate, which probably has some 
effect, but there are new potential violators coming on-stream all the 
time, so it must be a continuous process. It seems to me that what 
actually happens, mostly, is that IEEE, and similar smaller bodies, 
spends time educating its younger members, and not so much on educating 
manufacturers. Test houses and consultants have a dilemma - educate too 
well and you reduce your future revenue.


John Woodgate OOO-Own Opinions Only
J M Woodgate and Associates www.woodjohn.uk
Rayleigh, Essex UK

On 2018-11-01 23:37, Regan Arndt wrote:
Hi Pete. Yes, it's a sad state of affairs. Our profession needs to do 
more or something different to turn this around.


I wish AdCo could release where these products originated from so we 
can focus our attention on improvements in these regions.


Anybody know of some examples of penalties/fines that have occurred 
recently?


I'm also surprised there was no cross-border market surveillance of 
just LVD or Machinery.   It appears they are just cherry picking the 
high profile products/categories.






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Re: [PSES] CE non-conformity statistics

[Regan Arndt]

Hi Pete. Yes, it's a sad state of affairs. Our profession needs to do more
or something different to turn this around.

I wish AdCo could release where these products originated from so we can
focus our attention on improvements in these regions.

Anybody know of some examples of penalties/fines that have occurred
recently?

I'm also surprised there was no cross-border market surveillance of just
LVD or Machinery.   It appears they are just cherry picking the high
profile products/categories.

On Thu, Nov 1, 2018 at 9:01 AM Pete Perkins  wrote:

> Regan,  Thanx for chasing down these statistics; very
> interesting.  For most of the folks on this forum the most interesting are
> the technical non-conformity issues.  The best/lowest is 14% for EMC and
> higher 24%/25% for safety/radio.  Doesn’t speak well for our profession and
> influence on industry.  Yes, there are many others but most of them are
> Technical File paperwork issues.
>
>
>
> :>) br,  Pete
>
>
>
> Peter E Perkins, PE
>
> Principal Product Safety & Regulatory Affairs Consultant
>
> PO Box 23427
>
> Tigard, ORe  97281-3427
>
>
>
> 503/452-1201
>
>
>
> IEEE Life Fellow
>
> p.perk...@ieee.org
>
>
>
> *From:* Regan Arndt 
> *Sent:* Wednesday, October 31, 2018 3:52 PM
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* Re: [PSES] CE non-conformity statistics
>
>
>
> Thanks Charlie. I checked the latest on the RED. Below is an excerpt on
> the stats. Amazing. Wonder what the penalties were. h..
>
>
>
> ADCO RED report to TCAM WG on market surveillance statistics for 2016
>
>
>
> *2. Results for 2016 *
>
> Totally, 13,488 R equipment has been inspected by 25 market
> surveillance authorities in 2016: Austria, Cyprus, Denmark, Estonia,
> Finland, France, Germany, Greece, Hungary, Italy, Latvia, Lithuania,
> Luxembourg, Malta, Norway, Poland, Portugal, Romania, Slovakia, Slovenia,
> Spain, Sweden, Switzerland, The Netherlands and United Kingdom. About 10391
> equipment were been found non-compliant to the provisions of the R
> Directive. However, due to the fact that not all provisions were checked by
> all involved market surveillance authorities, the effective amount of non
> compliant equipment may be higher.
>
>
>
> *Summary of the results: **·** Overall : 10391 non compliant equipment
> (13488 inspected equipment)*
>
>- Declaration of conformity : 9372 non compliant DoC (13224 inspected
>equipment)
>- CE marking : 8307 non complaint CE marking (13371 inspected
>equipment)
>- Geographical area for use : 3773 not compliances (11750 inspected
>equipment)
>- Essential requirements : 579 technical non compliances (of 2131
>measured equipment)
>- Safety (art.3.1.a): 116 technical non compliances (of 488 measured
>equipment)
>- EMC (art 3.1.b.): 84 technical non compliances (of 583 measured
>equipment)
>- Radio (art.3.2.) : 434 technical non compliances (of 1755 measured
>equipment)
>- Technical documentation: 276 non compliances (of 651 inspected
>equipment)
>- Test reports: 236 non compliances (of 603 inspected equipment)
>- Drawings and explanations: 47 non compliances (of 212 inspected
>equipment)
>- Other elements: 79 non compliances (of 326 inspected equipment)
>
> Regan
>
>
>
> On Mon, Oct 29, 2018 at 4:47 PM Charlie Blackham <
> char...@sulisconsultants.com> wrote:
>
> Regan
>
>
>
> Market enforcement reports from the various “AdCos”, Administrative
> Cooperation Groups, can be found at
> http://ec.europa.eu/growth/single-market/goods/building-blocks/market-surveillance/organisation/administrative-cooperation-groups_en
> under the “Documents from the AdCo Groups)
>
>
>
> As well as a number of reports on EMC, you may wish to look at the
> R/RED ones as well
>
>
>
> Regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: **www.sulisconsultants.com*
> <https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Regan Arndt 
> *Sent:* 29 October 2018 23:34
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] CE non-conformity statistics
>
>
>
> Greetings fellow members,
>
>
>
> Out of curiosity, has anyone been privy to any recent EU statistics for
> those manufacturers who have been subjected to customs investigations
> pertaining to CE marking, penalties, sales bans, etc. due to, not only
> selling an unsaf

Re: [PSES] CE non-conformity statistics

[Pete Perkins]

Regan,  Thanx for chasing down these statistics; very 
interesting.  For most of the folks on this forum the most interesting are the 
technical non-conformity issues.  The best/lowest is 14% for EMC and higher 
24%/25% for safety/radio.  Doesn’t speak well for our profession and influence 
on industry.  Yes, there are many others but most of them are Technical File 
paperwork issues.  

 

:>) br,  Pete

 

Peter E Perkins, PE

Principal Product Safety & Regulatory Affairs Consultant

PO Box 23427

Tigard, ORe  97281-3427

 

503/452-1201

 

IEEE Life Fellow

 <mailto:p.perk...@ieee.org> p.perk...@ieee.org

 

From: Regan Arndt  
Sent: Wednesday, October 31, 2018 3:52 PM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] CE non-conformity statistics

 

Thanks Charlie. I checked the latest on the RED. Below is an excerpt on the 
stats. Amazing. Wonder what the penalties were. h..

  

ADCO RED report to TCAM WG on market surveillance statistics for 2016 

 

2. Results for 2016 

Totally, 13,488 R equipment has been inspected by 25 market surveillance 
authorities in 2016: Austria, Cyprus, Denmark, Estonia, Finland, France, 
Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, Malta, Norway, 
Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, Switzerland, The 
Netherlands and United Kingdom. About 10391 equipment were been found 
non-compliant to the provisions of the R Directive. However, due to the 
fact that not all provisions were checked by all involved market surveillance 
authorities, the effective amount of non compliant equipment may be higher. 

 

Summary of the results: * Overall : 10391 non compliant equipment (13488 
inspected equipment)

*   Declaration of conformity : 9372 non compliant DoC (13224 inspected 
equipment)
*   CE marking : 8307 non complaint CE marking (13371 inspected equipment)
*   Geographical area for use : 3773 not compliances (11750 inspected 
equipment)
*   Essential requirements : 579 technical non compliances (of 2131 
measured equipment)
*   Safety (art.3.1.a): 116 technical non compliances (of 488 measured 
equipment)
*   EMC (art 3.1.b.): 84 technical non compliances (of 583 measured 
equipment)
*   Radio (art.3.2.) : 434 technical non compliances (of 1755 measured 
equipment)
*   Technical documentation: 276 non compliances (of 651 inspected 
equipment)
*   Test reports: 236 non compliances (of 603 inspected equipment)
*   Drawings and explanations: 47 non compliances (of 212 inspected 
equipment)
*   Other elements: 79 non compliances (of 326 inspected equipment)

Regan

 

On Mon, Oct 29, 2018 at 4:47 PM Charlie Blackham mailto:char...@sulisconsultants.com> > wrote:

Regan

 

Market enforcement reports from the various “AdCos”, Administrative Cooperation 
Groups, can be found at 
http://ec.europa.eu/growth/single-market/goods/building-blocks/market-surveillance/organisation/administrative-cooperation-groups_en
 under the “Documents from the AdCo Groups)

 

As well as a number of reports on EMC, you may wish to look at the R/RED 
ones as well

 

Regards

Charlie 

 

Charlie Blackham

Sulis Consultants Ltd

Tel: +44 (0)7946 624317

Web:  
<https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f5=http%3a%2f%2fwww.sulisconsultants.com%2f>
 www.sulisconsultants.com

Registered in England and Wales, number 05466247

 

From: Regan Arndt mailto:reganar...@gmail.com> > 
Sent: 29 October 2018 23:34
To: EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@LISTSERV.IEEE.ORG> 
Subject: [PSES] CE non-conformity statistics

 

Greetings fellow members,

 

Out of curiosity, has anyone been privy to any recent EU statistics for those 
manufacturers who have been subjected to customs investigations pertaining to 
CE marking, penalties, sales bans, etc. due to, not only selling an unsafe 
product but, having no CE marking on product, no DoC, insufficient technical 
files, non-compliance to the directives, etc?

The only thing I can find on the web that has something close is from Yvonne 
Halpaus of QNET, LLC where she recently published a guide on CE marking in 
2015. An excerpt is below:

Findings in earlier reports show that 37,600 items of equipment tested in 
Switzerland showed 1,100 cases of CE Conformity problems. Of 3,962 items that 
were subjected to rigorous measurements, a high proportion of the devices were 
found defective (976 altogether) and that none of these met the EMC specified 
requirements. 

In 23 cases a sales ban was imposed and legal proceedings were launched. Two 
other Member States also revealed problems when testing against the EMC & 
Machinery Directive: 33% failed the EMC tests, 47% did not meet the Machinery 
Directive formal rules and 89% had technical non-conformities. 

These negative findings were not the result of regular surveillance mechanisms, 
58% was based on examinations triggered 

Re: [PSES] CE non-conformity statistics

[Regan Arndt]

Thanks Charlie. I checked the latest on the RED. Below is an excerpt on the
stats. Amazing. Wonder what the penalties were. h..

ADCO RED report to TCAM WG on market surveillance statistics for 2016

* 2. Results for 2016 *
Totally, 13,488 R equipment has been inspected by 25 market
surveillance authorities in 2016: Austria, Cyprus, Denmark, Estonia,
Finland, France, Germany, Greece, Hungary, Italy, Latvia, Lithuania,
Luxembourg, Malta, Norway, Poland, Portugal, Romania, Slovakia, Slovenia,
Spain, Sweden, Switzerland, The Netherlands and United Kingdom. About 10391
equipment were been found non-compliant to the provisions of the R
Directive. However, due to the fact that not all provisions were checked by
all involved market surveillance authorities, the effective amount of non
compliant equipment may be higher.

*Summary of the results:  Overall : 10391 non compliant equipment (13488
inspected equipment)*

   - Declaration of conformity : 9372 non compliant DoC (13224 inspected
   equipment)
   - CE marking : 8307 non complaint CE marking (13371 inspected equipment)
   - Geographical area for use : 3773 not compliances (11750 inspected
   equipment)
   - Essential requirements : 579 technical non compliances (of 2131
   measured equipment)
   - Safety (art.3.1.a): 116 technical non compliances (of 488 measured
   equipment)
   - EMC (art 3.1.b.): 84 technical non compliances (of 583 measured
   equipment)
   - Radio (art.3.2.) : 434 technical non compliances (of 1755 measured
   equipment)
   - Technical documentation: 276 non compliances (of 651 inspected
   equipment)
   - Test reports: 236 non compliances (of 603 inspected equipment)
   - Drawings and explanations: 47 non compliances (of 212 inspected
   equipment)
   - Other elements: 79 non compliances (of 326 inspected equipment)

Regan

On Mon, Oct 29, 2018 at 4:47 PM Charlie Blackham <
char...@sulisconsultants.com> wrote:

> Regan
>
>
>
> Market enforcement reports from the various “AdCos”, Administrative
> Cooperation Groups, can be found at
> http://ec.europa.eu/growth/single-market/goods/building-blocks/market-surveillance/organisation/administrative-cooperation-groups_en
> under the “Documents from the AdCo Groups)
>
>
>
> As well as a number of reports on EMC, you may wish to look at the
> R/RED ones as well
>
>
>
> Regards
>
> Charlie
>
>
>
> *Charlie Blackham*
>
> *Sulis Consultants Ltd*
>
> *Tel: +44 (0)7946 624317*
>
> *Web: **www.sulisconsultants.com*
> 
>
> Registered in England and Wales, number 05466247
>
>
>
> *From:* Regan Arndt 
> *Sent:* 29 October 2018 23:34
> *To:* EMC-PSTC@LISTSERV.IEEE.ORG
> *Subject:* [PSES] CE non-conformity statistics
>
>
>
> Greetings fellow members,
>
>
>
> Out of curiosity, has anyone been privy to any recent EU statistics for
> those manufacturers who have been subjected to customs investigations
> pertaining to CE marking, penalties, sales bans, etc. due to, not only
> selling an unsafe product but, having no CE marking on product, no DoC,
> insufficient technical files, non-compliance to the directives, etc?
>
> The only thing I can find on the web that has something close is from
> Yvonne Halpaus of QNET, LLC where she recently published a guide on CE
> marking in 2015. An excerpt is below:
>
> *Findings in earlier reports show that 37,600 items of equipment tested in
> Switzerland showed 1,100 cases of CE Conformity problems. Of 3,962 items
> that were subjected to rigorous measurements, a high proportion of the
> devices were found defective (976 altogether) and that none of these met
> the EMC specified requirements. *
>
> *In 23 cases a sales ban was imposed and legal proceedings were launched.
> Two other Member States also revealed problems when testing against the EMC
> & Machinery Directive: 33% failed the EMC tests, 47% did not meet the
> Machinery Directive formal rules and 89% had technical non-conformities. *
>
> *These negative findings were not the result of regular surveillance
> mechanisms, 58% was based on examinations triggered by accidents, 33.3%
> following inspection of equipment installation, 8.5% based on complaints
> from competing manufacturers and 0.2% following visits to trade fairs*.
>
>
>
>  Thanks for sharing any information you have. I'm wanting to update my CE
> marking training slides with some good solid facts.
>
>  Regan Arndt
>
> -
> 
>
> 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 

Re: [PSES] CE non-conformity statistics

[Doug Nix]

I’d be very interested in seeing more on this topic as well. I frequently get 
questions from my clients regarding EU enforcement activities.

Doug Nix
d...@ieee.org
+1 (519) 729-5704

> On 29-Oct-18, at 19:34, Regan Arndt  wrote:
> 
> Greetings fellow members,
> 
> 
> 
> Out of curiosity, has anyone been privy to any recent EU statistics for those 
> manufacturers who have been subjected to customs investigations pertaining to 
> CE marking, penalties, sales bans, etc. due to, not only selling an unsafe 
> product but, having no CE marking on product, no DoC, insufficient technical 
> files, non-compliance to the directives, etc?
> 
> The only thing I can find on the web that has something close is from Yvonne 
> Halpaus of QNET, LLC where she recently published a guide on CE marking in 
> 2015. An excerpt is below:
> 
> Findings in earlier reports show that 37,600 items of equipment tested in 
> Switzerland showed 1,100 cases of CE Conformity problems. Of 3,962 items that 
> were subjected to rigorous measurements, a high proportion of the devices 
> were found defective (976 altogether) and that none of these met the EMC 
> specified requirements.
> 
> In 23 cases a sales ban was imposed and legal proceedings were launched. Two 
> other Member States also revealed problems when testing against the EMC & 
> Machinery Directive: 33% failed the EMC tests, 47% did not meet the Machinery 
> Directive formal rules and 89% had technical non-conformities.
> 
> These negative findings were not the result of regular surveillance 
> mechanisms, 58% was based on examinations triggered by accidents, 33.3% 
> following inspection of equipment installation, 8.5% based on complaints from 
> competing manufacturers and 0.2% following visits to trade fairs.
> 
> 
> 
>  Thanks for sharing any information you have. I'm wanting to update my CE 
> marking training slides with some good solid facts. 
> 
>  Regan Arndt
> 
> -
> 
> 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 
> unsubscribe) 
> List rules: http://www.ieee-pses.org/listrules.html 
> 
> For help, send mail to the list administrators:
> Scott Douglas mailto:sdoug...@ieee.org>>
> Mike Cantwell mailto:mcantw...@ieee.org>>
> 
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> David Heald mailto:dhe...@gmail.com>>
> 


-

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 


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 unsubscribe)
List rules: http://www.ieee-pses.org/listrules.html

For help, send mail to the list administrators:
Scott Douglas 
Mike Cantwell 

For policy questions, send mail to:
Jim Bacher:  
David Heald: 

Re: [PSES] CE non-conformity statistics

[Charlie Blackham]

Regan

Market enforcement reports from the various “AdCos”, Administrative Cooperation 
Groups, can be found at 
http://ec.europa.eu/growth/single-market/goods/building-blocks/market-surveillance/organisation/administrative-cooperation-groups_en
 under the “Documents from the AdCo Groups)

As well as a number of reports on EMC, you may wish to look at the R/RED 
ones as well

Regards
Charlie

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

From: Regan Arndt 
Sent: 29 October 2018 23:34
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: [PSES] CE non-conformity statistics

Greetings fellow members,

Out of curiosity, has anyone been privy to any recent EU statistics for those 
manufacturers who have been subjected to customs investigations pertaining to 
CE marking, penalties, sales bans, etc. due to, not only selling an unsafe 
product but, having no CE marking on product, no DoC, insufficient technical 
files, non-compliance to the directives, etc?
The only thing I can find on the web that has something close is from Yvonne 
Halpaus of QNET, LLC where she recently published a guide on CE marking in 
2015. An excerpt is below:
Findings in earlier reports show that 37,600 items of equipment tested in 
Switzerland showed 1,100 cases of CE Conformity problems. Of 3,962 items that 
were subjected to rigorous measurements, a high proportion of the devices were 
found defective (976 altogether) and that none of these met the EMC specified 
requirements.
In 23 cases a sales ban was imposed and legal proceedings were launched. Two 
other Member States also revealed problems when testing against the EMC & 
Machinery Directive: 33% failed the EMC tests, 47% did not meet the Machinery 
Directive formal rules and 89% had technical non-conformities.
These negative findings were not the result of regular surveillance mechanisms, 
58% was based on examinations triggered by accidents, 33.3% following 
inspection of equipment installation, 8.5% based on complaints from competing 
manufacturers and 0.2% following visits to trade fairs.

 Thanks for sharing any information you have. I'm wanting to update my CE 
marking training slides with some good solid facts.
 Regan Arndt
-


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: 
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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/
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David Heald mailto:dhe...@gmail.com>>

-

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discussion list. To post a message to the list, send your e-mail to 


All emc-pstc postings are archived and searchable on the web at:
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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 unsubscribe)
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Mike Cantwell 

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Jim Bacher:  
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