From: Ron Pickard <[email protected]> Subject: RE: CE Marking Richard, let me take a stab at this with some opinions.
>I have a question about CE Marking. > >If I am a manufacturer in member state of the European Union, and I make a > product which I sell exclusively to my customer located in the same member >state: > >Have I placed my product on the "Community Market" ? Yes, and you've left off the other condition, which is "placing into service" (I suppose your customer is doing that). I believe there is no difference between a EU manufacturer putting its product on the EU market and, say, a US manufacturer putting its product on the US market? Both have to adhere to the respective requirements. I can't fathom where a manufacturer would be immune to these requirements unless maybe the manufacturer/supplier happens to be a government (but, that's another story). >Or is this transaction only taking place within a "National Market" ? By your definition, this transaction is taking place within a member state of the EU. But, this does not obviate one from complying with the EMC and LV directives. This can be likened to the states of the US. Transacting within a US state, FCC and UL (standards only) regulation-wise, is no different than transacting from state-to-state. Compliance to these regulations is required. I believe this US scenario is also true for the EU as well. According to the EMC and LV directive, there is no distinction between transacting within a EU member state and transacting from state-to-state. >If there are EU Directives applicable to my type of product am I required >to place the CE Marking on my products (assuming they are compliant) ? Assuming these products are compliant, duh... Actually, it's up to you, your company and the risk you're willing to take of running afoul with the authorities. >Does anything change if my business is actually owned by a large >international company whose headquarters are not in the EU ? The requirements don't change to accommodate big or small companies that are located inside or outside the border. The requirements are the requirements, plain and simple. Otherwise, playing this game to satisfy special interests would become so convoluted that it would become an unmanageable nightmare. Us compliance types would then need to go to law school and become lawyers to work thru the maze. And, we all know we don't need any more lawyers. >My thanks to anyone who can provide some clarification here. You're very welcome and if anyone else out there wishes to comment, please do. I would also like to hear some opinions. Best regards, Ron Pickard
