Maybe I'm totally missing the point, but I think what Rick Towner initially might have been asking is;
If the customer were given the choice of a product that costs $10.00 without a CE mark or a product that costs $12.00 with the CE mark, which would he/she choose. Another way to put this is how much is it worth to the customer to reduce the risk that a hazard, that is addressed by CE marking, is mitigated. Maybe consumers would be better off letting the market place control what is safe and what is unsafe or what emits RF and what doesn't and what is immune to things and what is not. It would make for alot more interesting stories on Dateline and Prime Time Live, and their counterpart shows in Europe. Whatever happened to Caveat Emptor (Buyer Beware)! Besides, we have to keep the undertakers from starving, they need the business from stupid, unknowing consumers who buy cheap, chinsy products that don't comply with the requirements for CE making. Got carried away standing on my soapbox with sick humor. Please excuse me. Oh, I hope my soapbox is CE marked so I don't fall on my butt! I knew I should have used a CE marked ladder instead. Strictly my opinions, Jim ---------- From: treg-approval To: treg Subject: RE: CE MARK: Value-added?? Rephrased List-Post: [email protected] Date: Tuesday, April 08, 1997 8:54AM Some more waffle. A customer has a minimum right to expect that a product he/she purchases will a) be safe and b) will not interfere with (or be interfered by) other equipment he/she already owns. These are slight distortions of two of the philosophies behind a) the Low Voltage Directive and b) the EMC directive. No one in the position of purchasing products would argue with a), none of us would want to be harmed by our purchases. b) is slightly more esoteric but has validity given the increasingly crowded elecromagnetic enviroment as more and more intentional and unintentional transmitting gizmos are introduced. In addition, the idea behind CE marking is to remove barriers to trade within the European Union (and EEA). Many of you possibly do not have the history of dealing with national compliance requirements in each country and having to re-test to the same basic standards time and time again because there was no mutual recognition of test results. Now, generally, you only have to meet one set of standards, you can test your products anywhere you choose (or not test if you choose) and once confident in your product's compliance affix the CE mark and away you go. Sounds good so far? So does CE compliance add value. Well, I guess if you comply with all relevant directives and standards and you implement a compliance maintenance program which ensures that all products shipped remain compliant then you won't get slapped with a huge lawsuit due to your product killing someone, have your products withdrawn from the market, etc. This is probably worth something. To your customers it doesn't matter except for their reasonable expectation to get a product which is safe and does not interfere. No one is going to buy a product just because it has a CE mark because all products must carry CE marks. CE marking does not provide a product differentiator. Does CE compliance add cost? This is relative. Everybody has to comply with the same requirements so well designed, compliant products should be competively priced. Of course the price of producing a safe, unobtrusive product is probably a little higher than producing a lethal, noisy one but producing the latter is probably not good for repeat sales. Product compliance does give an opportunity for some competiveness. One thing to keep in mind is that not every company has the same access to competent design engineers (and/or standards) and the initial design is where value can be added to (or rather cost removed from) products. Designing compliance into products from the start is the thing to do. At that point solutions may cost cents rather than the dollars you expend when you get into retrofitting. A well designed product will sail through compliance testing saving re-test costs and most importantly time to market. The world of compliance engineering is constantly changing with much more responsibility being placed at the feet of the manufacturer and supplier. If we accept that there must be a minimum level of safety and EMC performance built into products then it could be argued that the compliance procedure doesn't get any better than the CE marking requirements. I would argue, proceduraly, that it is now much easier, for example, for US companies to deal with the European regulatory process than for European companies to deal with the US processes. There is a potential problem, however, related to the technical standards which we apply under the scope of the legislation. The European directives have opened the floodgates for the development of all manner of new technical standards. The EMC area in particular is subject to extensive over-standardisation, particularly with respect to product immunity. Having a lot of standards available covering a wide variety of interference phenomena is not a bad thing. Manufacturer's need all the reference material they can get. The problem is having immunity requirements for all of these phenomena applied as mandatory compliance criteria. If we think EMC testing and compliance is an onerous cost burden now, wait until 2001 or 2002 when some of these new requirements may have kicked in. Nick
