Don't think that having compliant components (modules) ever meant anywhere in the world that an end-product is compliant and need not be tested. If only that were true.
What the Directives say is that the Member States will deem that the "Essential Requirements" have been met, if the final assembly is compliant with a harmonized European standard. Even that is somewhat less than a categorical statement. I've been waiting for an opportunity where somebody would pay me to design a product that would meet all applicable standards, yet fail the intent of all of them and be hazardous. I think I could do it. The notion that a Declaration of Conformity is "an easy way out", is a complete misconception. To the contrary, it moves a large part of the burden of uncertainty from the conformity assessment body (CAB) to the manufacturer. The advantages are that the manufacturer no longer has to ship products to a CAB for testing and can get his/her product to market at a speed controlled by the manufacturer. not a CAB. PLUS, the manufacturer no longer has to trust CABs with their Intellectual Property Rights. (In many countries, that is not a problem, in some it is). Because of the pressure that marketing departments can put on approvals groups, combined with the draconian penalties for false declarations in some countries, CEOs in many corporations now ask for "a second opinion" from outside test houses, before they release products to market. Ciao, Vic Boersma
