If I recall correctly, compliance to the EMC, or other directives, is
not to cross borders (but it is required when crossing borders!) but
rather to impose requirements on each member country (15 or so, and a
few more "associate members") that they must comply with those rules.
The countries then will impose requirements that apply to commerce.
Remember that EU directives apply only to countries and not to
commerce. If a certain nation requires CE marking or compliance to a
EU directive it is because that nation requires it.
______________________________ Reply Separator _________________________________
Subject: BOUNCE [email protected]: Non-member submission from [
Author: Non-HP-jdc ([email protected]) at HP-ColSprings,mimegw5
List-Post: [email protected]
Date: 9/12/97 8:38 AM
From: "Rene Debets" <[email protected]>
----------
From: [email protected] on behalf of Jon D Curtis
Sent: Thursday, September 11, 1997 5:04 PM
To: [email protected]
Subject: BOUNCE [email protected]: Non-member submission from
[[email protected]] (fwd)
From: [email protected]
Subject: Re: CE Marking
Hello there,
I'm new to this forum, but couldn't resist giving my opinion.
Richard wrote:
>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" ?
>
>Or is this transaction only taking place within a "National Market" ?
>
>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) ?
>
>Does anything change if my business is actually owned by a large
>international company whose headquarters are not in the EU ?
My response we should remember that compliance with the EU
Directives is required to cross EU borders. We show compliance with
the applicable directives by placing the CE mark on our products.
However if you manufacture and supply a product only in country A,
then do the EU Directives apply and do we apply the CE mark?
There is no requirement to comply with the EU Directives in this scenario
or to apply the CE mark. However each of the EU countries has assimilated the
EU directives into their National Regulations, so as the national regulations
of Country A must be complied with, then steps are being taken to comply with
the EU Directives. All that should remain is the CE mark and a Declaration of
Conformity.
By manufacturing and selling a product in country 'A' in Europe you are
effectively
placing this product on the EC market (since there are no limits on moving
goods
once they are placed on the EC market) and as a result you allways have to
apply
at least the basic the CE mark. The telecom CE mark can be avoided by applying
for
approval to a national standard (if they still exist).
The scenario is the same if your company is owned outside the EU, but you
manufacture within the EU. The scenario is different if your owned by a non EU
company and you only import their goods to the EU. You are then the first
importer
of these goods to the EU and as such, are responsible for ensuring compliance
with the EU Directives (the goods are afterall crossing an EU Border).
The border crossing is irrelevant. Anybody inside or outside the EC who places
goods
on the EC market is responsible for complying with the requirements for
putting on the
CE mark. Manufacturer and importer can decide who will carry the
responsibility for the
CE mark. The one who signs (person) is the one held responsible.
Best regards, Rene Debets
Cynthia wrote:
>From: [email protected]
>Date: 04-Aug-97
>
>
>
>Under the TTE directive, it would depend on your product type,
>but most would require a CE XXX crossed hockey stick. WIth
>XXX being the number of the notified body that granted approval.
>
Could someone direct me to a location on the web, where I may pick up
these TTE graphics (the annex VI and Annex VII markings).
Cheers,
Colin McGeechan,
Product Regulations Specialist,
Hewlett-Packard Ltd,
[email protected]
RCIC - http://www.rcic.com
Regulatory Compliance Information Center
