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You may be able to self-certify on the basis that all the components
are
certified, and simply keep records of this, though.
If something goes wrong, however, it's a general principle that
the
retailer is always responsible... since it's the retailer who enters into a
contract with the end user.
The retailer would then need to demonstrate that they'd made every
effort
to be compliant, and that the problem lay further up the chain.
Actually... just had a scarey thought... will post in another
thread...
-----Original Message-----
From: Nikola Kasic
[mailto:nikola@xxxxxxx]
Sent: Thu 30/05/2002 11:37
To:
ukha_d@xxxxxxx
Cc:
Subject: RE: [ukha_d] Re: CE
certification
Thanks Tony.
One
more interesting question:
If I
sell everything as a kit consisting of CE compliant components what's the
situation then.
E.g.
I found all the components to build TiVo or similar and I prepare software,
self unpacking ISO image. Then I don't want to bother assembling and
installing the things, but I sell it as a kit. All the components are CE
compliant.
Will
I be responsible, if when assembled resulting product is not, or do I have
to
certify resulting product?
Cheers,
Nik
Sorry, I started typing this
before lunch, then came back and saw several
replies. I hope what
I've written helps and doesn't overlap anything others
have
said:
In order to bring to market a product in the EU the
manufacturer or, where
the manufacturer is not in the EU, the
manufacturers representative or,
where the manufacturer does not have a
representative in the EU, the
importer needs to show that the product
meets all appropriate standards.
This is done by holding a "Certificate
Of Conformity" stating which European
Directives the product complies
with.
For our type of stuff, that means the Low Voltage Directive
(LVD) and the
ElectroMagnetic Compatibility (EMC) Directive.
The
LVD is basically there to ensure that users of your product are
not
exposed to any hazards during normal use and single-fault
conditions. It
covers products operating at voltages greater than
50V (there is an upper
limit, but I can't remember it off the top of my
head). You make your life
easier if your product is powered from
an
external, CE marked power supply,
and the voltages running around inside
your product are less than 50V. If
not, you need to ascertain
which
British Standard / European Norm your
product is categorised under, and
claim conformance to that standard.
EMC is somewhat worse(!)
Unless your product has no electromechanical
components, or you can
prove
it has a negligible EMC signature (such as a
wrist watch), you need to
show that your product complies with the relevant
EMC standards.
This is where it gets messy -
You can either go the "Standards
Route" to compliance : there are 100's of
standards, and probably only
one or two that your product falls into. Try
the EMC Compliance
Journal web site http://www.compliance-club.com/index.php
for
a start. Be prepared for a lot of reading. Alternatively, look
for a
friendly EMC testhouse (we use ETS in Dunmow, Essex - 01371
856061)
- at a
minimum I would imagine two days testing is required - at circa
?700 per
day!
Or the "Technical Construction File (TCF) Route" to
compliance : this is
where you prepare all technical, design, and
in-house test documentation,
send the lot off to a "Notified Body", pay
them ??k's up, and await their
comments. If you have designed it
using sound engineering practices, with
regard to EMC from the start,
then they might just issue you with a
certificate of compliance.
This route is now mainly used where the designed
product doesn't easily
fit into one of the categories for the "Standards
Route".
As for
Dave's comment about small-time PC assemblers - IIRC, a year or so
ago
Trading Standards took a small-time PC manufacturer to court and
won.
They had been assembling PC's using CE marked components however,
the final
PC's did not meet the EMC standards (even though each
component
part therein
was CE marked). CE + CE does not naturally equal
CE.
But as for Nik's original question - yes, there is a legal
requirement for
you to have a certificate. However, you don't
_have_ to do any testing at
all - it's all a matter of showing due
diligence. I can't remember the
origin of it but the phrase "You
have to be 80% certain that 80% of your
product would pass (the EMC
tests)" sticks in my mind from many years ago.
You may decide that
because your products are small, low powered, and sold
in very low
quantities (Trading Standards would not expect you to spend
?2000
getting
a product EMC tested if it sells for ?30 and you're likely to
only sell
six products in its lifetime), then the simple act of operating an
AM
radio close to the circuit and confirming that radio reception is
not
interfered with may be sufficient.
In reality, you're not
likely to get any problems unless a user of your
equipment finds it
malfunctions when, say, the microwave is on. Or their
television
reception is interfered with by the use of your product.
That
coupled with the fact that Trading Standards don't have the
manpower
or
finance to effectively police the directive.
(Apologies if my
definitions are not 100% correct as I'm running from
memory.
Standard disclaimers apply.)
HTH
Tony
-----Original
Message-----
From: Downes, David [mailto:David.Downes@xxxxxxx]
Sent:
29 May 2002 12:11
To: 'ukha_d@xxxxxxx'
Subject: RE: [ukha_d]
Re: CE certification
If I remember correctly all electrical
equipment which is sold has to
guarantee meeting the standards for
electromagnetic compatibility. This
guarantee is either by testing
or via documentation and someone taking legal
responsibility. This
is not an area I'm familiar with, and wonder what the
situation is with
regards to small time PC assemblers. Are all the
components
supposed to be CE certified and therefore the product as a
whole
is?
Dave
-----Original Message-----
From:
paul_watkin [mailto:paul_watkin@xxxxxxx]
Sent: 29 May 2002
11:59
To: ukha_d@xxxxxxxSubject: [ukha_d] Re: CE
certification
From memory if you use an external power supply
that is CE approved
you still need to have your product tested but as
you don't have
mains going into it the testing is less complex and
therefore cheaper.
Regards
Paul
--- In ukha_d@y...,
"Nikola Kasic" <nikola@k...> wrote:
> Does anyone
knows:
>
If I want to design and start selling some electrical device, when
do I
need
> to get CE certification.
> I think that proces for
obtaining such certification is expensive
so, for
> the cheap
things and small series, probably it's not worth taking
such
>
route.
> However, I would like to know, is there any legal
requirement
to
have such
> certificate if you want to sell such
devices.
> I think that someone mentioned that if your device has
separate
power supply
> then it doesn't need it.
> Anyone
to
put some light on this issue?
> Nik
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