Re: Do production tools need CE marking
- From: Wimpie <wimabctel@xxxxxxxxx>
- Date: Sat, 18 Jul 2009 08:26:59 -0700 (PDT)
On 18 jul, 08:41, "jeem" <jan.mob...@xxxxxxxxxx> wrote:
"Wimpie" <wimabc...@xxxxxxxxx> schreef in berichtnews:9abefe32-2bf8-498e-b510-bd5c9c580b81@xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
On 17 jul, 19:51, "jeem" <jan.mob...@xxxxxxxxxx> wrote:
<J...@xxxxxxxxxxxxxxxxx> schreef in
berichtnews:ud5v55t12qktnghtah73auk09plsubsqb7@xxxxxxxxxx
On Thu, 16 Jul 2009 19:07:34 +0200, "jeem" <jan.mob...@xxxxxxxxxx>
wrote:
Hello
My question is do even production tools designed as measuring apparatus
for the production of other product bear a CE mark.
So for instance signal measuring tools to measure the signal from a
product
during after their production?
These tools electronics and mechanical for printed circuit measuring
will
only be used inside a production site
thanks for your reply.
Jan
Only if you have procured them within the EU or have imported them
into the EU. Otherwise, you should not have purchased them.
If they are homegrown, the still need to comply with relevant H&S
rules. If you wish to place them on the market, they will need to
comply with relevant legislation and be CE marked.
The CE mark is merely a declaration by the manufacturer or importer
that the item in question complies with the relevant EU legislation.
It is necessary under these circumstances but is not sufficient. You
should not trust without some confirmation that any compliance marking
is valid.
If you are procuring such articles look for a declaration by the
supplier or manufacturer that identifies the European Norms with which
the article is alleged to comply. Look also for the marks of Notified
Bodies that are recognised as being competent to certify compliance
with these standards. Then check that the application of these marks
are actually valid.
Think 'Inquest'.
IANAL
JonH
Hi John,
Thanks for your reply.
We (in the Netherlands) design and manufactur only a few specific test
apparatus for our production sites in Europe and also for service
purposes.
Jan
Hello Jan,
Much information can be found here:http://ec.europa.eu/enterprise/newapproach/legislation/guide/index.htm
An important thing is whether the product is placed on the market or
not. When it stays within the company (so it is not sold, but for own
use only), CE marking it not required.
When the product is part of an installation (and not sold as separate
useful product), the product is not subjected to CE marking, but the
installation as a whole does. When the product is sold for use in an
installation, you must provide information to enable the system
integrator / installer to install the product properly so that it is
very likely that the installation stays within the essential
requirements for CE marking.
If you decide to not CE mark your product for own use, keep in mind
that the product must still be safe and does not harm other equipment/
people/animals, etc.
When you go for CE marking, most directives do not require third party
testing (self declaration). Many companies do third party testing
(they don't have all the equipment/knowledge to do it and it is easier
to show that you did your job in case of a dispute). Also many
products are affected by more then one EU directive (for example radio
equipment is covered by EMC, LVD and R&TTE directive).
Best regards,
Wim
PA3DJSwww.tetech.nl
Please remove the obvious three characters in the mail address.
Thanks Wim
<An important thing is whether the product is placed on the market or not..
When it stays within the company (so it is not sold, but for own use only),>
This is a grey area.
We make these tools in the Netherlands and hand it over (for material and
some labor cost) to our production site in another european country. Also to
a external repair centre inEurope that will be handover for use only (no
costs?)
Best Regards.
Jan
Hello Jan,
As long as it is not covered by the "machinery directive" The grey
area may be on your side. When you make sure that it is a safe and
sound product, mention in the documents that it is not for sale and
only for a particular installation, and it has no useful function
without the installation, you may not expect problems when shipping
throughout Europe.
There is change that your boss thinks: "no CE, so no strict
requirements!" As you know this is not true.
As far as I know, for the "machinery directive" the moment of "put
into service" determines when CE has to be applied.
Find below a link http://www.be.sgs.com/cebec_index_v2/euro_directives_cebec/ce_low_voltage_cebec.htm
to SGS Belgium. This may be helpful.
Best regards,
Wim
PA3DJS
www.tetech.nl
don't forget the obvious letter combination in the PM.
.
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