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The Question
Can a company buy multiple CE marked units and keep them as spares. The issue is the Declarations may become out of date when they replace the item. An example product could be an electric actuator. Common sense says this should be allowed but I can not find any information within the Directives to support this.
Our Answer
You may find the EU Guidance notes ‘The Blue Guide’ helpful;
CE Marking applies when first placing the product on the market. As long as, then item has been placed / made available on the market, then in theory the item will be acceptable to use. A problem could arise where a customer may wish to use the spare part for incorporation into a NEW end product/assembly (instead of being used as a spare part for a like-for-like replacement on a product that has already been placed on the market).
If , however your question is referring to spare parts for incorporating into NEW end product, then the new end product would have to meet the Legislation that was applicable at the time the new end product was being placed on the market. If the Legislation does not change, then this should not be a problem, however should the Legislation change, then the manufacturer of the NEW end product would have to make sure that it complies with the new requirements and this would also including reviewing the components within the assembly. Using ‘OLD’ components in a ‘NEW’ end product could mean that the new product may not comply, obviously this will depend upon what has changed within the Legislation.
If you need any support with CE marking, then please contact us on 01564 792349.
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