UPDATE: On the 6^th July, The Cabinet of the United Kingdom agreed its position on the UK’s exit from the European Union. We take a look at how this may affect your CE Marking Obligations.

The cabinet agreed that the UK should maintain a common rulebook for all goods within the UK and EU following Brexit. The Government seems willing to commit to a treaty allowing ongoing harmonisation with European rules (which would by definition include CE Marking legislation) but would retain the ability to choose which future legislation it may decide to incorporate into UK law. There was also an implicit suggestion that this would only be done in the best interest of UK manufacturers.

The Government is also keen to maintain the UK’s strong position on the various International Standards Bodies on which it currently sits, effectively giving the UK leverage over the factors underpinning EU legislation if not over EU legislation itself. A full transcript of the Government statement following the Chequers agreement can be found here:

It should be stressed that this is currently only a proposal at present and will require agreement from both the UK parliament and the EU.

Should the UK Parliament and the EU agree to this model, it would suggest very little change to the current system in terms of product compliance however questions would still remain over the UK’s position in the ‘Community’ for certain aspects of the process and as such it may pay to continue to assume that the UK will sit outside of the Community following Brexit.

The CE Marking Association will continue to follow the Brexit process and consider its effects on CE Marking for UK Manufacturers; we will publish updates as they become available however if you wish to discuss any topics related to CE Marking, then please get in contact.

It is commonly known that a Manufacturer of a product which falls under CE Marking legislation must demonstrate that the product meets the requirements of that legislation and affix the CE Mark before it is placed on the market. However, what if the manufacturer is not actually selling the product?

The ‘Blue Guide’ on the implementation of EU Product Rules 2016 offers some good guidance on the subject. Clause 2.2 refers to ‘Making Available on the Market’ and defines this as being ‘supplied for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge’.

So promotional products would fulfil that definition and would therefore, if applicable, be required to be CE Marked.

But how about if the product is custom made and donated for charitable purposes? This would appear to be a grey area, however the Blue Guide goes on to define that making available may amongst other things, refer to advertising campaigns. As such, if the purpose of making the charitable donation is to promote the business (for instance it is marked as ‘Supplied By…’) , then the product should be CE Marked.

Notwithstanding the question of whether a product should be CE marked or not, Manufacturers, of course, have both a legal and moral obligation to ensure that their products are safe!

If you need any help and support with CE Marking or Product Compliance, then please call us on 01564 792349.

The new General Data Protection Regulations came into force today (25^th May) and the CE Marking Association has changed the way we market our business in order to meet these new Regulations. Amongst other obligations, businesses are no longer able to use personal details held on file for marketing or information purposes without the explicit 

permission of that person.

The CE Marking Association holds information related to our clients to allow us to perform our contract and provide an audit trail following completion of a project, however we will not use this information to contact you unless you have given us explicit permission.

Turning to our Members, a benefit of joining the CE Marking Association is to receive our newsletter and information regarding our training events and therefore we consider that we already have the explicit consent of our members to continue performing that contract, however if you do not wish to continue receiving these emails, please let us know.

We have changed our privacy policy in line with the new regulations, our privacy policy can be viewed here: http://www.cemarkingassociation.co.uk/privacy/

If you need any help and support with CE Marking or Product Compliance, then please call us on 01564 792349.

Recent tragic events have highlighted the fact that a Manufacturer’s CE Marking Risk assessment should be a living document and that Manufacturers should act on feedback from the field.

Take refrigerators for example; the Standard EN 60335-2-24:2010 is no longer harmonised under the Low Voltage Directive and as such no longer offers a Presumption of Conformity against the Safety Objectives of the Directive. So in this case, how is a Manufacturer able to demonstrate conformity?

Article 13 of the Low Voltage Directive (2014/35/EU) advises that in the absence of a Harmonised Standard, manufacturers may use an international Standard set out by the International Electrotechnical Commission (IEC) (barring objection by the European Commission) so long as it assures the relevant safety level.

Moving back to the example of fridges; the withdrawn standard IEC 60335-2-24:2010 (being the same Standard as above) has been amended to IEC 60335-2-24:2010+A2:2017 (which is not yet listed on the Official Journal); a major amendment being the inclusion of Clause 30.2 requiring a flame test to be carried out on the material used to form the rear of the fridge. In this case and in light of recent events, a Manufacturer should identify risk of fire as being a more severe risk and therefore the application of the amended IEC Standard would be highly recommended.

If you need any help and support with CE Marking under the Low Voltage Directive, then please call us on 01564 792349.

As we have previously reported via the CE Marking Association website, The Radio Equipment (RED) Directive (2014/53/EU) came into force on 13 June 2016, replacing the Radio and Telecommunications Terminal Equipment (R&TTE) Directive (1999/5/EC). However, at the time, the UK Government had not enacted the new Directive into UK legislation meaning that it was still technically possible to place products conforming to the old Directive onto the UK Market.

As of 26^th December 2017, The Radio Equipment Regulations 2017 (S.I. 2017/1206) came into force within the UK to implement the Radio Equipment Directive into UK law thus repealing R&TTE (S.I. 2000/730).

The implementation of this Statutory Instrument was delayed for reasons beyond the control of Department of Business, Energy and Industrial Strategy (BEIS); the responsible government department, however an extension had been granted by the European Commission to allow the UK to delay the introduction of the legislation.

The new legislation does not apply to equipment placed on the market within the UK before 26^th December 2017, however equipment placed on the market within any of the other 27 EU member states or 3 EFTA members has had to comply since 13 June 2016.

It is now a clear legal requirement that all radio equipment now placed on the market for the first time within the UK must comply with 2014/53/EU.

If you need any help and support with CE Marking under the Radio Equipment Directive, then please call us on 01564 792349.