The CE Marking Association invites company to become members of Association to give them support on a regular basis. Part of membership is to offer access to our technical inbox and when a question crops up that might be of interest to a wider audience, we like to publish them in our news section. Some of the details may have been altered for confidentiality reasons.

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 The issue is the Declarations may become out of date when they replace the item.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.

Every year, the CE Marking Association is asked to speak at the Southern Manufacturing & Electronics Show (held in Farnborough) and this year Mike Foster & Peter Evans attended the show over the course of the three days to give a talk on the CE marking process and to discuss the changes that are planned in 2016 and beyond. The free seminars proved to be very popular and if you were able to attend, then we hope that you found it very useful.

A copy of the presentation is available to download (please click here – PDF 1.2MB), but if you do have any questions or if you were unable to attend the show, but would like to help with CE Marking then please feel free to get in contact (call us on 01564 792349 or e-mail info@cemarkingassociation.co.uk)

We hope to see you again.

The analysis of risk is always an important step when placing products or machines on the market. The task of trying to foresee any potential problems associated with the equipment and then implementing risk reduction measures is a crucial way to ensure that the products are safe to use. The need to design a safe product is already embedded into most people’s mind sets, however from experience, it is not always the case that every risk and associated risk reduction measure is adequately documented.

This scenario recently came to light during a visit to a manufacturer of wood-working machines, who were confident that their machines were safe, however their risk assessment was very light on risks that could have been associated with their equipment. For example, it did not document how they were confident that there was no potential risk of electric shock. The Technical Director of the company explained that they used a qualified electrician, who designed and built the machines in accordance with a standard, which gave them the confidence that the machines were safe. The electrically safety of their machines was not being challenged during this visit but, as none of their risk reduction measures had been documented, it did raise a question as to whether they could provide sufficient evidence to an enforcement authority if the electrical safety of their machines was raised 9 years later. Given that no one could remember which standard had been used, it was clear that they should improve their risk assessments.

It has been a clear requirement for machines cover by CE marking that a risk assessment should be undertaken and form part of the technical documentation that a manufacturer must hold. However, whilst it is a clear requirement under the Machinery Directive, it is not quite as clear under some of the other CE marking Directives. The Low Voltage Directive, as an example, does not make any reference to risks assessments being undertaken on electrical equipment, however this will soon change.

In 2016, when the new CE marking Directives come into force, the technical documentation requirements under these new Directives will be changed to match the text of the New Legislative Framework and therefore will include the requirement for manufacturers to ensure that they have undertaken an adequate analysis and assessment of the risks associated with their products. The new CE Marking Directives will largely involve just an administrative change, with Declarations of Conformity being required to be updated, however the process of CE marking an electrical appliance will also change to include a risk assessment. The risk assessments does not need to be complicated and any suitable methods of assessment that can be chosen, as long as it can show that all of the potential risks have been identified and that they have been eliminated or reduced to a suitable level, then it should be perfectly fine.

If you are looking for more guidance on undertaking risk assessments, then please contact the CE Marking Association. Or why not attend our Annual CE Marking Seminar, which includes a presentation on risk assessments under the new 2016 Directives.

The CE Marking Association is hosting the 2015 Annual CE Marking Seminar on Thursday 19th November. The 1 day similar will be FREE for members to attend and non-members can attend for a small fee. The day will start with a session for persons who are new to CE Marking or would like a refresher; and then lead on to focus on hot topics around the 2016 changes. Tours of the new test facility are also available.

The key topics for the 2015 seminar are:

– Beginners/Refreshers topic on CE marking
– New Radio Equipment Directive (RED)
– EMC problem solving
– The 2016 CE Marking Directives changes
– Risk Assessments for the new 2016 Directives

The seminars are a great way for you to keep up to date with technical and regulatory changes, with a range of speakers available to discuss CE marking related queries. We are also offering the opportunity to have a look and a guided tour behind the scenes at our new test facility, looking at the EMC and electrical safety test labs.

The meeting will be held at the Twenty10 Venue (next to the CE Marking Association’s offices at Wootton Park), with free parking and lunch provided.

You can register today, by filling in the form on the event flier.

We have had a question from a member regarding a machine that is branded by themselves, but is being fitted with a control panel that has been designed and built by a subcontractor. They wondered whether their subcontractor was required to provide them with a Declaration of Conformity for the control panel.

There are three Directives involved with this scenario that could be considered. 

 
a) Machinery Directive – The panel may feature safety components (such as an emergency stop button or w safety relay) as defined under the Machinery Directive, but ultimately the end assembly does not come under the scope of this Directive. It would be important for information regarding the design and choice of safety components to be passed on to allow the manufacturer of the machine to complete a safety control system assessment.

b) The Low Voltage Directive – Potentially, the panel could fall into scope of the LVD (depending upon the voltage range and application). However, if the control panel is deemed to be a ‘component’ then it might not be covered, as the Low Voltage Directive only applies to electrical equipment / apparatus. Regardless, as to whether the control panel has been defined as a component or not by the subcontractor, they have no legal obligation to supply a copy of the Declaration of Conformity to anyone other than an enforcement authority.

c) The EMC Directive – Will not be required, as the control panel is intended to be incorporated into the end apparatus. However, it is important to note that the design of the panel and choice of components will have a bearing of whether the manufacturer can meet the EMC Directive for the machine.

If you have any questions regarding this article, or need any support with CE marking, please call us on 01527 595066.