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Members Question: CE Marking Bespoke Products

One of the frequent questions that we get asked is: Do bespoke products need to be CE marked?

It can very much depend upon the type of product and the Legislation that is applicable. As a general rule of thumb, most of the current CE Marking Directives do not have any exclusions for one-off items or bespoke products, so usually the answer is that they will need to be CE Marked. However, this isn’t necessarily the case for ‘construction products’. It is possible, under the Construction Products Regulation, for a manufacturer to refrain from drawing up a Declaration of Performance, using one of the derogations given within Article 5.  There are three possibilities:

  (a) The construction product is individually manufactured or custom-made in a non-series process in response to a specific order, and installed in a single identified construction work, by a manufacturer who is responsible for the safe incorporation of the product into the construction works, in compliance with the applicable national rules and under the responsibility of those responsible for the safe execution of the construction works designated under the applicable national rules.

(b) The construction product is manufactured on the construction site for its incorporation in the respective construction works in compliance with the applicable national rules and under the responsibility of those responsible for the safe execution of the construction works designated under the applicable national rules.

(c) The construction product is manufactured in a traditional manner or in a manner appropriate to heritage conservation and in a non-industrial process for adequately renovating construction works officially protected as part of a designated environment or because of their special architectural or historic merit, in compliance with the applicable national rules.

The first derogation probably has the widest appeal of the three, but it care must taken when applying this rule. Firstly it is important to point out that the derogation makes a point about the ‘custom’ construction product being made in a ‘non-series’ process, but also that the bespoke nature must be in terms of the Essential Characteristics that are given within the relevant standard (and not necessarily its physical appearance). If we were to take a domestic bath as an example, a customer may want a bespoke bath to be made in a specific colour other than the standard white colour. In this scenario, the bespoke bath would not fall within the derogation given within the Regulation as the colour of the tub is not included in the list of Essential Characteristics for a domestic bath and would therefore need to be CE Marked.

There is only one other consideration: Does the bespoke construction product fall within any other CE marking Directives? If the construction product is also electrical at a mains voltage, then it is likely that it will also fall in scope of the Low Voltage Directive and will be required to be CE marked anyway.

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

Partly Completed Machinery Guidance

Partly Completed Machinery GuidancePartly completed machinery is a term under the Machinery Directive (2006/42/EC) for an assembly of parts which is almost machinery but which cannot in itself perform a specific application. The partly completed machinery must be incorporated into or assembled with other machinery (or other partly completed machinery) to form a complete machinery that also comes under the scope of the Machinery Directive. We often get lots of questions about Partly Completed Machinery and whether it can be CE marked or not, so the CE Marking Association have developed a basic guide to point manufacturers in the right direction.

The guide can be downloaded here (PDF – 0.3MB)

If you need assistance with the Machinery Directive, then please get in contact on 01527 595066.

Water Jetting Equipment & CE Marking Guidance

CE Marking and water jetting guideDoes a Water Jetting equipment need to be CE marked under the Machinery Directive?

A typical Water Jetting Gun may not have any powered moving parts and as such you may believe that it does not fall within the scope of the Machinery Directive (2006/42/EC) and does not need to be affixed with the CE Marked. However you should be aware that there are in fact many types of products which fall under the scope of the Machinery Directive which have no powered moving parts.  A Water Jetting Gun is an example of a product which may need to be CE Marked under the Machinery Directive, despite it having no powered moving parts.

To explore this subject further, the CE Marking Association has developed a short guide to help manufacturers determine if their water jetting equipment falls within scope of CE Marking or not. The guide can be downloaded for free here.

Annual CE Marking Seminar 2014

The CE Marking Association is hosting the 2014 Annual CE Marking Seminar on Thursday 13th 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 and forthcoming changes in product legislation. The key topics for the 2014 seminar are:

– Beginners/Refreshers topic on CE marking
– Forthcoming changes to CE marking
– Changes in the NEW Low Voltage, EMC, ATEX and Pressure Equipment Directives
– Current funding available for CE marking.

The seminars are a great way for you to keep up to date with technical and regulatory changes and enable members to discuss issues. These meetings are also a great way to help maintain and enhance your product compliance knowledge and appropriate for your Continuous Professional Development.

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.

To register to attend, please click here to go to the event flier.

Standards Updates – Sept-Oct 14

The following lists of harmonised standards referenced on the European Commission’s Official Journal have been updated  in September & October 2014.

 

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