CE status of subassemblies

Although, as John notes, there are no requirements for CE marking/testing of subassemblies designed to be embedded in OEM equipment, I can tell you (as one of those OEM designers) that if a product has been tested to CE standards and found to be compliant, I am far more likely to use it. Emissions are by far my biggest concern, but it's nice if the drop-in unit has had any other applicable testing. For instance, if the device has any pins that may connect to the outside world, have the various ESD and suscetibility tests been done? Such testing, although expensive and a royal pain on occasion make the unit much more marketable, in my experience.

Just my $0.02

Cheers PeteS

What's the story on Pb-free? Does it apply to finished products only?

Best regards, Spehro Pefhany

I read in sci.electronics.design that John Larkin wrote (in ) about 'CE status of subassemblies', on Thu, 10 Mar 2005:

If it is marketed only to OEMs for embodiment, there are no requirements under either EMC or Low Voltage Directives. But the client may well want information to help with his own technical files and conformity assessment.

I have two oem customers in the UK, one in Oxford and one in Belfast. Whenever I mention CE, they all laugh at me. They claim it means "Can't Enforce."

Somebody in this ng says that they keep a roll of CE stickers in their shipping department and slap one on everything that goes out. I figured we'd at least make a sorta-sincere effort to compile a test file.

John

I read in sci.electronics.design that Spehro Pefhany wrote (in ) about 'CE status of subassemblies', on Fri, 11 Mar 2005:

This is a total dog's dinner, and there has been some correspondence on the IEEE emc-pstc mail list about it.

The WORDS of the RoHS Directive imply that the only acceptable concentration of the controlled substances is zero, but there is provision for concentration limits to be set. It appears that the text (which may not yet be finalized) establishing these limits implies that the percentage content limits apply to everything that is a separate constituent, so a 10 kg product is non-compliant if 10 mg of paint somewhere in it has more than the limit of a controlled substance!

I expect that when/if challenged, the Commission will say 'Of course it doesn't mean that.' and then refuse to say what it DOES mean.

Incidentally, arsenic is not a controlled substance.

I read in sci.electronics.design that PeteS wrote (in ) about 'CE status of subassemblies', on Fri, 11 Mar 2005:

Quite right, but the OEMs tend to have their own particular requirements for these 'pre-tests', so it may not be appropriate to go into a 'generic' test programme before determining what clients actually ask for.

Do people actually go to prison for this?

John

Sure. It helps keeps the apparent unemployment rate lower ;-)

...Jim Thompson

Sounds familiar. At least once a year I receive a very official-looking missive with similar scare tactics, and a fee, of course ;-)

...Jim Thompson

Has anyone compiled a site that lists the requirements for different approvals, both mandatory and others, for different markets and countries?

I read in sci.electronics.design that John Larkin wrote (in ) about 'CE status of subassemblies', on Fri, 11 Mar 2005:

Fools' paradise. Make sure you don't extend any credit to them. It only need ONE ambulance, fire pump or police car to have a communication problem and someone will be round with the portable receiver.

I read in sci.electronics.design that John Larkin wrote (in ) about 'CE status of subassemblies', on Fri, 11 Mar 2005:

There was so much alarmist talk about this a few years back that, very uncharacteristically, the UK government issued a statement. This was because some people were attempting to extract cash by fraudulent threats from small businesses. (Incidentally, this hasn't stopped. A trade publication I've just read refers to fraudulent threat letters from a 'Health and Safety Enforcement Department' or words to that effect, demanding fees of £200 or £250 for some nebulous 'registration' or 'assessment'.)

The statement said [paraphrase] that there was no intention to pursue individuals for violation of the EMC or Low Voltage Directives, except in the most serious, cases where obvious deliberately malicious or wholly negligent behaviour occurred.

This statement was no doubt in part prompted by the known difficulty of proving such behaviour, a difficulty that has beset the pursuit of prosecutions of managers of the companies concerned in respect of the fatal railway accidents that occurred in the recent past.

I believe this is only possible for deliberate falsification of records etc. Even then probably unlikely.

or, as happened to us, one (massive) competitor makes a phone call complaining our products didnt in fact comply, despite the CE mark. Our TCF saved our asses big time, but if we had somebody in the shipping department "just slap CE stickers on" heads would have rolled (possibly directly to jail in Europe).

Cheers Terry

Back in the mid 1990s when I was involved with CE marking AC drives, we were required to have our declarations of conformity (I forget what the hell it was actually called) signed by somebody based in the EU, because there *were* such legal ramifications - 5 years IIRC. We had a subsidiary in Britain, and Mr Humphrey Catchpole (I kid you not) signed all the paperwork.

Whether or not people have actually been jailed I cannot say. But we took it quite seriously, because we (rightly it turns out) assumed that our competitors (Siemens, ABB etc) would shop us if we cheated.

Cheers Terry

We regularly get invoices for all sorts of stuff we never ordered or received. Luckily, our office manager is very sharp and we never pay. I bet a lot of other companies just pay.

John

Or Chinese Export. Or Caveat Emptor.

Paul Burke