CE marking and Brexit

Try this concept then - buy a bag filling machine a hopper and a weigh station, all ce approved. join them together in a "production line" and the whole thing then requires approval. Why would I need to approve my own line built from approved equipment?

I understand the idea about components making up a larger bit of kit but this is a production line and for your own use...... you still think it is drivel? Its mad. It is the latest proposals being floated regarding automation etc.

Mark

I hope that you are not putting the BSI down- ( a British disease I believe )

It is a world leader in advising on standards in industry,

It's not hard to imagine ways of combining two safe machines to make a dangerous situation. How is the law to know in advance which combinations are safe and which aren't?

Surely your 'simple system' should be simple to self-certify? I would have thought the manufacturers would be able to give you all the required data so you can just add your own risk assessment and top and tail it?

For us to supply product into Europe we will still need to find some way of CE marking a lot of it is done by manufacturers who are allowed to self certify under a scheme run by BSI. It going to take some sorting out.

The systems are all in place already. What has to change?

Neil

Notified Bodies are appointed by Member States of the EU - so depending upon quite what Brexit ends up meaning, it is possible that the UK may not be able to appoint Notified Bodies. I think nobody has a real clue about which way this will end up. I am aware of one UK Notified body that has taken the precaution of registering a company in another EU country, so that if necessary it will be able to provide services within the UK under the umbrella of that new company.

UK manufacturers can already choose to use NBs from other EU states if they so wish - some have offices in the UK.

Neil,

"the systems are all in place already. What has to change"

Exactly, We have been building production lines for years and managing happily with the HSE and the other directives, why do we suddenly need to CE mark?

As for making a dangerous packing line; sorry, I forgot to mention we are boxing spent reactor rods.... but then again that would fall under its own special controls and CE would not get a look in. On a less flippant note, how exactly can you envisage a dangerous packing line that would not be covered by existing HSE legislation (anyone remember the nice factories inspector by the way?).

Mark

Exactly. Other than the point David raises - company movement so that it's still under the EU umbrella. If Brexit really means Brexit there is likely to be lots of that so that companies retain full access to the market. Plus the ability to influence standards of one sort or another of course. Those in general sense are derived from the views of the people who have to use them via consultation.

John

-

Bear in mind that the EU directives are largely about free movement of goods - the 'safety' bit is only there to prevent member states using differing safety legislation as a barrier to free movement.

If a company provides a complete production line to you - directives apply to the complete system (Machinery Directive plus maybe others). If assembled in house, even if by a contractor under your direction, then other legislation likely covers that.

In Pressure Systems (which I do know something about) a supplied system has to comply with PED (PER in UK), an in house assembled or modified system is subject to PSSR.

In Pharmaceutical industry, production systems have to be 'validated' (for FDA compliance), it becomes very difficult to make any changes, as that requires the validation process to be repeated. That has been the case for a long time.

I'm ignoring any 'for trade' aspects of the weigh station, which might require approval in the finished installation.

On a simpler note that affects us all probably so is easy to relate to. Each electronic gadget has to be approved with the psu it will be supplied with. Customer uses a perfectly working equivalent psu of another gadget it is no longer covered by its certification.

Not difficult but mfr gets another psu for security of supply, cost saving, pretty colour etc and it has to be re-certified. May only be a partial redo at £10k instead of £50k but still another cost. If the psu mfr decides to make the unit obsolete for marketing reasons and bring out a new model it sounds like progress. Each of their say 100 customers (OEMs) has to recertify with the new model so 100x £10k or more costs.to industry and the consumer for paperwork of dubious value.

One thing will catch lots of us out, is the little panel on our car numberplates with the twelve stars and a tiny GB.

Once we are out that will no longer be valid in Europe, and to drive on the continent we will need to comply with the Paris Convention of 1921. This mean we must carry an 'oval white plate 300mm x 180mm' on which are painted the letters GB. Or risk being fined at the roadside by any gendarme whose breakfast was not perfect.

I wonder how much that change will cost us all?

Cheers, Tim

In my position as part time engineering manager (I 'retired' 8 years ago) with an industrial fan manufacturer I have dealt with directives and regulations and associated standards a lot over the years. I don't see much changing to be honest, they still have to be complied with to enable a CE mark and selling into the EU. Most of the regs that we work to are quite sensible to be honest and in fact other countries outside the EU accept them as a sign of an authoritative standard of design. I fully expect it to be business as usual in this respect.

In the run up and post referendum there has been a lot of rubbish and misconceptions about the UK in the EU. the common theme being on the basis of 'in the EU we have this situation', by implication being if we leave this will change or not exist anymore.

Bill D

As long as the UK has a mutual recognition agreement with the EU (the likely situation as EU countries won't want to have to pay for BS certification as win order to sell to the UK), it won't be an issue, we can still have UK Notified Bodies.

I suspect the truth about Brexit is that in practice very little will change for the way businesses operate.

Neil

As I recall from the days before the EEC they were more like 4" x 3" and usually sticky-backed plastic.

I think car ferry companies did a brisk trade in them and little yellow headlight converters.

Neil

That is oh so true Bill and most regs are pretty sensible really and often relate to what other countries use anyway.

The complication could be not having free access to the market and if that is the case a lot of none obvious things will change. A number of companies for instance that one way or the other pay considerable amounts of tax have already said that they must have this. Bang goes at least some of the tax if they move to retain it. Also some jobs.

John

-

Components (drives, power supplies etc etc) have ALWAYS had to be marked up, either UL, CSA, VDE, SEMKO etc etc etc. The only difference with the CE mark is that one marking applies to ALL of Europe so you don't have to get products approved in every single European country, which is pretty much how it was when I started out 30 odd years ago.

When you build a system from components, you still have to have it (the system) approved for the market you want to sell it in (yes, by UL, CSA etc etc). So if it's Europe, you have a CE mark, if it's USA you have a UL mark, if it's Canada you have a CSA mark etc etc. It's really very simple. Sadly perhaps for some, it's got absolutely nothing to do with Brexit or the EU.

As I said it's ALWAYS been this way, at least for most of our lifetimes. Quite simply, you will NOT be able to sell your product unless it is approved by the national approvals body and generally they require you to show the mark that indicates that approval. Conversely if you show the mark and haven't actually got approval you can get into some serious bother. Do people who have this irrational dislike of the CE mark also have a hatred of the UL,CSA etc marks too? Only asking.

We still still have CE marks on most of our products and soon perhaps (eventually) we will also have a "BS" mark too. Is that helpful? I must say, there seems to be no shortage of "BS" to choose from, much of it uninformed and negative.....

That has always been a bit debatable. Consider for example a bare board switching power supply. It can in no way comply with the LV Directive nor the EMC Directive so cannot be CE marked. However it can be sold to a company who uses it in a system which is tested and CE marked before being placed on the market.

Russell

Muzzer, I am taking it that you think I have a hatred of CE. I do not, it is a good idea for the things it was originally meant for especially domestic kit. The problems start when the people start making money out of doing the certification and then they get on the standards committee due to their "expertise". This then becomes a self gratifying exercise in charging for what we all did before some one required proof and certificates. CE marking production lines built by you for your own use has no place in manufacturing - all you need is HSE..... I can assure you it will stifle R&D and I say this as I have direct experience of people deciding against a project due to the red tape to be dealt with. Its easier to get a cheap machine overseas with dubious certification and forget all the grief. Or better still, just off shore the job all together and further help turn our economy into a service based economy making diddle squat.

Mark

Worked as a UK expert and Chairman of a working group for BSI not putting them down just stating a fact far to many are copied these days. Also as a working group member I used to get a free copy of any standards I work on.

Edited By Old School on 02/08/2016 20:56:44

We are already largely a service based economy Mark. The UK has been doing pretty well developing automotive electronics mainly I think down to skills and wage levels in that area but it's slowly been fading away for many years.

In any case actual manufacture often gets shipped out for the simple reason it's a bit cheaper. The biggest cost is the development and the gear for manufacture which in many cases needs very few people to drive it especially high volume stuff.

The other problem with manufacture is parts. Even Dyson sent that to the far east for the simple reason that is where the parts he needs were.

The other problem of course is just selling means less risks, less money invested, higher profit margins and a simpler life.

Having spent most of my working life in development I don't think that there is much concern about eventual compliance with this and that. All have to meet that - at some point. Getting something ready for that is part of the job. R&D is very similar but I feel I should mention that research is not the same thing as development. Development means that there will be a product at the end.

HSE actually working in this sort of area. Best not mention it but we did do risk assessments - of some sort or the other but sometimes to a certain extent getting the job done takes a higher priority.

John

-

Is there any justification for assuming that Britain will not continue to manufacture CE marked products, and to require CE marking of products? Despite whatever Boris Johnson may have said, Turkey remains outside the EU and has little prospect of joining in the near future, yet it still requires CE marking of applicable products, as do Norway and Iceland.

Even if we chose to return to the kite mark, we would probably have to equal or exceed the requirement for CE marking in order to obtain mutual recognition of conformity.

Brian