CE marking and Brexit

Some of this just doesn't sound right to me.

My understanding is that a mark like UL recognised or UL listed can only be used if a UL test house has directly evaluated a product for compliance.

By contrast, a CE mark can in many cases be self certified. No independent test authority required to mark the product.

If one were to gain a UL type approval, for example, it would likely be a significant basis for justifying self certified CE marking with little other work. Equally one could quite properly and justifiably self certify for CE without a UL type approval.

Is is notable that a self certified CE marking would likely be ignored by a UL authority, unless it was unjustifiably applied. Indeed you would probably expect them to "dob you in" to someone, somewhere who might actually care.

What is even more interesting about the CE marking is that different product classifications have differing levels of standard. The Underwriters Labs are pretty strict as I understand it. Given that they are a commercial entity they have to be. The quality and reputation of their mark depends on them upholding good standards, wherever is it displayed. The authority protecting the CE mark has no such concerns - in most cases.

Actually, an interesting area of concern for the European authorities is pressure vessels. The CE mark is still self certified, but where pressure vessels are the subject of international trade, they must carry those marks, or be impounded.

I don't think there is any requirement that any goods be sold with any kind of mark anywhere in the world (except probably North Korea). I do find it interesting though that the EU specifically reserve the right to impound pressure vessels that cannot be traceably linked to a manufacturer.

The idea of CE marking is that it demonstrates that a product meets all applicable standards, which may, for instance, include EMC emissions and susceptibility and RoHS regulations. On the other hand UL certification is primarily concerned with safety, especially fire and overheating. I've taken telecoms equipment through UL certification and it involved things like assessing the plastic case for flammability, its resistance to mechanical shock and ensuring that component overheating didn't occur as a result of external faults. Since our equipment connected to telephone lines that included lightning strikes on the 'phone network and shorts to the utility voltages. In the US it is the FCC that look after EMC issues.

Andrew

I am afraid you are wrong in some cases here. If you build electrical control panels it could have a UL mark as part of a product assessment bu UL where their labs have checked it, but also panels can be UL shop where a factory can self certify the panels and apply a UL shop mark. Not so different from CE.

Steve

That is correct. Something built for your own use, whether private or in industry doesn't need CE marking. Building a bespoke production line for a third party under contract doesn't need CE marking either. CE marking is only required for something that is "placed on the market". That is to say a product that is manufactured to be sold. If your production line includes standard products that are subject to certain Directives then those items alone must be CE marked.

I too have served on BSI and European standards committees and it was certainly not a gravy train. Neither BSI nor the EU paid any expenses.

Russell.

Unlike certain Political establishments.

Dave
The Emerald Isle

Not true, production lines are an exception - I know because I checked yesterday, even building one up in house requires certification.

Does an assembly line have to be CE marked?

and:

If I make a product for my own use, do I need to CE mark it?

Hi all.

Are we seriously to understand from this Neil, that if we were to make a power feed as per the discussions running in another thread, we would have to CE mark it and keep the paperwork for 10 years etc.?

Kind regards

Anna

If I make a product for my own use etc

Does this mean MEW will CE all of the designs it contains Neil ?

I suspect this really applies to professional work areas that produce product of some sort and are subject to those inspectors that sometimes cause small machining businesses etc problems.

Curiously I have never seen one of those in a development area that is part of some rather large business. I can think of some instances that they might not like what they see as well. One for instance on company long since gone had some modified 3 pin dual socket plugs modified to disconnect the earth connection. Why because that was needed in order to use an oscilloscope on some of the items that were being worked on. The scope had to float. The sockets were painted red. A HSE person did visit here on occasion and there were several other rather bad HSE factors about several things that were going on and that wasn't a problem. Mainly because we couldn't do what was needed if they were.

John

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I don't think so. The HSE site Neil quotes is summarising what's required of a business. The wording isn't aimed at us.

Mostly the CE Mark is for the benefit of purchasers, but it can also be used for the benefit of users. In the case of an Assembly Line, there's a bunch of HSE requirements to be met. Requiring a CE Mark is the HSE's shorthand way of telling the lines' builder that he has to confirm that all the legal requirements have been met. The purpose is to ensure that the safety requirements of the Assembly Line are considered.

Although hobbyists wouldn't normally need to provide a CE Mark there might be exceptions. I can't think of any though. The possibility of falling foul of other legislation is something to be aware of. For example, the law takes a dim view of private individuals who make weapons, house-breaking equipment, drugs or coinage, whether or not you CE mark your toys.

Dave

Thank the Lord for some sense at last, isn't it time this thread was put to bed before someone explodes.

Only if it was for commercial purposes.

Neil

Indeed. bear in kind the HSE specifically point out "The technical file only needs to contain the design details and drawings of any control systems and other parts you've had to supply or modify, and the Declarations of Conformity / Incorporation for each of the items in the line."

So if the business doesn't change anything or add any elements of their own making, they don't have to create any technical documentation, really just gather together the certifications of the OEM suppliers with their own operating procedures.

I hate to say this but after some 25 years involved with H&S most of these regs are actually quite sensible when it comes to actually putting them into action.

Neil

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Although the 'Answer' is logical and reasonable; the wording of that 'Frequently Asked Question' [taken out of context, as it has been by some on this thread], is perhaps unfortunate.

I agree with Duncan's closing remark.

MichaelG.

Firstly, Russel and Dave, I did not mean the BS people. I meant the subcontract certification houses who use the legislation as a cash cow.

Second, as I said before, why on earth do we (professional engineers?) need further layers of bureaucracy to cover what we all do anyway as it has always been covered by other acts?

Third, R&D has always done (dodgy) stuff that would never normally be allowed on the basis that design engineers ought to understand the risk. The way it always used to work involved closing the doors and making certain everyone was out of the way before you turned it on for the first time (usually hiding behind something substantial if it looked like it could escape when the power went on! There seems to be a developing problem with R&D in as much as how do you allow it within the constraints that are being imposed. And lets not even bother thinking about drawings and documentation (revision control etc).....

Mark

I usually am wrong, but in the case you cite, it is the shop that is listed and not the panel. Unfortunately you cannot self certify your own shop.

Obviously your particular cited scheme only applies in the US anyway, but with reference to my own comments UL reserve and confer special meaning to the words "listed" and "recognised". These meanings hold throughout the world, as far as I can see.

I must add to this by suggesting that even if the meaning were an actual directive (and not just FAQ), that this kind of intent will always be heavily flouted anyhow. I am unwilling to cite examples here because of the public and hostile nature of the discussion, but I witness it every day.

Unfortunately there are definite practical constraints that make such rules impractical. Often there is a choice to do no business, or to work around the book.

Edited By Andy Ash on 03/08/2016 21:53:37

CE approval can involve some costly equipment out of the scope of some companies so the people who offer the service for others at a cost need not be as bad as some may think. There can also be a problem interpreting exactly what legislation means.

One example of something that is costly is emissions work. Lots of things involve electronics and to get that through companies either have to pay some one to do it, rent an rfi lab or own their own. Rents are so high that it doesn't take an awful lot of work in that line to justify owning one. The other problem is skills. An external company may have some one that knows what to do to cure problems. In this case companies can approve their own products but need traceable documented proof that the items do meet the requirements. Calibration comes into things like this.

HSE is needed because companies will concentrate more on profit rather than the safety of their work force. There are some odd ones such as hgv drivers having to have breaks - needed because there was no saying how many hours they were expected to drive. Way too many at times. Same with the working time directive which isn't actually binding on workers. It's more of a case of not allowing people to be forced to work long hours. Companies have other methods of encouraging people to work as long as they want them to anyway.

EU - a lot of what they put out is aimed at obtaining a level playing field. Bit tough when salaries vary country to country but at least it does cause countries to work to the same basic rules - also certain civil rights. While certain quarters would like to get rid of the red tape involved with employing people that's unlikely to happen and again there are ways of circumventing some aspects anyway. There are signs that the state may be fed up of footing the bill these methods cause. On the other hand they might just be after collecting more tax and probably are. If wages stagnate so does the tax revenue.

Having to CE a line is a new one on me. I have seen various kit in production areas all CE'd and people behaving in a manner that allows the company to claim they work to certain quality standards. The only line I have seen put in recently was done by a specialist company. The work area was placement machines, wave solderers, test gear and etc. Not exactly a line in this case as people usually carried the stuff about by hand from one to another. HSE requirements yes, CE of it all put together. Afraid i don't think so.

What will change post Brexit - nothing needs to really and very probably wont. It would just be a costly ineffective thing to change.

The tele managed to put up some people that get info on directives who clearly don't understand what they were being given. Often a problem with legislation of any sort. I was reminded of a time when I temporarily exported some gear to Dublin. Some of the gear was in my car and some was on a truck. Had to fill in a form, total gobble de guke as far a I am concerned. Turned out that there was a bloke in a nice posh suit in a hut that charged £10 to fill them in for people. As that was about 30 years ago he must have been making a very good living. Busy man. So rather than guess what legislation means in practice find some one that really understands it. Obviously the advice will cost.

John

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Edited By Ajohnw on 03/08/2016 23:39:34

I think, Neil, that this is a typical case of the HSE overstepping the mark. They always try to make more work for themselves.

As far as I can tell the comments on their site are not supporte. by any EU Directives. Indeed the CE marking Directive makes it a criminal offence to apply the CE mark to anything that is not covered by a Directive that requires it to be marked.

Russell

All very interesting and applicable to "Work".

Nothing at all to do with ME or ME private workshops except when you buy electrical goods they should come properly CE marked as do commercially made boilers (at present)

I think it's just confusing. What would they do stamp a CE mark on the entrances to the work areas in factories ? Or maybe on the building.

What I suspect it infers is that such places will get visits from an HS type person. They do. On the other hand maybe the company I mentioned chose to have people carry stuff about from machine to machine to avoid having to get CE approval and why they got specialists in to install something more akin to a production line. Afraid I don't think so. There is another aspect as well. Production lines sometimes have in house designed special purpose equipment some where along them. Lots of things are special purpose - plastic moulding tools, press tools and etc. Machines too. This is why manufacturers had large tool rooms some probably still do but often now it's done by a separate company.

Russel had a point as well. Employ a group of people to do something and they will find things to do even when there isn't really anything worth doing. I'd guess if I phoned up a CE outfit and asked if my home workshop needed CE approval they would only to be too pleased to do it and even might mislead me. That's life. I'd guess that the only sort of person who could clear up many point relating to CE and this sort of thing would be a director of a decent sized company who's general responsibility was the actual production work areas. They might just have a title of something like factory manager. A rather high grade job either way.

KWIL has a point as well. Also no change comments post Brexit. A lot of the stuff we make is exported to Europe. Having the approval will help exporting elsewhere as well. BSI suddenly go back to what it was - no chance. The only change that will happen post Brexit has been mentioned in the media a number of times. No longer being able to have any influence on what any standards contain but still having to work to them. This can apply to any product and could also possibly apply to financial areas. Frankly as far as product goes I don't think it really matters. I've had to cope with standards from several parts of the world. In general meeting one is very likely to meet all. In my case that has also included type approval. Even TUV which is something entirely different. There can be other factors creep in some areas as will. I doubt if many people watched C4's Dispatches on how safe is your car.It illustrates how the motor industry actually work. Me I''m an old style automotive person and think aspects like that really stink. Some other areas do too these days. Maybe a CE or whatever will prevent that sort of thing one day. Doubtful though. it's a fact that HS seldom stops large scale production. Some local yo yo factory inspector may stop a one man business. I here that at that level an unguarded belt is likely to get cut. Maybe also a don't use sticker like some gas fitters who buy loads of them. Good for business and is abused. That's life again.

John

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