CE status of subassemblies

[John Larkin]

If I were to offer a special-function pc board (a digital delay
generator, to be specific) that a customer would incorporate into his
product (say, a laser in its own enclosure with its own power
supplies), what would be my status and responsibilities re CE marking?

The gadget would get 12 volts DC from the customer, and we'd use a
polyfuse or maybe a real surfmount fuse on the input, so do I have to
address the LV directive stuff?

What about EMI? Clearly it would fail if run alone in free air, but
that's not the intended use.

John

 

[John Woodgate]

I read in sci.electronics.design that John Larkin <jjlarkin@highSNIPland
THIStechPLEASEnology.com> wrote (in <iem131tgbjkemkg3hmc2k8j78fgvbjd9jm@
4ax.com>) about 'CE status of subassemblies', on Thu, 10 Mar 2005:

If I were to offer a special-function pc board (a digital delay
generator, to be specific) that a customer would incorporate into his
product (say, a laser in its own enclosure with its own power supplies),
what would be my status and responsibilities re CE marking?

The gadget would get 12 volts DC from the customer, and we'd use a
polyfuse or maybe a real surfmount fuse on the input, so do I have to
address the LV directive stuff?

What about EMI? Clearly it would fail if run alone in free air, but
that's not the intended use.

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.

 

[Spehro Pefhany]

I read in sci.electronics.design that John Larkin <jjlarkin@highSNIPland
THIStechPLEASEnology.com> wrote (in <iem131tgbjkemkg3hmc2k8j78fgvbjd9jm@
4ax.com>) 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.

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


Best regards,
Spehro Pefhany

 

[PeteS]

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

 

[John Woodgate]

I read in sci.electronics.design that Spehro Pefhany <speffSNIP@interlog

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

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.

 

[John Woodgate]

I read in sci.electronics.design that PeteS <[email protected]>

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.

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.

 

[John Larkin]

I read in sci.electronics.design that PeteS <[email protected]>

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.

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

 

[John Woodgate]

I read in sci.electronics.design that John Larkin <jjlarkin@highSNIPland
THIStechPLEASEnology.com> wrote (in <eio33191vfvcoetkngs2prv4safq5o63qb@
4ax.com>) about 'CE status of subassemblies', on Fri, 11 Mar 2005:

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."

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.

 

[Terry Given]

I read in sci.electronics.design that John Larkin <jjlarkin@highSNIPland
THIStechPLEASEnology.com> wrote (in <eio33191vfvcoetkngs2prv4safq5o63qb@
4ax.com>) 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.

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

 

[John Larkin]

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).

Do people actually go to prison for this?

John

 

[Terry Given]

Do people actually go to prison for this?

John

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

 

[Jim Thompson]

Do people actually go to prison for this?

John

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

...Jim Thompson

 

[Brian]

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

...Jim Thompson

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

 

[John Woodgate]

I read in sci.electronics.design that John Larkin <jjlarkin@highSNIPland
THIStechPLEASEnology.com> wrote (in <ss1431h600luh6qhho6nsumourb7jinila@
4ax.com>) about 'CE status of subassemblies', on Fri, 11 Mar 2005:

Do people actually go to prison for this?

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.

 

[Jim Thompson]

On Fri, 11 Mar 2005 21:40:01 +0000, John Woodgate

[snip]

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.

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

 

[Mike Harrison]

Do people actually go to prison for this?

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

 

[Paul Burke]

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."

Or Chinese Export. Or Caveat Emptor.

Paul Burke

 

[John Larkin]

On Fri, 11 Mar 2005 21:40:01 +0000, John Woodgate

[snip]

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.

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

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