CE marking misconceptions

March 27, 2015 //By Jean-Louis Evans
CE marking misconceptions
Products that fall under a CE marking Directive cannot be imported into the EU unless they show the CE marking, which is simply a manufacturer's self-declaration that the product complies with the relevant European legislation.

By applying the CE marking and providing the associated EU Declaration of Conformity (DoC), a manufacturer or importer is confirming that a product meets the requirements of all applicable EU Directives. However, common misconceptions about CE marking mean that products often don’t comply. Also, due to language issues, other manufacturers who mean well are misunderstanding the requirements of a complex set of Directives - applying CE marking to products that should fail tests.

If the CE marking is the manufacturer's declaration that the product meets the requirements of the applicable EC Directives, how can they ensure they are on the right track to compliance?

Who is responsible?

It is the manufacturer or importer of a product that is responsible for the compliance through a process of self-declaration, which manifests itself as the DoC. This is a formal statement that a product complies with applicable Directives and standards. It must be signed by the responsible person within the organisation and that signatory may be subject to prosecution, or even imprisonment, if the equipment is found not to comply.

The DoC must include, amongst other things:

· Name and address of the manufacturer (or their authorised representative)

· Description of the product - including type, model and any other information that clearly relates the equipment to the declaration

· Reference to the standards applied

· Identification of the signatory

Unlike certifications to show compliance with Directives, a test house will not assume responsibility for the product, but can help with the self-declaration process. Some Directives may require you to consult a Notified Body (Medical, Machinery etc.)

Supply chain assurances

The New Legal Framework for EU Directives redefines the responsibilities of economic operators – manufacturer, authorised representative, importer and distributor. There are also rules which relate to traceability of a product and how it should be identified, depending on whether the manufacturer is within or outside the EU.

By law, whoever is placing a product for sale in the EU market, is responsible for its compliance. Companies buying directly from abroad therefore need to be increasingly vigilant and take steps themselves to ensure compliance, rather than rely on others to take on the burden of proof.

To meet the demand for low-cost goods, companies are increasingly buying electronic products and components directly from manufacturers abroad. However, many non-EU exporters are still unaware of or unsure about compliance requirements. Therefore, an EU company’s reliance on the CE marking applied by a non-EU manufacturer could mean that they are purchasing unsafe goods.

Customs officials keep watch for the CE marking on products, and those businesses importing into the EU are required to hold evidence of the test reports and certificates in the form of a technical file that proves compliance. If such information is missing, this may result in their prosecution as they have a legal responsibility for ensuring proof of compliance.

The Radio and Telecommunications Terminal Equipment Directive (R&TTE) is an excellent example of how this approach is failing within the electronics industry. Since its introduction in April 2000, the Directive has been the required method for those placing products on to the market to demonstrate compliance of any radio and telecoms equipment that is sold across Europe. This meant that manufacturers or importers could simply sign a declaration of conformity indicating that the product met the Essential Requirements and apply CE marking themselves, provided of course that there was an adequate technical file supporting the claim.

However, a market surveillance report conducted in 2003 in 19 European Conference of Postal and Telecommunications Administrations (CEPT) countries showed that 76 per cent of equipment that relies on the radio spectrum failed to comply with the R&TTE. Another CEPT market surveillance campaign conducted in 2005 showed that 88 per cent of the terminal equipment checked failed to comply with the Directive’s technical requirements.

As the European Commission became concerned about the low level of compliance with the R&TTE for some categories of radio equipment, it has published the new Radio Equipment Directive (RED) 2014/53/EU, which will be applicable from 13 June 2016.

More than safety

Many make the mistake of presuming that CE marking only relates to safety and EMC requirements. European harmonised standards detail technical tests and design requirements to meet essential requirements. Subsequently, products which are shown to meet the essential requirements of more than 20 EU Directives must display the CE marking.

The CE marking Directives which would most typically be applicable to consumer & technical products are - Restriction of Hazardous Substances (RoHS), Low Voltage Directive (LVD), Electromagnetic compatibility (EMC), Radio Equipment Directive (RED), Ecodesign of Energy-related Products (ErP), Energy labelling of Energy-related Products.

A modular approach ensures that CE marking Directives follow the same assessment processes - described in Council Decision 768/2008/EC. CE marking Directives each use one or more module (A to H), which lay out generic assessment methods:

· Module A – internal production control

· Module B – EC type examination

· Module C – conformity to type

· Module D – production quality assurance

· Module E – product quality assurance

· Module F – product verification

· Module G – unit verification

· Module H – full quality assurance

Brand reputation

On an increasingly technologically level playing field, it is brand reputation that sets one manufacturer apart from another. A significant part of reputation comes from a positive user experience, created through safe and reliable products that satisfy the intended use, meet consumer expectation and don’t harm anyone.

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