CE Wiring

[Killen]

I am banging my head against the wall trying to find someone in my area that would be interested in making some money wiring up lamps in the European Standard - CE Certified. I have spoke to several labs and they will simply not give me the name of someone they have certified. They want us to go through the certification process and wiring lamps is simply not our business.If you could help me find someone, if you could it would be most appreciated.

Thank you,

Jason

 

[eng1ne]

You should[/] come across the RoHS directive, as well as the Low Voltage directive and the WEEE directive, just to name a few which deals with the waste of electrical and electronic equipment.

I say should, because these will form part of your declaration of conformity - if you follow the proper routes!

The lamp isn't a 'substance', but like macgyvers said, the lead possibly used in your solder is! Some paints and pigments might include hazardous substances!

The only way you will do this yourself is if you follow the guidance on the authority's website with lots of attention, or employ a consultant!

 

[LionelHutz]

You're quite far off the mark with your assumption about what RoHS means.

I think you're quite confused with what CE means too though. Installing some wiring in a "CE approved shop" does not create a CE product. As already mentioned, the completed product is evaluated, not just some of the wires inside.

Dan - isn't there some requirement to provide the means for recycling the product too if applicable? Most likely something with metal and copper would require recycling.

 

[eng1ne]

Lionel, perhaps you are thinking of the WEEE directive, Waste of Electrical and Electronic Equipment?

 

[Killen]

Why can I not simply find someone who deals with this aspect of business in this region? I assume at this point it is "most always the manufacture" that has to deal with these regulations and this is something that is not typically outsourced. You all seem to know some of the details about this subject?

Just inquiring - does this apply to your daily business in any way?

Yes, I did read into the RoHS further and I am sure that is another optical we are going to have to hurtle in order to get this aspect of business moving forward - I am less then pleased to say. "I do appreciate the heads up on this added hurtle, sincerly".

 

[MacGyverS2000]

RoHS is most definitely a part of my daily business life. I cannot use leaded solder on anything I wish to ship out of the country (or to California, since they've accepted the majority of the RoHS edicts). When I use lead-free, I have to be more aware of what is being used, as well as the process used to solder... lead-free solder is a nasty bit that takes special care to make a solid connection, I cannot mix equipment between the two solder types, etc.



Lionel, my recycling "plan" is "Send it back to us and we'll dispose of it for you". Considering the type of products I produce, I doubt I'll ever receive a single item back.

Dan - Owner

http://www.Hi-TecDesigns.com

 

[eng1ne]

Being in the EU, it is something I am familiar with, though do not encounter very often with respect to consumer goods. I have only thus far certified equipments for use within explosive atmospheres which requires a CE mark.

Most consultancies will offer you a free consultation. No answer or advise on here would be as valuable as those obtained from professional consultants.

Go to the pages below, explain that you have a lamp you wish to certify for export to the EU, and take it from there.

You might find the cost for them to review your manufacturing processes and the final product is not quite as expensive as you'd expect! Then again, it might be astronomical, but there is only one way to find out!

http://complianceinsight.ca/Consulting/FreeConsult.html

http://www.centronsolutions.com/contact.php

http://www.barclay-phelps.com/page8.html

Note though, that these have been pulled out of Google at random.

 

[zappedagain]

I'll give a plug for F-Squared labs in Ohio/Maryland (

http://www.f2labs.com).

Is that close enough to Dallas? They could probably help with your testing. They have tested my equipment for Europe and I highly recommend them.

You also might want to check out this site:

http://www.cemarking.net/

You can take Hans' free course to get up to speed on CE Marking.

John D

 

[Killen]

John,

I do appreciate the feedback, but Ohio is further then Atlanta and so is Maryland. I have spoke with Han about this as well and he was able to give me a clear understanding, but it still does not help my situation in finding someone to take the lamps and certify.

Thanks again,

Jason

 

[DYV1973]

CE means that the manufacturer or the company that imports the products, declares that the products are in conformatity with all applicable European guidelines. If a company decides (eg by its own measurements) that the product is conform these European regulations, it can put the CE mark on it. These means that the company that puts the CE mark on it, will be liable if failures / accidents occur that were ruled out by the European regulations, and for which the product turns out not to comply. Most of the time 1 one of the obligations is that you need a file in which construction / design is evaluated. Other regulations that are applicable depend on the type of product, but they mainly base on saftey, health and environmental risks. And for a lamp this could be something simple as the risk of getting burned by the hot surface. Further the documentation needs probably to be in the local language.

It is in fact quite simple: If you are confident that you are in compliance with the European rules and regulations, put a CE mark on it. If you are not, then hire a consultant that can tell you exactly which regulations are applicable, or try to find out yourselves at the internet:

http://eur-lex.europa.eu

You can also find out in which cases a notified body is required (you can recognize these on the CE including a 4 digit number).

In this business case you have to weigh your expected earnings against investing time/money for CE, with keeping in mind the financial risks for not being secure. Penalties for using the CE mark without fullfilling the requirements are high, as it is considered to be economical crime.

It is probably most convenient to contact a European certification institute like KEMA or TuV.

 

[Killen]

Thank you, that was informative. We are not looking to take the risk of backing up the wiring or taking liability for it. That is the sole purpose we are trying to find someone to take care of certifying the product for us.

 

[itsmoked]

You will unfortunately have to if you want to sell into CE land.

You can have someone else build the whole thing but YOU are responsible for making sure it gets built correctly.

Same thing you see with Chinese poison products. The US toy company takes the heat when lead is discovered not the Chinese company. (Though of course heads roll there too.)

Same with this. If you have another company assemble/build your product you must inspect or have the product line watched. You need to make sure they don't switch to cheap dangerous wire or lead based paint after a day, or week, or month, or year.

Keith Cress
kcress -

http://www.flaminsystems.com

 

[Killen]

What makes you believe what you just stated is true. For what I understand who ever places the CE sticker with their marking on it is liable for the proformance of the product and takes liability for compliance.

 

[benta]

Global, what is not clear to me is your business model here. Do you intend to sell in volume to an importer in the EU? Or do you plan to sell directly to consumers?

There is a reason for these questions. If a product is produced in the EU, the manufacturer has liability and has to sin the declarations of conformance. This is not the case here.

In your case, the company *importing* goods into the EU is legally regarded as the "manufacturer", and he has to sign the DoC's.
Now, not a lot of trade companies like to do this, so they come back to the producer and ask for backup declarations and test reports.
However, if you do have an importer, you might ask him to help finding a test house in Europe, as he will have to sign the documents in the end.

If you are selling directly to consumers (like over the Web), there is an "own use" clause, which means products do not necessarily need to be CE/RoHS/WEEE conform, that's customer's own responsibility.

Best Regards,

Benta.

 

[MacGyverS2000]

benta,

I'd certainly be interested in hearing a bit more about this "own use" clause... can you point to any documentation (or sections of the RoHS code) that specify this?

Dan - Owner

http://www.Hi-TecDesigns.com

 

[Killen]

Benta,

We only sell to retailers or interior designers. This will likely turn into a mass production thing where we import many lamps (hundreds) and a portion of those will need to be either "wired" or "rewired" for export to Europe.

 

[benta]

Dan, a quick search found this:

http://www.conformance.co.uk/directives/puwer.php

The key phrase both for RoHS and CE is "put on the market", which is not the case for "own use".

Regards,

Benta.

 

[MacGyverS2000]

benta,

Your first post on "own use" seemed to suggest the CE compliance was only required if the product was sold to resellers, but not straight to customers. Obviously this didn't seem correct to me, hence my question. Reading over the link you sent, those rules apply to equipment to be used "in-house" by employees, not to anything that is sold for profit.

Were you intending otherwise?


Dan - Owner

http://www.Hi-TecDesigns.com