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'[EE] CE self-certification'
2007\08\14@224544 by Vitaliy

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M. Adam Davis wrote:
> It's too bad we can't self-certify such devices like CE allows one to do.


Have you ever actually done it?

Last time I checked, you had to fly a CE rep over to the certifying lab, pay
his fare/room/board, plus whatever CE charges for the rep to be on site.

Best regards,

Vitaliy

2007\08\14@225627 by M. Adam Davis

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I am unfamiliar with the complete CE certification process.  I've CE
certified one device, and it was a usb memory card reader
(unintentional radiator, low power, etc).  Further, it was through
TUV, and they have offices and lawyers in the EU so they have local
representation.

-Adam

On 8/14/07, Vitaliy <spam_OUTspamTakeThisOuTspammaksimov.org> wrote:
{Quote hidden}

> -

2007\08\14@231931 by Gerhard Fiedler

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M. Adam Davis wrote:

> On 8/14/07, Vitaliy <.....spamKILLspamspam@spam@maksimov.org> wrote:
>> Last time I checked, you had to fly a CE rep over to the certifying lab,
>> pay his fare/room/board, plus whatever CE charges for the rep to be on
>> site.

I don't think this is correct. AFAIK there are labs in the USA that can do
the certification where necessary, e.g. TUV USA
<http://www.tuv-usa.com/services.htm>.

> I am unfamiliar with the complete CE certification process.  I've CE
> certified one device, and it was a usb memory card reader (unintentional
> radiator, low power, etc). Further, it was through TUV, and they have
> offices and lawyers in the EU so they have local representation.

As above... TUV is also present in the USA. But I don't think they are the
only ones in the USA.

AFAIK there are some classes of devices that may be self-certified, whereas
others require an accredited lab to run the certification tests.

Gerhard

2007\08\15@104320 by alan smith

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Didn't it used to be a one-player game...UL Labs? Then the monopoly was broken up some years ago, and now its called NRTL (national regulatory testing labs) certification and....as far as I can recall its still TUV Rhineland and UL that are doing it.  Its just the TUV is usually easier to work with on issues.  Just remember to renew the fees every year...just so they can keep the paperwork in a active folder

Gerhard Fiedler <listsspamKILLspamconnectionbrazil.com> wrote:  M. Adam Davis wrote:

> On 8/14/07, Vitaliy wrote:
>> Last time I checked, you had to fly a CE rep over to the certifying lab,
>> pay his fare/room/board, plus whatever CE charges for the rep to be on
>> site.

I don't think this is correct. AFAIK there are labs in the USA that can do
the certification where necessary, e.g. TUV USA
.

> I am unfamiliar with the complete CE certification process. I've CE
> certified one device, and it was a usb memory card reader (unintentional
> radiator, low power, etc). Further, it was through TUV, and they have
> offices and lawyers in the EU so they have local representation.

As above... TUV is also present in the USA. But I don't think they are the
only ones in the USA.

AFAIK there are some classes of devices that may be self-certified, whereas
others require an accredited lab to run the certification tests.

Gerhard

2007\08\15@170045 by Howard Winter

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Vitaliy,

On Tue, 14 Aug 2007 19:42:56 -0700, Vitaliy wrote:

> M. Adam Davis wrote:
> > It's too bad we can't self-certify such devices like CE allows one to do.
>
>
> Have you ever actually done it?
>
> Last time I checked, you had to fly a CE rep over to the certifying lab, pay
> his fare/room/board, plus whatever CE charges for the rep to be on site.

I'm confused!  CE is a certification mark (it means European Conformity, in French) - what would be a "CE Rep"?  

As far as I know there is no organisation for anyone to be a Rep for!  Any labs doing certification work would know the requirements of the product
they are testing in order to satisfy CE marking, so if you are using a lab they should be able to do the work without outside interference - and as I
say, there is nobody to do so anyway.

Cheers,


Howard Winter
St.Albans, England


2007\08\15@220231 by Vitaliy

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Howard Winter wrote:
> I'm confused!  CE is a certification mark (it means European Conformity,
> in French) - what would be a "CE Rep"?
>
> As far as I know there is no organisation for anyone to be a Rep for!  Any
> labs doing certification work would know the requirements of the product
> they are testing in order to satisfy CE marking, so if you are using a lab
> they should be able to do the work without outside interference - and as I
> say, there is nobody to do so anyway.

Another person at our company was primarily responsible for doing the CE
research, so I don't know all the details at this time. However, he told me
that only one of the labs he contacted did not have to have the rep flown
in, and that was only because its headquarters were in Europe.

One of these days I will look through the communication, and will try to
make sense of it. It could be that the representative had to be there
because we were interested in getting our device both CE and eMark
certified.

...to be continued...

2007\08\16@035940 by Ruben Jönsson

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{Quote hidden}

The CE mark states that a product is compliant against all relevant european
directives and legislations that are in the scope for that product. There are
quite a few:

EMC - Electromagnetic compatibility, emission and immunity.
LVD - Low voltage directive, electric safety against fire and shock.
ATEX - Equipment used in explosive gas and dust atmosphere.
Machine directive - Safety requirements for machines with moveable parts.
R&TTE - Radio equipment.
RoHS - Hazardous substances (including lead)
WEEE - Waste electrical and electronic equipment
TOYS - Safety of toys
And some more...

Some directives allows self-certification and some don't. Some directives have
different levels, classes or categories where the lower ones allows self-
certification (the ATEX directive for example).

The directives normally don't state a specific standard to test against but
there are usually harmonized standards that, when met, will guarantee
compliance. In some cases there doesn't exist relevant standards or the
standards that do exist can't be used on the equipment. Then compliance can be
done through a "technical construction file" where the manufacturer
demonstrates that the product meets the requirement of the directive. The
technical construction file also has to be assessed by a competent body.

The directives that don't allow self-certification will require that a
notified/competent/approved body assesses the equipment. In some cases the
identification number of the notified body must be included on the CE mark
(together with data, classes, categories, levels...).

The EMC directive can be self certified to standards without the use of a
notified/competent/approved body for equipment that doesn't include a radio
transmitter. In the this case the declaration of conformity document must list
all of the relevant harmonized standards that have been used. By signing this
declaration the manufacturer guarantees that the product is compliant to the
directive. The manufacturer doesn't even have to keep documents that shows
this. He actually doesn't even have to test the equipment.

Some directives exclude other directives. The ATEX directive exlude the LVD
directive and the machine directive have it's own limits for EMC compliance
(which can't be self certified) to name some.

/Ruben


==============================
Ruben Jönsson
AB Liros Electronic
Box 9124, 200 39 Malmö, Sweden
TEL INT +46 40142078
FAX INT +46 40947388
.....rubenKILLspamspam.....pp.sbbs.se
==============================

2007\08\16@074107 by Xiaofan Chen

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On 8/16/07, Ruben Jönsson <EraseMErubenspam_OUTspamTakeThisOuTpp.sbbs.se> wrote:
>
> The CE mark states that a product is compliant against all relevant european
> directives and legislations that are in the scope for that product. There are
> quite a few:
>
> EMC - Electromagnetic compatibility, emission and immunity.
> LVD - Low voltage directive, electric safety against fire and shock.
> ATEX - Equipment used in explosive gas and dust atmosphere.
> Machine directive - Safety requirements for machines with moveable parts.
> R&TTE - Radio equipment.
> RoHS - Hazardous substances (including lead)
> WEEE - Waste electrical and electronic equipment
> TOYS - Safety of toys
> And some more...
>
> Some directives allows self-certification and some don't. Some directives have
> different levels, classes or categories where the lower ones allows self-
> certification (the ATEX directive for example).

Good to know this. For me ATEX is always very stringent. Maybe I
am wrong. I have only dealt with EEx i, EEx d, and EEx n.

> The EMC directive can be self certified to standards without the use of a
> notified/competent/approved body for equipment that doesn't include a radio
> transmitter. In the this case the declaration of conformity document must list
> all of the relevant harmonized standards that have been used. By signing this
> declaration the manufacturer guarantees that the product is compliant to the
> directive. The manufacturer doesn't even have to keep documents that shows
> this. He actually doesn't even have to test the equipment.

I do not know. I was always asked to keep the test documents. I was
even told to take nice photos so that the reports are presentable.

Anyway, the customers can always request for the test documents.
And I will be very cautious to deal with a small vendor who
does self-certification without a proper test document.

> Some directives exclude other directives. The ATEX directive exlude the LVD
> directive and the machine directive have it's own limits for EMC compliance
> (which can't be self certified) to name some.

I know that the marine industry have their own EMC limits and I think
you can not do self-certification.

Xiaofan

2007\08\16@083833 by Ruben Jönsson

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{Quote hidden}

Electrical category 3 equipment (for zone 2 and 22) and non electrical category
2 and 3 equipment (for zone 1,2,21 and 22) can be self certified.

{Quote hidden}

Of course it is good practice to keep these document (we always do so too)
but the eu directive doesn't actually require it (not yet anyway).

{Quote hidden}

/Ruben==============================
Ruben Jönsson
AB Liros Electronic
Box 9124, 200 39 Malmö, Sweden
TEL INT +46 40142078
FAX INT +46 40947388
@spam@rubenKILLspamspampp.sbbs.se
==============================

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