CE marking and Brexit

[Mark CParticipant @markc]

Neil,

"the systems are all in place already. What has to change"

Exactly, We have been building production lines for years and managing happily with the HSE and the other directives, why do we suddenly need to CE mark?

As for making a dangerous packing line; sorry, I forgot to mention we are boxing spent reactor rods…. but then again that would fall under its own special controls and CE would not get a look in. On a less flippant note, how exactly can you envisage a dangerous packing line that would not be covered by existing HSE legislation (anyone remember the nice factories inspector by the way?).

Mark

[AjohnwParticipant @ajohnw51620]

Posted by Neil Wyatt on 02/08/2016 08:11:09:

The systems are all in place already. What has to change?

Neil

Exactly. Other than the point David raises – company movement so that it's still under the EU umbrella. If Brexit really means Brexit there is likely to be lots of that so that companies retain full access to the market. Plus the ability to influence standards of one sort or another of course. Those in general sense are derived from the views of the people who have to use them via consultation.

John

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[David JuppParticipant @davidjupp51506]

Bear in mind that the EU directives are largely about free movement of goods – the 'safety' bit is only there to prevent member states using differing safety legislation as a barrier to free movement.

If a company provides a complete production line to you – directives apply to the complete system (Machinery Directive plus maybe others). If assembled in house, even if by a contractor under your direction, then other legislation likely covers that.

In Pressure Systems (which I do know something about) a supplied system has to comply with PED (PER in UK), an in house assembled or modified system is subject to PSSR.

In Pharmaceutical industry, production systems have to be 'validated' (for FDA compliance), it becomes very difficult to make any changes, as that requires the validation process to be repeated. That has been the case for a long time.

I'm ignoring any 'for trade' aspects of the weigh station, which might require approval in the finished installation.

[BazyleParticipant @bazyle]

On a simpler note that affects us all probably so is easy to relate to. Each electronic gadget has to be approved with the psu it will be supplied with. Customer uses a perfectly working equivalent psu of another gadget it is no longer covered by its certification.

Not difficult but mfr gets another psu for security of supply, cost saving, pretty colour etc and it has to be re-certified. May only be a partial redo at £10k instead of £50k but still another cost. If the psu mfr decides to make the unit obsolete for marketing reasons and bring out a new model it sounds like progress. Each of their say 100 customers (OEMs) has to recertify with the new model so 100x £10k or more costs.to industry and the consumer for paperwork of dubious value.

[Tim StevensParticipant @timstevens64731]

One thing will catch lots of us out, is the little panel on our car numberplates with the twelve stars and a tiny GB.

Once we are out that will no longer be valid in Europe, and to drive on the continent we will need to comply with the Paris Convention of 1921. This mean we must carry an 'oval white plate 300mm x 180mm' on which are painted the letters GB. Or risk being fined at the roadside by any gendarme whose breakfast was not perfect.

I wonder how much that change will cost us all?

Cheers, Tim

[Bill DawesParticipant @billdawes]

In my position as part time engineering manager (I 'retired' 8 years ago) with an industrial fan manufacturer I have dealt with directives and regulations and associated standards a lot over the years. I don't see much changing to be honest, they still have to be complied with to enable a CE mark and selling into the EU. Most of the regs that we work to are quite sensible to be honest and in fact other countries outside the EU accept them as a sign of an authoritative standard of design. I fully expect it to be business as usual in this respect.

In the run up and post referendum there has been a lot of rubbish and misconceptions about the UK in the EU. the common theme being on the basis of 'in the EU we have this situation', by implication being if we leave this will change or not exist anymore.

Bill D

[Neil WyattModerator @neilwyatt]

Posted by David Jupp on 02/08/2016 09:53:14:

Notified Bodies are appointed by Member States of the EU – so depending upon quite what Brexit ends up meaning, it is possible that the UK may not be able to appoint Notified Bodies. I think nobody has a real clue about which way this will end up. I am aware of one UK Notified body that has taken the precaution of registering a company in another EU country, so that if necessary it will be able to provide services within the UK under the umbrella of that new company.

UK manufacturers can already choose to use NBs from other EU states if they so wish – some have offices in the UK.

As long as the UK has a mutual recognition agreement with the EU (the likely situation as EU countries won't want to have to pay for BS certification as win order to sell to the UK), it won't be an issue, we can still have UK Notified Bodies.

I suspect the truth about Brexit is that in practice very little will change for the way businesses operate.

Neil

[Neil WyattModerator @neilwyatt]

Posted by Tim Stevens on 02/08/2016 16:15:01:

One thing will catch lots of us out, is the little panel on our car numberplates with the twelve stars and a tiny GB.

Once we are out that will no longer be valid in Europe, and to drive on the continent we will need to comply with the Paris Convention of 1921. This mean we must carry an 'oval white plate 300mm x 180mm' on which are painted the letters GB. Or risk being fined at the roadside by any gendarme whose breakfast was not perfect.

I wonder how much that change will cost us all?

Cheers, Tim

As I recall from the days before the EEC they were more like 4" x 3" and usually sticky-backed plastic.

I think car ferry companies did a brisk trade in them and little yellow headlight converters.

Neil

[AjohnwParticipant @ajohnw51620]

Posted by Bill Dawes on 02/08/2016 18:54:32:

In my position as part time engineering manager (I 'retired' 8 years ago) with an industrial fan manufacturer I have dealt with directives and regulations and associated standards a lot over the years. I don't see much changing to be honest, they still have to be complied with to enable a CE mark and selling into the EU. Most of the regs that we work to are quite sensible to be honest and in fact other countries outside the EU accept them as a sign of an authoritative standard of design. I fully expect it to be business as usual in this respect.

In the run up and post referendum there has been a lot of rubbish and misconceptions about the UK in the EU. the common theme being on the basis of 'in the EU we have this situation', by implication being if we leave this will change or not exist anymore.

Bill D

That is oh so true Bill and most regs are pretty sensible really and often relate to what other countries use anyway.

The complication could be not having free access to the market and if that is the case a lot of none obvious things will change. A number of companies for instance that one way or the other pay considerable amounts of tax have already said that they must have this. Bang goes at least some of the tax if they move to retain it. Also some jobs.

John

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[MuzzerParticipant @muzzer]

Components (drives, power supplies etc etc) have ALWAYS had to be marked up, either UL, CSA, VDE, SEMKO etc etc etc. The only difference with the CE mark is that one marking applies to ALL of Europe so you don't have to get products approved in every single European country, which is pretty much how it was when I started out 30 odd years ago.

When you build a system from components, you still have to have it (the system) approved for the market you want to sell it in (yes, by UL, CSA etc etc). So if it's Europe, you have a CE mark, if it's USA you have a UL mark, if it's Canada you have a CSA mark etc etc. It's really very simple. Sadly perhaps for some, it's got absolutely nothing to do with Brexit or the EU.

As I said it's ALWAYS been this way, at least for most of our lifetimes. Quite simply, you will NOT be able to sell your product unless it is approved by the national approvals body and generally they require you to show the mark that indicates that approval. Conversely if you show the mark and haven't actually got approval you can get into some serious bother. Do people who have this irrational dislike of the CE mark also have a hatred of the UL,CSA etc marks too? Only asking.

We still still have CE marks on most of our products and soon perhaps (eventually) we will also have a "BS" mark too. Is that helpful? I must say, there seems to be no shortage of "BS" to choose from, much of it uninformed and negative…..

[Russell EberhardtParticipant @russelleberhardt48058]

Posted by Muzzer on 02/08/2016 19:23:27:

Components (drives, power supplies etc etc) have ALWAYS had to be marked up, either UL, CSA, VDE, SEMKO etc etc etc. The only difference with the CE mark is that one marking applies to ALL of Europe so you don't have to get products approved in every single European country, which is pretty much how it was when I started out 30 odd years ago.

That has always been a bit debatable. Consider for example a bare board switching power supply. It can in no way comply with the LV Directive nor the EMC Directive so cannot be CE marked. However it can be sold to a company who uses it in a system which is tested and CE marked before being placed on the market.

Russell

[Mark CParticipant @markc]

Muzzer, I am taking it that you think I have a hatred of CE. I do not, it is a good idea for the things it was originally meant for especially domestic kit. The problems start when the people start making money out of doing the certification and then they get on the standards committee due to their "expertise". This then becomes a self gratifying exercise in charging for what we all did before some one required proof and certificates. CE marking production lines built by you for your own use has no place in manufacturing – all you need is HSE….. I can assure you it will stifle R&D and I say this as I have direct experience of people deciding against a project due to the red tape to be dealt with. Its easier to get a cheap machine overseas with dubious certification and forget all the grief. Or better still, just off shore the job all together and further help turn our economy into a service based economy making diddle squat.

Mark

[Old SchoolParticipant @oldschool]

Posted by Sam Longley 1 on 02/08/2016 07:23:49:

Posted by Old School on 01/08/2016 19:12:25:

Most standards used in the EU are Euro Norms each country publishes it own standard with a national forward for us they are BS EN and for France they are NF EN etc, so in reality BSI sells quite small quantities of standards. Most of the experts BSI uses come from industry and a large part of the costs of these experts is paid by industry. For us to supply product into Europe we will still need to find some way of CE marking a lot of it is done by manufacturers who are allowed to self certify under a scheme run by BSI. It going to take some sorting out.

I hope that you are not putting the BSI down- ( a British disease I believe )

It is a world leader in advising on standards in industry,

[Old SchoolParticipant @oldschool]

Worked as a UK expert and Chairman of a working group for BSI not putting them down just stating a fact far to many are copied these days. Also as a working group member I used to get a free copy of any standards I work on.

Edited By Old School on 02/08/2016 20:56:44

[AjohnwParticipant @ajohnw51620]

We are already largely a service based economy Mark. The UK has been doing pretty well developing automotive electronics mainly I think down to skills and wage levels in that area but it's slowly been fading away for many years.

In any case actual manufacture often gets shipped out for the simple reason it's a bit cheaper. The biggest cost is the development and the gear for manufacture which in many cases needs very few people to drive it especially high volume stuff.

The other problem with manufacture is parts. Even Dyson sent that to the far east for the simple reason that is where the parts he needs were.

The other problem of course is just selling means less risks, less money invested, higher profit margins and a simpler life.

Having spent most of my working life in development I don't think that there is much concern about eventual compliance with this and that. All have to meet that – at some point. Getting something ready for that is part of the job. R&D is very similar but I feel I should mention that research is not the same thing as development. Development means that there will be a product at the end.

HSE actually working in this sort of area. Best not mention it but we did do risk assessments – of some sort or the other but sometimes to a certain extent getting the job done takes a higher priority.

John

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[Brian GParticipant @briang]

Is there any justification for assuming that Britain will not continue to manufacture CE marked products, and to require CE marking of products? Despite whatever Boris Johnson may have said, Turkey remains outside the EU and has little prospect of joining in the near future, yet it still requires CE marking of applicable products, as do Norway and Iceland.

Even if we chose to return to the kite mark, we would probably have to equal or exceed the requirement for CE marking in order to obtain mutual recognition of conformity.

Brian

[Andy AshParticipant @andyash24902]

Posted by Muzzer on 02/08/2016 19:23:27:

Components (drives, power supplies etc etc) have ALWAYS had to be marked up, either UL, CSA, VDE, SEMKO etc etc etc. The only difference with the CE mark is that one marking applies to ALL of Europe so you don't have to get products approved in every single European country, which is pretty much how it was when I started out 30 odd years ago.

When you build a system from components, you still have to have it (the system) approved for the market you want to sell it in (yes, by UL, CSA etc etc). So if it's Europe, you have a CE mark, if it's USA you have a UL mark, if it's Canada you have a CSA mark etc etc. It's really very simple. Sadly perhaps for some, it's got absolutely nothing to do with Brexit or the EU.

As I said it's ALWAYS been this way, at least for most of our lifetimes. Quite simply, you will NOT be able to sell your product unless it is approved by the national approvals body and generally they require you to show the mark that indicates that approval. Conversely if you show the mark and haven't actually got approval you can get into some serious bother. Do people who have this irrational dislike of the CE mark also have a hatred of the UL,CSA etc marks too? Only asking.

We still still have CE marks on most of our products and soon perhaps (eventually) we will also have a "BS" mark too. Is that helpful? I must say, there seems to be no shortage of "BS" to choose from, much of it uninformed and negative…..

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.

[Anonymous]

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

[S.D.L.Participant @s-d-l]

Posted by Andy Ash on 02/08/2016 21:42:25:

Posted by Muzzer on 02/08/2016 19:23:27:

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.

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

[Russell EberhardtParticipant @russelleberhardt48058]

Posted by Mark C on 02/08/2016 20:15:19:

CE marking production lines built by you for your own use has no place in manufacturing – all you need is HSE…..

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.

[steamdaveParticipant @steamdave]

Posted by Russell Eberhardt on 03/08/2016 15:44:35:

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

[Neil WyattModerator @neilwyatt]

Posted by Russell Eberhardt on 03/08/2016 15:44:35:

Posted by Mark C on 02/08/2016 20:15:19:

CE marking production lines built by you for your own use has no place in manufacturing – all you need is HSE…..

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.

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?

Yes. When you combine a series of complete machines and / or partly completed machines so they operate as a single assembly line (ie under a single control system), you have to:

• apply the CE mark
• issue a Declaration of Conformity
• produce / keep a technical file

This must be done for the complete assembly line as a whole, even if each individual machine has its own CE mark. 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.

and:

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

It depends on the product but you must CE mark work equipment that comes under the Machinery Directive and make sure it meets all of its essential health and safety requirements – even if it is only for your own use and you have no intention of supplying it to other parties.

[Anna 1Participant @anna1]

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

[AjohnwParticipant @ajohnw51620]

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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[SillyOldDufferModerator @sillyoldduffer]

Posted by Anna 1 on 03/08/2016 17:54:46:

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

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

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