CE marking and Brexit

[duncan webster 1Participant @duncanwebster1]

Posted by SillyOldDuffer on 03/08/2016 20:20:09:

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

Thank the Lord for some sense at last, isn't it time this thread was put to bed before someone explodes.

[Neil WyattModerator @neilwyatt]

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

Only if it was for commercial purposes.

Neil

[Neil WyattModerator @neilwyatt]

Posted by SillyOldDuffer on 03/08/2016 20:20:09:

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.

Indeed. bear in kind the HSE specifically point out "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."

So if the business doesn't change anything or add any elements of their own making, they don't have to create any technical documentation, really just gather together the certifications of the OEM suppliers with their own operating procedures.

I hate to say this but after some 25 years involved with H&S most of these regs are actually quite sensible when it comes to actually putting them into action.

Neil

[Michael GilliganParticipant @michaelgilligan61133]

Posted by Neil Wyatt on 03/08/2016 16:56:16:

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.

.

Although the 'Answer' is logical and reasonable; the wording of that 'Frequently Asked Question' [taken out of context, as it has been by some on this thread], is perhaps unfortunate.

I agree with Duncan's closing remark.

MichaelG.

[Mark CParticipant @markc]

Firstly, Russel and Dave, I did not mean the BS people. I meant the subcontract certification houses who use the legislation as a cash cow.

Second, as I said before, why on earth do we (professional engineers?) need further layers of bureaucracy to cover what we all do anyway as it has always been covered by other acts?

Third, R&D has always done (dodgy) stuff that would never normally be allowed on the basis that design engineers ought to understand the risk. The way it always used to work involved closing the doors and making certain everyone was out of the way before you turned it on for the first time (usually hiding behind something substantial if it looked like it could escape when the power went on! There seems to be a developing problem with R&D in as much as how do you allow it within the constraints that are being imposed. And lets not even bother thinking about drawings and documentation (revision control etc)…..

Mark

[Andy AshParticipant @andyash24902]

Posted by S.D.L. on 03/08/2016 04:30:21:

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.

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

I usually am wrong, but in the case you cite, it is the shop that is listed and not the panel. Unfortunately you cannot self certify your own shop.

Obviously your particular cited scheme only applies in the US anyway, but with reference to my own comments UL reserve and confer special meaning to the words "listed" and "recognised". These meanings hold throughout the world, as far as I can see.

[Andy AshParticipant @andyash24902]

Posted by Michael Gilligan on 03/08/2016 20:59:21:

Posted by Neil Wyatt on 03/08/2016 16:56:16:

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.

.

Although the 'Answer' is logical and reasonable; the wording of that 'Frequently Asked Question' [taken out of context, as it has been by some on this thread], is perhaps unfortunate.

I agree with Duncan's closing remark.

MichaelG.

I must add to this by suggesting that even if the meaning were an actual directive (and not just FAQ), that this kind of intent will always be heavily flouted anyhow. I am unwilling to cite examples here because of the public and hostile nature of the discussion, but I witness it every day.

Unfortunately there are definite practical constraints that make such rules impractical. Often there is a choice to do no business, or to work around the book.

Edited By Andy Ash on 03/08/2016 21:53:37

[AjohnwParticipant @ajohnw51620]

CE approval can involve some costly equipment out of the scope of some companies so the people who offer the service for others at a cost need not be as bad as some may think. There can also be a problem interpreting exactly what legislation means.

One example of something that is costly is emissions work. Lots of things involve electronics and to get that through companies either have to pay some one to do it, rent an rfi lab or own their own. Rents are so high that it doesn't take an awful lot of work in that line to justify owning one. The other problem is skills. An external company may have some one that knows what to do to cure problems. In this case companies can approve their own products but need traceable documented proof that the items do meet the requirements. Calibration comes into things like this.

HSE is needed because companies will concentrate more on profit rather than the safety of their work force. There are some odd ones such as hgv drivers having to have breaks – needed because there was no saying how many hours they were expected to drive. Way too many at times. Same with the working time directive which isn't actually binding on workers. It's more of a case of not allowing people to be forced to work long hours. Companies have other methods of encouraging people to work as long as they want them to anyway.

EU – a lot of what they put out is aimed at obtaining a level playing field. Bit tough when salaries vary country to country but at least it does cause countries to work to the same basic rules – also certain civil rights. While certain quarters would like to get rid of the red tape involved with employing people that's unlikely to happen and again there are ways of circumventing some aspects anyway. There are signs that the state may be fed up of footing the bill these methods cause. On the other hand they might just be after collecting more tax and probably are. If wages stagnate so does the tax revenue.

Having to CE a line is a new one on me. I have seen various kit in production areas all CE'd and people behaving in a manner that allows the company to claim they work to certain quality standards. The only line I have seen put in recently was done by a specialist company. The work area was placement machines, wave solderers, test gear and etc. Not exactly a line in this case as people usually carried the stuff about by hand from one to another. HSE requirements yes, CE of it all put together. Afraid i don't think so.

What will change post Brexit – nothing needs to really and very probably wont. It would just be a costly ineffective thing to change.

The tele managed to put up some people that get info on directives who clearly don't understand what they were being given. Often a problem with legislation of any sort. I was reminded of a time when I temporarily exported some gear to Dublin. Some of the gear was in my car and some was on a truck. Had to fill in a form, total gobble de guke as far a I am concerned. Turned out that there was a bloke in a nice posh suit in a hut that charged £10 to fill them in for people. As that was about 30 years ago he must have been making a very good living. Busy man. So rather than guess what legislation means in practice find some one that really understands it. Obviously the advice will cost.

John

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Edited By Ajohnw on 03/08/2016 23:39:34

[Russell EberhardtParticipant @russelleberhardt48058]

Posted by Neil Wyatt on 03/08/2016 16:56:16:

.

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?

<Snipped.>

I think, Neil, that this is a typical case of the HSE overstepping the mark. They always try to make more work for themselves.

As far as I can tell the comments on their site are not supporte. by any EU Directives. Indeed the CE marking Directive makes it a criminal offence to apply the CE mark to anything that is not covered by a Directive that requires it to be marked.

Russell

[KWILParticipant @kwil]

All very interesting and applicable to "Work".

Nothing at all to do with ME or ME private workshops except when you buy electrical goods they should come properly CE marked as do commercially made boilers (at present)

[AjohnwParticipant @ajohnw51620]

Posted by Russell Eberhardt on 04/08/2016 11:28:06:

Posted by Neil Wyatt on 03/08/2016 16:56:16:

.

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?

<Snipped.>

I think, Neil, that this is a typical case of the HSE overstepping the mark. They always try to make more work for themselves.

As far as I can tell the comments on their site are not supporte. by any EU Directives. Indeed the CE marking Directive makes it a criminal offence to apply the CE mark to anything that is not covered by a Directive that requires it to be marked.

Russell

I think it's just confusing. What would they do stamp a CE mark on the entrances to the work areas in factories ? Or maybe on the building.

What I suspect it infers is that such places will get visits from an HS type person. They do. On the other hand maybe the company I mentioned chose to have people carry stuff about from machine to machine to avoid having to get CE approval and why they got specialists in to install something more akin to a production line. Afraid I don't think so. There is another aspect as well. Production lines sometimes have in house designed special purpose equipment some where along them. Lots of things are special purpose – plastic moulding tools, press tools and etc. Machines too. This is why manufacturers had large tool rooms some probably still do but often now it's done by a separate company.

Russel had a point as well. Employ a group of people to do something and they will find things to do even when there isn't really anything worth doing. I'd guess if I phoned up a CE outfit and asked if my home workshop needed CE approval they would only to be too pleased to do it and even might mislead me. That's life. I'd guess that the only sort of person who could clear up many point relating to CE and this sort of thing would be a director of a decent sized company who's general responsibility was the actual production work areas. They might just have a title of something like factory manager. A rather high grade job either way.

KWIL has a point as well. Also no change comments post Brexit. A lot of the stuff we make is exported to Europe. Having the approval will help exporting elsewhere as well. BSI suddenly go back to what it was – no chance. The only change that will happen post Brexit has been mentioned in the media a number of times. No longer being able to have any influence on what any standards contain but still having to work to them. This can apply to any product and could also possibly apply to financial areas. Frankly as far as product goes I don't think it really matters. I've had to cope with standards from several parts of the world. In general meeting one is very likely to meet all. In my case that has also included type approval. Even TUV which is something entirely different. There can be other factors creep in some areas as will. I doubt if many people watched C4's Dispatches on how safe is your car.It illustrates how the motor industry actually work. Me I''m an old style automotive person and think aspects like that really stink. Some other areas do too these days. Maybe a CE or whatever will prevent that sort of thing one day. Doubtful though. it's a fact that HS seldom stops large scale production. Some local yo yo factory inspector may stop a one man business. I here that at that level an unguarded belt is likely to get cut. Maybe also a don't use sticker like some gas fitters who buy loads of them. Good for business and is abused. That's life again.

John

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[speelwerkParticipant @speelwerk]

I am lost a little, Great Britain is leaving the EU to take matters in its own hand, they should set there own (higher) standards to which all imports must comply and refuse all import with CE and other standards. Niko.

[Sam Longley 1Participant @samlongley1]

Posted by speelwerk on 04/08/2016 14:33:43:

I am lost a little, Great Britain is leaving the EU to take matters in its own hand, they should set there own (higher) standards to which all imports must comply and refuse all import with CE and other standards. Niko.

What is the point of that ??

[duncan webster 1Participant @duncanwebster1]

Posted by speelwerk on 04/08/2016 14:33:43:

I am lost a little, Great Britain is leaving the EU to take matters in its own hand, they should set there own (higher) standards to which all imports must comply and refuse all import with CE and other standards. Niko.

That just makes everything, including what we manufacture here, more expensive. You can't have one standard for imports and a lower one for home produced stuff or the lawyers will have a field day.

[Neil WyattModerator @neilwyatt]

Posted by Russell Eberhardt on 04/08/2016 11:28:06:

Posted by Neil Wyatt on 03/08/2016 16:56:16:

.

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?

<Snipped.>

I think, Neil, that this is a typical case of the HSE overstepping the mark. They always try to make more work for themselves.

As far as I can tell the comments on their site are not supporte. by any EU Directives. Indeed the CE marking Directive makes it a criminal offence to apply the CE mark to anything that is not covered by a Directive that requires it to be marked.

Russell

Sorry Russell, I've just read much of the text of the EU machinery directive, it covers:

"assemblies of machinery referred to in the first, second and third indents or partly completed machinery referred to in point (g) which, in order to achieve the same end, are arranged and controlled so that they function as an integral whole" i.e. assembling a production line

and

"placing machinery on the market and/or putting it into service"

The HSE interpretation is clearly based on that basis.

(But they wouldn't cover John's example where items are transported between unlinked machinery in a sequence).

Neil

[speelwerkParticipant @speelwerk]

The point is that the UK wants all the advantages of the EU without any of the obligations, they were always reluctant members and kept on driving on the left while the rest of the EU drives on the right, so why make problems with CE standards as the UK standards have always been much better? Niko.

[Martin KyteParticipant @martinkyte99762]

Isn't that what a standard is. Some universal bench mark from which everything else is derived. The main point of Europe was to ensure things fitted together whether it was workers rights, weights and measures or safety of fire extinguishers. Sounds like some of you lot metaphorically speaking want to go back the the good old days when everybody had their own individual 'screw thread' which worked fine until you went out of your own back yard and then you were stuffed. The CE mark is the combined best practice of all the member sates pre-existing regs. Why re-invent anything.

regards Martin

[Jon GibbsParticipant @jongibbs59756]

Posted by speelwerk on 04/08/2016 14:50:12:

The point is that the UK wants all the advantages of the EU without any of the obligations, they were always reluctant members and kept on driving on the left while the rest of the EU drives on the right, so why make problems with CE standards as the UK standards have always been much better? Niko.

That's more than a bit of a generalization – I'd suggest that there is good evidence that almost half of the UK were happy to go along with their EU obligations

As an engineer working in international standards I'd be mightily surprise if our UK businesses don't continue to participate in, and attempt to influence, standards at the European level and more broadly whether we're in or out of the EU. We see more and more standards that are truly international particularly in Telecomms where I work and influence can be easily obtained with well located subsidiary companies or flags of convenience.

Jon

[AjohnwParticipant @ajohnw51620]

I don't interpret what you have stated as being a production line Neil. I see it relating to equipment that is built from multiple parts that may have ce approval and also stuff that will need it at some point. This is the problem with legal jargon. It's very easy to miss understand and assume it means things that it doesn't.

It's a logical extension of CE's on things like power supplies maybe linked to induction heating units. The result of that is something that should have CE approval on H&S grounds. Emissions too.

A production line may have one of these at some stage and many other dedicated pieces of equipment. What makes it a production line is that there will be some method of moving product from one stage to another and each movement will have a cycle time that needs to be the same for all operations the line performs. This often means that the slowest operation needs to have several stations to keep up.

Afraid I don't believe that anyone would want CE for that only H&S. These things are agreed and not just implemented by some dictatorial person.

No way would I employ you as a consultant. I do wonder if German interpretations could be some what different. It's a much more specific pedantic language.

John

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[Anna 1Participant @anna1]

Hi, all.

We have brexit, which could be a golden opportunity to but Britain on the map again. However, It strikes me unless we get rid of the British disease whereby 10 men with clipboards tell the one poor little worker / business how to do/ not to do the job, and in essence just get in the way and cause unwanted problems, this country is going nowhere. It is no wonder this countrys productivity is so low.

As an aside, a friends son is at university studying electronic engineering. I understand part of the course is a requirement to study "Corporate Speak", I will say no more.

Kind regards

Anna

[Neil WyattModerator @neilwyatt]

Posted by Ajohnw on 04/08/2016 16:08:52:

I don't interpret what you have stated as being a production line Neil. I see it relating to equipment that is built from multiple parts that may have ce approval and also stuff that will need it at some point. This is the problem with legal jargon. It's very easy to miss understand and assume it means things that it doesn't.

It's a logical extension of CE's on things like power supplies maybe linked to induction heating units. The result of that is something that should have CE approval on H&S grounds. Emissions too.

A production line may have one of these at some stage and many other dedicated pieces of equipment. What makes it a production line is that there will be some method of moving product from one stage to another and each movement will have a cycle time that needs to be the same for all operations the line performs. This often means that the slowest operation needs to have several stations to keep up.

Afraid I don't believe that anyone would want CE for that only H&S. These things are agreed and not just implemented by some dictatorial person.

No way would I employ you as a consultant. I do wonder if German interpretations could be some what different. It's a much more specific pedantic language.

John

–

Rather than shooting from the hip, why not read the HSE pages and the directive like I did and speak froma position of knowledge rather than guessing?

Neil

[duncan webster 1Participant @duncanwebster1]

What's this got to do with model engineering in any shape or form? Brexiteers will never see reason. Pull the plug moderators

[MuzzerParticipant @muzzer]

Because it's far easier to trade worthless opinions than to speak from knowledge.

[Sam Longley 1Participant @samlongley1]

Posted by speelwerk on 04/08/2016 14:50:12:

as the UK standards have always been much better? Niko.

Do you actually have hard evidence to back that statement— !!!

If you want an example of sub standard Britishness just start with motorbikes & work your way through cars whilst comparing them with Japanese ones then tell me UK standards have always been better

[MWParticipant @mw27036]

These are not the droids we are looking for.

[Author]

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