So Much For CE Labels!

[Michael GilliganParticipant @michaelgilligan61133]

Posted by SillyOldDuffer on 25/01/2021 12:22:19:

[…]

The UK Government website here explains what has to be done to implement UKCA.

Dave

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<< Snap ! >>

MichaelG.

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Edit: … and, reverting to the earlier discussion; it specifically states:

• you must not place any marking or sign that may misconstrue the meaning or form of the UKCA marking to third parties

Edited By Michael Gilligan on 25/01/2021 14:48:11

[old martParticipant @oldmart]

We still don't know the name of the shop the lamp came from.

[Former MemberParticipant @formermember12892]

[This posting has been removed]

[pgk pgkParticipant @pgkpgk17461]

Posted by SillyOldDuffer on 25/01/2021 12:47:57:…., people believed Skoda's were nasty, irrespective of their actual qualities.

'Skoda' in czech was (is) used as slang for '(that's a) shame' and the 1000MB was referred to as "1000 small pains)

pgk

[Anonymous]

Posted by Howard Lewis on 25/01/2021 11:23:02:

Being a sceptic can extend your life span. Don't believe all that you are told, examine and analyse.

+1
… but be prepared to explain the difference between cynicism and scepticism.

[duncan webster 1Participant @duncanwebster1]

So if a UK company wants to import stuff from the EU and sell it in UK he has to ensure it meets all the relevant UK regs and put on this new mark. That doesn't come for nothing, so the price goes up. Of course if the UK regs exactly match the EU regs he can just stick the label on, but what exactly is the point of all this bureaucracy.

I'll shut up now before it gets political

[john fletcher 1Participant @johnfletcher1]

We have had 2 Skoda cars, the first was an early front engine job, good reliable car, easy to work on and cheap spare when required, after 4 trouble free years of motoring, we bought a second hand Felicia. The Felicia, took us to South of France 6 times. The last long trip was 4 weeks camping in Eastern Europe, via Belgium, Germany, Poland, Czech. The Skoda works is huge, they make machine tools as well VW Polo cars. We also visited Berlin, Dresden, Leipzig and Coldiz on the way home. John

[Anonymous]

It's odd, but whenever I try to reply to Michael's post and press "Add Posting" I get a page with the address:

https://www.model-engineer.co.uk/generic/forums_admin.asp

which says: "Sorry – the page you requested cannot be displayed at this time. Please try again later. "

(Not temporary, been happening for a couple of hours).

Edited By Peter Greene on 25/01/2021 18:34:17

[noel shelleyParticipant @noelshelley55608]

funny that SOD should mention skoda bolt quality we had the same trouble with zetor tractors ! noel

[Michael GilliganParticipant @michaelgilligan61133]

Posted by Peter Greene on 25/01/2021 18:20:46:

It's odd, but whenever I try to reply to Michael's post and press "Add Posting" […]

.

None of my doing, I assure you

MichaelG.

[Anonymous]

No, I wasn't suggesting it was something you did, Michael … doubt that you could.

I still can't post my response to your earlier message. I'll try posting just the quote without my response after this.

Edit … tried to post just the quote and still it won't let me.

Edited By Peter Greene on 25/01/2021 22:19:28

[Nigel Graham 2Participant @nigelgraham2]

Duncan –

You ask the point of the bureaucracy.

There are two.

One is the obvious, that of trying to ensure that goods are sold fit for purpose.

The other, and hinted at by contributors, is mere protectionism.

When the subject first appeared for us with the Pressure Equipment Regulations I bought copies of the two official documents. One is the law itself, seeming written by lawyers for lawyers who wouldn't know a toothed steel bar is a 'file' but had heard of pressure-vessels made from aluminium-alloy and stainless-steel. The other is a booklet by our own DTI and clearly written by professional engineers and legal advisors to help professional engineers to comply with the law.

It is clear from the UK-law version of the EU document, that product safety is the lesser consideration, versus trade-barrier and money-spinner for "Notified Bodies". The document even gives a little drawing showing the correct form and proportions of the CE label.

.

I worked for some ten years at a lowly level in the scientific civil-service. Then we were sold off, rather dodgily that elicited Questions in Parliament, whereupon the non-ISO-registered Govt. agency that was still our primary customer insisted we had to be ISO-9001 accredited. We felt insulted because our work was not changing and They had always been happy with it.

We were all sent on short courses that explained that ISO9001 drew heavily on the old UK DEF-STAN system, a genuine technical guarantee scheme; but the Americans refuse to recognise any foreigners' standards although they tolerate ISO. However, ISO9001 is a guarantee not of quality necessarily, but of consistency.

The course failed to warn of us of ISO900x's deadening top-down stifling of initiative and even suggestions – "Sorry – can't. Not in the Procedures." It did though question the idea that low-quality work can gain ISO900x if it is consistent, and to written processes. Whilst theoretically true that would obviously be commercially self-destructive.

So we laboriously wrote hundreds of Guides, Work Instructions and Procedures, differing by degrees of prescription. The templates were credibly, allegedly copied from some American business-school text-book, so had 2 A4 pages of useful stuff, several of waffle and a few "intentionally blank" – no-one knew why – but added the real instructions as a mere Appendix!

I prepared one for a particular piece of lab equipment, and it became what I called "Auditor Bait" for the company's internal auditors to make them feel – and the WI look – useful enough to avoid awkward questions. I hung the folder invitingly from the equipment; and watched the posse, clip-boards drawn a la Clint Eastwood, come in, tick off the WI's existence, title and page-width Master Copy reference- number, and be happy.

They never knew because they never asked, that the instructions were out of date! For soon after my writing them my manager heavily modified the rig to perform the same tests in a very different way. Unfortunately the old Work Instructions were by now lithified in the 3rd draw of the 4th filing-cabinet of Room…, so the Auditor Bait remained just that. We who were paid to use it, knew how to use it.

The real, external auditors did give the company the ISO9001 ticket we'd been forced into striving for – but only after we'd stripped our newly-invented bureaucracy back to what was necessary.

So much for ISO9001. QA? Not really. It's a costly management-control scheme.

[Anonymous]

Michael Gilligan wrote

you must not place any marking or sign that may misconstrue the meaning or form of the UKCA marking to third parties.

——-

With my best internet wannabe lawyer hat on … seems to me there's a lot of legal difference between saying "though shalt not copy our mark" and "thou shalt not use anything similar". Is this really any better than the CE mark situation?

 

(Michael, in order to finally get this to post I had to manually retype the quote. Quoting it in the normal fashion or even cutting/pasting it wouldn't work …. I assume you cut/pasted from the source? maybe there's some hidden character in it)

Edited By Peter Greene on 25/01/2021 22:32:40

[Michael GilliganParticipant @michaelgilligan61133]

Posted by Peter Greene on 25/01/2021 22:28:52:

Michael Gilligan wrote

you must not place any marking or sign that may misconstrue the meaning or form of the UKCA marking to third parties.

——-

With my best internet wannabe lawyer hat on … seems to me there's a lot of legal difference between saying "though shalt not copy our mark" and "thou shalt not use anything similar". Is this really any better than the CE mark situation?

.

It’s probably not much better, Peter … but I think it shows recognition of the ‘loophole’ that I was alluding to:

The design of the CE mark is explicit, and the widespread belief is that some are ‘passing off’ a similar [but clearly different] marking, BUT are reasonably safe in so doing because it said to have a different meaning … and therefore it cannot be a fake.

The UK wording may strengthen our position … Only time, and case-law will tell.

MichaelG.

[Michael GilliganParticipant @michaelgilligan61133]

Posted by Peter Greene on 25/01/2021 22:28:52:

…

(Michael, in order to finally get this to post I had to manually retype the quote. Quoting it in the normal fashion or even cutting/pasting it wouldn't work …. I assume you cut/pasted from the source? maybe there's some hidden character in it)

Edited By Peter Greene on 25/01/2021 22:32:40

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No idea, I’m afraid, Peter

… Yes, I copied and pasted from the .gov web-page … but I don’t understand why that would prevent you from quoting my post.

MichaelG.

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Edit: __ I have just tried quoting my own post, and encountered the same problem that you did 

Edited By Michael Gilligan on 25/01/2021 23:01:15

[Nick WheelerParticipant @nickwheeler]

Posted by noel shelley on 25/01/2021 18:50:08:

funny that SOD should mention skoda bolt quality we had the same trouble with zetor tractors ! noel

Not much different from 70's BL cars, which were assembled from fasteners made from an engineering grade of cheese. A French one, as they were soft and weren't usable for long

[Michael GilliganParticipant @michaelgilligan61133]

I’ve located the problem, Peter … but my HTML skills are insufficient to explain it:

.

.

MichaelG.

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Ref. __ https://www.w3schools.com/tags/tag_ul.asp

Edited By Michael Gilligan on 25/01/2021 23:37:14

[Anonymous]

Posted by Michael Gilligan on 25/01/2021 22:56:43:

Edit: __ I have just tried quoting my own post, and encountered the same problem that you did

Weird eh?

[SillyOldDufferModerator @sillyoldduffer]

Posted by Michael Gilligan on 25/01/2021 22:56:43:

Posted by Peter Greene on 25/01/2021 22:28:52:

…

(Michael, in order to finally get this to post I had to manually retype the quote. Quoting it in the normal fashion or even cutting/pasting it wouldn't work …. I assume you cut/pasted from the source? maybe there's some hidden character in it)

…

No idea, I’m afraid, Peter

… Yes, I copied and pasted from the .gov web-page … but I don’t understand why that would prevent you from quoting my post.

…

Edit: __ I have just tried quoting my own post, and encountered the same problem that you did

I can't make it work either. I looked at Michael's post with Firefox's Inspector facility and, although there are a few oddities, nothing stands outs as different from any other post. When 'Add Post' is pressed, the browser sends a form consisting of what the user typed and any tick box settings (Send me email notifications, and Bookmark this thread), plus hidden info, viz the thread number, an 'insert post' command, and something called 'w' set to 7, purpose unknown. It all looks normal.

So does the network chat triggered by pressing 'Add Post':

• My browser calls the server.
• Server acknowledges. We are connected
• Browser asks for encryption
• Server replies, yes but says change the Cipher
• Browser acknowledges and makes the change successfully
• Browser sends form to server
• Server acknowledges receipt
• Server replies to browser with an error message suggesting it can't find the thread the post is being added too.
• Browser acknowleges

I guess something non-obvious is wrong with the form, but I can't see what it is. Maybe w=7, because the post number sent to the server is correct. Never seen anything like this before on the forum so it's probably just a glitch.

Dave

[Anonymous]

Posted by SillyOldDuffer on 26/01/2021 11:59:04

:…..it's probably just a glitch.

Er …. yeah

It's the only time I've ever encountered it too.

Michael, thanks for the hard work.

[Neil WyattModerator @neilwyatt]

Posted by SillyOldDuffer on 25/01/2021 12:22:19:

Here's what to look out for. Perhaps there should be a prize for spotting the first genuine one and another for identifying the first fake!

The UK Government website here explains what has to be done to implement UKCA.

Dave

I wonder when people will start moaning that they have to pay twice for documenting both CE and UKCA marking on their products?

<edit> err… three times as they will need a UKNI marking if they want to sell in Northern Ireland as well.

Edited By Neil Wyatt on 26/01/2021 18:37:12

[Robert Atkinson 2Participant @robertatkinson2]

Posted by Neil Wyatt on 26/01/2021 18:33:02:

Posted by SillyOldDuffer on 25/01/2021 12:22:19:

Here's what to look out for. Perhaps there should be a prize for spotting the first genuine one and another for identifying the first fake!

The UK Government website here explains what has to be done to implement UKCA.

Dave

I wonder when people will start moaning that they have to pay twice for documenting both CE and UKCA marking on their products?

<edit> err… three times as they will need a UKNI marking if they want to sell in Northern Ireland as well.

Edited By Neil Wyatt on 26/01/2021 18:37:12

If they moan they do not understand, there is nothing to stop you using one technical file for multple approvals. The only exception is those items that have to be assessed by a Notified Body, they wll have to pay for two of those.

There is no separate marking for NI they will stay with the CE mark.

The real issue is that many smaller suppliers will just stop selling into the UK because of this, customs paperwork and if online, the e-commerce act making them pay UK VAT.

[SillyOldDufferModerator @sillyoldduffer]

Posted by Robert Atkinson 2 on 26/01/2021 22:04:55:

Posted by Neil Wyatt on 26/01/2021 18:33:02:

Posted by SillyOldDuffer on 25/01/2021 12:22:19:

There is no separate marking for NI they will stay with the CE mark.

…

Read all about it on the UK government website…

Dave

[Robert Atkinson 2Participant @robertatkinson2]

Posted by SillyOldDuffer on 26/01/2021 22:21:43:

Posted by Robert Atkinson 2 on 26/01/2021 22:04:55:

Posted by Neil Wyatt on 26/01/2021 18:33:02:

Posted by SillyOldDuffer on 25/01/2021 12:22:19:

There is no separate marking for NI they will stay with the CE mark.

…

Read all about it on the UK government website…

Dave

As I said " The only exception is those items that have to be assessed by a Notified Body,"

The UKNI is only for Items requiring NB 3rd party approval who use a UK NB. CE marking is still accepted if you use an EU NB.

Robert.

Edited By Robert Atkinson 2 on 27/01/2021 07:53:29

[Neil WyattModerator @neilwyatt]

Posted by Robert Atkinson 2 on 26/01/2021 22:04:55:

If they moan they do not understand, there is nothing to stop you using one technical file for multple approvals. The only exception is those items that have to be assessed by a Notified Body, they wll have to pay for two of those.

There is no separate marking for NI they will stay with the CE mark.

There are "goods covered by national rules (non-harmonised)" i.e. never subject to specific EU regulations just UK ones. I've read the guidance twice and I'm still not understanding how CE will apply to them from 2022, but assume that guidance will come from the EU not from the UK.

It may be that NI goods can be marked UKNI as well as CE non the same evidence, but again that isn't clear to me.

[Author]

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