CE marking

[Erfolg]

I have just gone through one of my model files.

 

What is interesting, relating to documents, and items

 

a) Only one of my ESC's has a CE marking, a Keda.

b) My Kontronics does not, but is in accordance with 89/336/ewg, etc.

c) My Weston 35 OrangeRx  has no CE marking, made in Europe.

d) None of motors has CE marking including Kontronics, HET, Tornado except

e) An old 480 Jarama brushed motor.

 

I have in excess of 14 ESC's and similar numbers of motors.

 

Most were UK purchases at least 90%.

 

Just found my Ripmax Xtra has a CE marking on the package.

 

Certainly not uniformly applied it would seem.

Edited By Erfolg on 21/09/2010 15:48:00

[Biggles' Elder Brother - Moderator]

Tony, things get modified all the time. In fact when we test an item for EMC the sample we are given to test is usually a preproduction prototype. All we can do is report what the emmissions were from the device we were given and if there are below the limit then state that that particular item satisfies the Directive.

 

Now the manufacturer takes it back. Often makes changes prior to production. Does he have it tested it again. Well its entirely up to him. If he is fairly sure his changes will not have altered the emissions characteristics he might choose not to. But obviously he then takes a risk in putting on the CE mark. A very small risk maybe - but a risk non-the-less. If he is not sure - then he might ask us to test a production sample just to be sure.

 

The product then goes into service and after 12 months he designs some small modifications - maybe he can no longer get a certain bought in component so he has to replace it with an equivalent. Does he ask for a retest now? Again its entirely up to him. He might decide the mod is so small it makes no difference - so he just carries on using the mark. On the other hand he might decide to "play safe" and have a new test done. Its his choice.

 

Notice its common for us to only see a single sample of a product and only once.

 

So you can see its a very dynamic picture. The manufacturer does all this because he is going to sell this item as his business. As a hobbist if you modify something you are not required to consider the implications to CE marking were your own use is concerned because you are not selling the item as a business. Even if you do eventually sell the item on - its a private sale and so is not covered.

 

The one I don't know is if you were to trade it in for a new model and then the dealer who bought it from you decided to sell it through his dealership. I think he has a problem. It would be like Stephen Grigg buying an extensively modified car and selling it second hand through his business - he is responsible for the car satisfying the road vehicle usage regs as the seller. If it doesn't - i.e. its no longer road legal - the emphasis would be on him to tell any buyer that. And I guess for that reason Stephen would, like any other second hand car dealer - be very reluctant to buy a heavily modified vehicle. I guess that's what auctions and 'caveat emptor' is all about!

 

BEB

Edited By Biggles' Elder Brother on 21/09/2010 19:36:11

[Biggles' Elder Brother - Moderator]

Erfolg,

 

to answer your questions (without another long post which will simply repeat much I have already said more than once!) I can do no better than refer you to this and when you've read that introduction to here which is the website of the official body responsible for overseeing the CE mark in the UK.

 

Once again I emphasis that I am not here to defend the system - only trying to explain how it works

 

BEB

[Tony Smith 7]

Posted by Biggles' Elder Brother on 21/09/2010 19:34:31:

 

The one I don't know is if you were to trade it in for a new model and then the dealer who bought it from you decided to sell it through his dealership.

 

That happens all the time if you consider all the items that are CE marked, rather than just electronics.   Sticking to boats, there are plenty of dealers selling second hand boats from stock (as opposed to by brokerage), and most of those are going to have been modified.  Some modifications are self evidently not relevant, but lets say they fitted an echo sounder.  That requires a hole through the hull below the waterline.  Done wrong it will sink the boat.   Fit a gas or Diesel heater wrong and you could blow up the boat.

 

But as I say, you never hear scare stories like circulate here.   It really seems to me that CE must only be important at time of new sale, and completely irrelevant to later use.   I'll certainly not worry about changing a connector inside my transmitter any more than I would worry about replacing a seacock to my preferred type, or drilling the mast for a new fitting.

 

Actually come to think about it, it must be not even at point of new sale - plenty of dealers will fit accessories (= modification from CE tested form) at the time of sale.

[Biggles' Elder Brother - Moderator]

You're quite possibly correct Tony and it does only cover sale of  "new" items. Another problem if it did cover second hand items would be if the Directive is updates which set of standards appliy - the old or the new?

 

As I say I don't know much about the retail side of things my team normally only gets involved that the prototype and early product EMC testing. There might be some info on the second hand sales from a business stuff on the second of the two links I posted above - i.e. the UK gov site.

 

One thing to keep in mind is that the purpose of the legislation is to try to ensure that products entering the market are "safe" and meet certain minimum requirements in regard of how they might interfere with other kit. Its likely that the commission feel they can basically achive this by simply controlling the entry of "new" goods on the theory that anything second hand must have passed originally. We have to keep in mind that this legislation covers a huge range of goods of which those likely to be modified in some way would only form a very small percentage overall. So perhaps they are just pragmatic about thise cases?

 

BEB

[Erfolg]

I have been reading the "The Guide to the Implementation of  Directives Based on the New Approach and the Global Approach. This is EU document which all national CE regulations are required to be based.

 

It is interesting at many levels, remembering that legislation is at national level, although adhere to the provisions.

 

The document states that are "two objectives".

 

1) Create a EU wide harmonisation of standards, where national standards which act as barriers to free trade are removed.

2) That citizens are provided with consumer rights, relative to the areas affected by the standards.

 

The CE mark is the vehicle to meet these objectives, within a limited range.

 

There are probably others, a second reading will be necessary to find them, these are the headline statements.

 

The CE mark within the document requires two features to be valid

 

a) Certificates of conformity

b) QA documents.

 

A number of the points raised, as issues, are recognised, and at least partially addressed.

 

1) The CE mark offers protection to the consumer to a 10 year max. This is in respect as to compensation for a defective product. ie design.

2) If the importer or manufacturer of the product cannot be identified, all those who have retailed the product become liable.

3) In applying the CE mark, that organisation becomes responsible for proving that the item meet the CE requirements. Any one can place a CE mark on a product, recognising what it takes to be valid. There are challenge processes.

 

What is clear that the document is written from the perspective of selling the goods.

 

In the area  where no CE mark is present, but a CE mark is required for sale, that in itself is not an issue, other you cannot sell it. But the product but must be compliant with national regulations (which are to harmonised across the EU). This is addressed from a prototyping and modified equipment perspective.

 

When it refers to claims, it in this respect, it is with respect to claims on the basis of consumer protection ie deficient design.

 

So if you modify your transmitter, which could be a repair and this is the cause of some claim due to a deficiency. As was previously the case, you cannot point a finger at the original supplier or manufacturer. Remember the emphasis is with respect to consumer rights.  The item must still be compliant.

 

It must be emphasised, that the document is not legislation. But is the device for the formulation of national legislation, (so how UK regulations are written is up to our government).

 

There are reference to the World Trade Organisation and Inter country reciprocity and the legal requirement not to legislate as to form trade barrier.

 

I suspect that this is the beginning of a process, which sees some of the obvious shortcomings within the CE concept addressed. At the same time there is the ever present legal obligation not to discriminate against non-EU goods( that is products not commissioned by EU manufacturers to contractors located outside the EU) in line with WTO agreements.

 

I will be reading this again, as I am not yet sure, I have taken on board other than a fraction of the requirements.

 

I would recommended this as the "Book of the Week", but, but, in my case I have some wing ribs to cut.

 

 

 

[Biggles' Elder Brother - Moderator]

One thing you will find Erfolg is that various goods and requirements are listed as modules 'a' to 'h'. The "rules" are ifferent for different modules. For example only modules 'b' to 'h' require independent certification and QA. All our stuff, receivers and transmitters etc., come under module 'a' for EMC and Low Voltage. Hence no independent test needed - and this stuff is "self-certified"..

 

BEB

[Erfolg]

Biggles

 

I did see that (was it appendix 1?), I wanted to stick to the main principles.

 

I purposely wanted to avoid the detail, as it distracts from what is intended and generally starts the canards of how to interpret sentence's, phrases and paragraphs.

 

Of course UK implementation is another matter, and variously been described, famously as Gold Plated, others as what is required, with a Government agenda attached.

[Biggles' Elder Brother - Moderator]

Posted by Erfolg on 23/09/2010 20:10:36:

 

Of course UK implementation is another matter, and variously been described, famously as Gold Plated, others as what is required, with a Government agenda attached.

 Ah, how true!

[Erfolg]

Well!

 

I have had a small HK parcel arrived. Not with the 2.4 Fasst Rx. This is is a separate parcel of a motor and a batch of servo, extension and Y leads. I do this to stay within the £18 import limit and if the customs do not believe it. Just like investing in shares, I can afford to right it off, rather than argue as bureaucracy is always right.

 

The significant thing is this, the instruction sheet for the motor come s with a CE marking, plus what looks like an FC and a RoHS markings.

 

Any guesses what the other marks are?

 

I have also have been told the CE mark, can be confused with CE, which is Chinese Export. So I will have to carefully study the physical requirements for the EU, CE marking.

 

 

[Steve Hargreaves - Moderator]

Aaarrgghhhh...this is never ending!!!

 

Interestingly I bought a back up HDD for my Mums computer over the weekend & reading the manual (after I had installed it obviously...I'm a man!!) it had a paragraph about CE marking which said (& I paraphrase) that the equipment was CE marked & met the EU approvals, blah, blah but (& this is the bit I really like) when used in a domestic environment may cause radio interference & it is up to the user to sort this out!!!

 

Amazing!!

 

I should have kept hold of the manual...I try & get hold of it when I next visit my parents & copy down exactly what it said

[Biggles' Elder Brother - Moderator]

Hi Erfolg,

 

RoHS - the Restriction of the Use of Certain Hazardous Substances in Electrical and Electronic Equipment Regulations 2008 is a relatively new EU Directive aimed at controlling levels of Lead, Cadium. Mercury etc in electrical products offered for sale in the EU. It is the legislation that effectively stops the industrial use of leaded solder.

 

Don't know FC -. Are you sure its not FCC? FCC is the USA equivalent of our EMC requirements.

 

Finally, yes you do have to tbe very careful to distinguish between "CE - meaning China Export" and "CE as in the EU mark." There is a slight difference in the form and the spacing of the letters. At least one of the links I gave before shows you the difference.

 

BEB 

[Biggles' Elder Brother - Moderator]

Posted by Steve Hargreaves on 27/09/2010 14:13:51:

Aaarrgghhhh...this is never ending!!!

 

 

Do you mind Steve!

 

At least two of my staff earn their salary purely on the basis of this stuff! Its a good little earner. "Never ending indeed"! You'll be complaining about Her Majesty's Revenue and Customs and other august and upstanding bodies next.

 

BEB

[Erfolg]

Biggles

 

You have pressed the go button again. My mother is embroiled with the Revenue. I have seen her paperwork, being an ex accountant (having a maths degree that did not count in the UK, but some thought she may be able to add up), she has 10 years of segregated finance files, with correspondence. It is obvious that the revenue are totally incompetent, or are playing dumb, to bamboozle money out of tax payers. Anyway she has copied the correspondence to Cameron as an example of incompetence, and seeking assistance.

 

Anyway back to the leaflet, it could be the FCC mark. It actually has the "C"'s within each other.  

 

To some extent I can see the benefit of the CE, but then again, I have doubts. It feels like a poor system. It lacks that, I will do this (from a manufacturer's perspective) because it helps me sell, type feel. More of I need to comply with some regs, because of the financial penalties, rather than the standards being robust and useful. Plus the vagueness from a consumers perspective of what it specifically underwrites, rather than providing a vague it complies with some regs or other.

[Steve Hargreaves - Moderator]

I think the problem stems from the ignorance & dull wittedness of those who govern us....I think they see Europe ie the EU as this big box & everything that comes into it must meet this & that regulation or it doesn't get in. Then we grateful citizens can go to the shops provided for us & pay top dollar for nice shiny trinkets to keep us amused, secure in the knowledge that our Dear Leaders have ensured our safety. This I am sure is how they saw it

 

What they didn't forsee was that people might not play by the rules & (shock horror) think for themselves & look elsewhere for their goods (& admittedly the internet has had a huge hand in this) effectively importing them directly.

 

Think about it.....if all you could buy is what was on the LMS shelves then CE marking wouldn't be a problem because it would have been "officially" imported & "approved"

[Tim Mackey]

A pleasant update on this matter - I started it off by referring to the cheapy little spektrum clone receivers from Hobby City - having just looked again at some un-opened ones, I am relieved to see they do in fact carrry the CE marking on the "packaging".

Yippee.

Now, just my luck, BEB is gonna tell me thats the China Export mark instead

 

[Chris Bott - Moderator]

Packaging? You got packaging?  There was none on my 6Ch ones.

[Erfolg]

Tim

 

CE mark or CE mark, I personally do not worry to much.

 

My interpretation is that using the Rx is not illegal in itself without the CE mark. What would be illegal is using equipment that does not comp;y with national regulations. The Real CE mark provides confidence that the equipment is compliant.

 

Without the CE mark it would illegal to sell the item in the UK.

 

Reading the enabling document by the EU, it is very clear, that a principle aim is removing Internal Barriers to trade and the harmonisation of  national regulations. A component of this strategy is a single set  of standards.

 

I do have faith that made in China, can signify quality, after all all my 5 Futaba 617 Rxs are made in China.

 

 

 

 

[Martin Harris - Moderator]

Posted by Tim Mackey - Administrator on 07/10/2010 11:35:38:

A pleasant update on this matter - I started it off by referring to the cheapy little spektrum clone receivers from Hobby City - having just looked again at some un-opened ones, I am relieved to see they do in fact carrry the CE marking on the "packaging".

Yippee.

Now, just my luck, BEB is gonna tell me thats the China Export mark instead

 

 I don't know what BEB will say but it doesn't appear to conform with the CE mark which is based on segments of 2 adjacent overlapping circles.

 

Edited By Martin Harris on 07/10/2010 12:47:20

Edited By Martin Harris on 07/10/2010 12:50:03

[Biggles' Elder Brother - Moderator]

The image is a bit small to be sure - but I suspect its a "China Export" mark. The reason is that the letters look too close together to be a EU CE Mark logo! But as I say - difficult to be sure.

 

Take a look at the bottom of this page which shows the correct proportions for the CE mark and displays the "China Export" mark for comparison. Then you can make your own decision.

 

Erfolg is quite correct - as we have discussed at length - owning and using a non-CE marked receiver is not in and of itself an offence.

 

BEB

 

PS - Plead ignorance! If ever challenged just point to the letters "CE" and say "I understood that to be a CE Mark". It would be an interesting test case - we'll all come and watch!

Edited By Biggles' Elder Brother on 07/10/2010 13:23:19

[Bert]

European Commission's response to China Export Mark question.

 

 

Bert

Edited By Bert on 07/10/2010 13:24:27

[Erfolg]

Bert

 

As you would expect, the EU response to the CE (China Export) mark is that sale of such goods within the EU would be a breach. A breach occurs whether in compliance with EU regs or not, in that it does not carry a valid EU, CE mark. It has to be emphasised that it is sales within the EU that is the issue. Not the use of compliant equipment.

 

The rest is with respect to registration of the CE mark, so as to make enforcement easier. The other issue addressed is the level of enforcement within the EU, and the achievement of enforcement.

 

There are hints of attaching a unique marker to CE markings, to enable tracing.

 

What is not mentioned is the difficulties/discussions  that the EU has with respect to the WTO (World Trade Organisation) with respect to ensuring that the CE mark is not a covert mechanism of discriminating against imports.

 

In principle the CE mark can only be seen as a good idea, the devil is often in the detail and the ensuing bureaucracy.

 

The important aspect with respect to the EU is that there are twin objectives, of consumer protection (deficient design and compensation to the user, which is time limited) and harmonisation of standards.

[Erfolg]

Biggles

 

I have just seen your response.

 

As long as Timbo does not sell the goods and it is compliant with National (which should be EU regulations) there are no issues (not at present).

 

I think it is interesting that the EU recognises the issue of traceability. I suspect that the officials always were aware of this gaping deficiency, but took the view "slowly, slowly, catchy monkey".

 

In the long run I am fearful of the direction the CE mark will take. Keeping many civil servants in employment, at the same time increasing the cost of goods within the EU. Yet the stated aims are to be applauded.

[Biggles' Elder Brother - Moderator]

You're absolutely correct Erfolg.

 

Interesting response that Bert. One wonders though just how much it is driven by "diplomatic" considerations!

 

The way they say they are not "aware" - is thought provoking. Thinking about it they could not admit to being "aware" even if they were, as it would be tantamount to accusing Chinese manufacturers of deliberately seeking to mislead European consummers! And that would not be good for EU/China relations!

 

BEB

[Erfolg]

Many years ago now, well that is how it seems, a different person even, I sat on two international bodies framing legislation, as part of the working parties developing the content.

 

It became quite apparent, that the full time officials, actually wrote the documents/legislation. There were unseen governmental interventions by various nations, again unseen, sometimes diametrically opposed, revealed by changing emphasis and complexion of the documents.

 

It was apparent if you stopped and observed, although instructed that national interests and issues, could not and would not be incorporated, this was all done behind the scenes. The real power was the full time officials and governmental interventions. The rest was window dressing and proof reading.

 

So I am sure that politics is the real driver, yet it should not be forgotten, that within the EU, there will differing positions and objectives. Some valuing "free trade", others "political union", some valuing the "transfer of wealth for universal prosperity" etc.

 

I could guess what the position of the previous government would be, the present one, I wonder. At present it is any ones guess where the CE mark ends up, I suspect this is the begging of a long journey, or it could be reined in by some interests.

 

I am some what taken aback by our own attitudes.