CE Mark

Subject: CE Mark
From: Alexander Von_obert <avobert -at- TWH -dot- MSN -dot- SUB -dot- ORG>
Date: Thu, 5 Dec 1996 12:05:00 +0100

Hello Tim,

* Antwort auf eine Nachricht von Tim Altom an All am 05.12.96

[Sorry, quite long and a quite difficut topic for me -
please do not judge me by my English :-)]

TA> A client has just engaged us to produce a set of machinery
TA> manuals for a
TA> product that he hopes to market to the European community.

In EU terms you are producing a part of a product.

TA> To that end, he's
TA> seeking the CE mark, a prerequisite to doing business in the
TA> modern European world.

The CE mark means that the product conforms to all European standards that are
valid for that product.

TA> I have the documentation standards, but the CE mark is
TA> too new for me
TA> to corral a sample from most people around here.

It does not mean very much to documentation in most fields. As long as I do
not know the kind of product I cannot say much more.

TA> Has anybody out there done
TA> a CE-qualified project? And if so, could you write to me
TA> (probably
TA> off-line...it's probably not of general interest) and describe
TA> it?

Naturally I was involved in EU conformity :-)

The European Union (former European Community) wishes to create a single market
for most of Europe. About every European country had its own standards. A
single market can only develop if the same standards are valid all over the
market - especially about security aspects.

One of the first actions was to define a single power line voltage all over
Europe: Most of continental Europe used 220 V, Great Britain had 240 V. Now
coutries use 230 V.

The European Commission issues "directives" for diferent groups of products.
One of the first was the "directive on toys". In 1988 the "directive on
machinery" was issued, last modified in 1993. A year ago or so I posted parts
of that directive in this mailing list.

These directives are no laws. They must be converted to national laws by the
governments of all countries of the European Community. The governments are
even liable if they do not pass appropriate legislation in time. E.g. the
German government must pay damages to those who lost money due to travel
agency bankruptcies: There is a EU directive for a insurance that was not
converted to German law until the end of 1992.

The EU directives only define the general framework. The national laws must be
embedded into the national legislation which is quite diverse all over Europe.
The British system should be quite familiar to those of you in the US. The
German one is quite different with much less influence of judges and more
detailed laws.

The laws formed according to EU directives refer to the "state of the art" as
defined e.g. in industrial standards (as ANSI in the US or DIN here in
Germany). But these are national standards that existed before these
directives and therefore they are replaced by "harmonized" European standards.

As soon as there are harmonized standards, they must be adopted. Products
conforming to all relevant EU standards may be marked with the EC mark. From a
date given by the EU diectives only products marked with the EC signs may be
distributed within the EU.

The other side: As long as there are no harmonized standards, no CE sign is
needed. E.g. there is a directive about house building products (German name:
Bauproduktenrichtlinie), but no harmonized standards. Therefore no house
building product (brick, window...) need to be signed with a CE mark.

Read: A German manufacturer develops a product conforming to Germany laws
according to EU directives and harmonized industrial standards. Without any
further investigation he may distribute the product all over the EU.

The EC sign only means "this product conforms to all relevant standards and
the manufacturer can prove it to the authorities". The EC sign is no quality
sign or anything else.

The EC sign must be attached by the manufacturer according to EU legislation.
This means:

- If a product is manufactured within the EU, the real manufacturer
is resposible.

- If a product is imported into the EU, the first institution within the
EU is resposible.

- If someone is the only recognizable manufacturer (e.g. distributers
with their own trade marks), he is responsible.

But back to Tim's question: The manufacturer as above is resposible for the CE
mark. He must specify any modifications needed. The most important aspect
about the manuals is that in many cases a translation for every country where
the product will be distributed (not necessarily sold) is needed.

But it is a generally bad idea to simply translate an U.S. manual for use in
Europe. From time to time I proved a few cultural differences in this list and
if you keep all your warnings in there, no one will dare to use such a
dangerous product :-)

Greetings from Germany,

Alexander von Obert, Urbanstr. 2, 90480 Nuernberg, Germany
Free-lance Technical Writer (electronics, software)
Voice +49-911-403903, Fax +49-911-403904, BBS +49-911-403905 (FIDO 2:2490/1719)

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