CE conformance expe...
 

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CE conformance experts please gather

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Would a device that is axle-mounted for the purpose of speed detection and odometry come under the machinery directive? The device is manufactured by my company but is mounted on third party equipment. Without the external power to rotate the axle and initiate speed detection, our product is mechanically passive.

The internal electronics conform to EMC and LVD. Would anything further be required on the CE side of things?

TiA

 
Posted : 05/10/2022 1:24 pm
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This is quite a good guide...

Would depend on "Defined in 2006/42/ EC article 1(k)"

 
Posted : 05/10/2022 6:54 pm
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Been a year or so since I spent any time on this, but I don't think it will come under the machinery directive.

You need to maintain a construction/design file explaining what you've done and provide a user guide (in the language you're selling into).

You need to find the harmonised standards for your product and ensure you meet them. This, by definition, means you meet the requirements of CE. The hard part is finding which harmonised standards apply.

Don't forget if you sell in the UK you'll need to conform to UKCA as well (or instead if you're only selling in the UK, unless you're selling in NI, when you need CE and UKCA.)

Not surprisingly, UKCA requirements are the same as CE!

 
Posted : 05/10/2022 7:43 pm
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Ooh, interesting and hijack (sorry)

We want to buy a piece of lab equipment from a US supplier. They have tested / certificated to IECEE CB and are saying that allows them to also claim CE compliance. Is that right, or something extra needed. Our compliance dept will not approve purchase as it stands, but would allow purchase under a non-conformance / concession but that requires quite a bit more work on our science team's side.

 
Posted : 05/10/2022 7:58 pm
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theotherjonv,

I am not an expert! But it depends on the product. Somethings can be self-certified, others, like ATEX stuff, needs to be tested by an approved external test house. So the supplier may not be able to just say 'it's CE compliant', without something to back it up.

If they can self certify, they need to provide a declaration of conformance to you. I don't know whether IECEE CB is equivalent to CE for the product you want to buy, I'd be asking the suppier why they think it is.

 
Posted : 05/10/2022 8:37 pm
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Good flowchart from @footflaps

From a CE/ PUWER course a while back, a machine (as far as CE Machinery Directive goes) is something that does a job of work, where work has the Physics definition i.e. work = force x distance. So a force is applied, and something moves as a result. The Machinery Directive wouldn't apply to the OPs example, but other legislation might - see flowchart!

 
Posted : 06/10/2022 12:06 pm

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