http://www.hse.gov.uk/wo...claration-conformity.htm

if you cant get the above link, go to HSE, and type in Declaration of Conformity..........

which I'm sure you already looked at

Could be taken that where it says 'or the manufacturer's representative' could be taken as an independent?

Its a fairly cut and dried issue.

Whoever places the equipment 'on the market' (i.e. who supplies/sells the machine) within the EU is responsible for CE marking and associated paperwork i.e. Declaration of Conformity.

It is illegal to supply unless CE marked.

Unless the machine is in one of the excluded categories? Doubt it from how described so far.

Thanks JJ.

Unfortunately, I was only consulted after the machine was imported.

Ian

Ian,

If your company has brought it into the UK (and thus EEC), your company take on all the responsibilities of the manufacturer.

If relevant, you could contact a notified body and pay them to undertake one of the three options that may be applicable.



MACHINERY DIRECTIVE - INDEPENDENT SOURCES OF ADVICE
http://webarchive.nation...v.uk/files/file54513.pdf

MACHINERY --Guidance notes on the UK Regulations SEPTEMBER 2009:-
https://www.gov.uk/gover...notes-uk-regulations.pdf

Machinery manufacturers: legal responsibilities
https://www.gov.uk/machi...d-their-responsibilities
http://www.cemarkit.co.uk/





Notified Body

A Notified Body (NB) is a legal entity or person who has been appointed by the Government and notified to the European Commission for the purposes of conformity assessment. In the UK, NBs are assessed by UKAS, the United Kingdom Accreditation Service on an annual basis and the status can be removed at any time.

Routes to compliance
There are 3 routes to compliance for equipment falling under the scope of the Machinery Directive.

1.Self Assessment.

This route is applicable for all types of equipment not included in Annex 4 of the Directive and for Annex 4 equipment which are wholly covered by harmonised standards. Under this route, the responsible person assesses the equipment against the Essential Health and Safety Requirements of the Directive, produces a technical file, produces a declaration of conformity or incorporation as appropriate and affixes the CE Marking.

2 .EC Type Examination.

This route applies to Annex 4 equipment that is not wholly covered by a harmonised standard or the manufacturer has not chosen to use the self assessment route. To use this route, the responsible person has the equipment assessed by a Notified Body who will issue a Type Examination certificate if they are satisfied that the equipment complies.

3 .Full quality assurance.

This route is for Annex 4 equipment which is manufactured using a full quality control system which has been assessed by a Notified Body. The NB issues the technical documentation and CE Marking.

I have a related issue here with some equipment we have purchased from a 3rd party supplier in the UK, acting on behalf of a manufacturer in Vietnam. They have not been able to supply us with a CE certificate, but the manufacturers in Vietnam have sent us a copy of a Certificate of Inspection (CI) which they believe is a valid alternative. I have not heard of such a certificate, does any one know is there any viable international alternative to the CE marking/certification? I certainly have never come across this before.

Fairground

Sounds like the equipment you have, is illegal from the paperwork point of view.

The 3rd party supplier is responsible for the CE making, by the look of it - if they have purchased the equipment from Vietnam for onward sale in the UK/EU.

Jj thank you for putting me right, sounds like Ian should have ensured CE marking was applied prior to purchase. Bit of a minefield now then.

quote=fairground42]I have a related issue here with some equipment we have purchased from a 3rd party supplier in the UK, acting on behalf of a manufacturer in Vietnam. They have not been able to supply us with a CE certificate, but the manufacturers in Vietnam have sent us a copy of a Certificate of Inspection (CI) which they believe is a valid alternative. I have not heard of such a certificate, does any one know is there any viable international alternative to the CE marking/certification? I certainly have never come across this before.

Finally

This is about UK Regulations, based on an EU Directive, and it applies to the whole of the EEA.

Fairground and JJ Proudbody - Annex B of the BIS guidance states that equipment specifically for ue in fairgrounds and/or amusement parks are excluded from the Regulations.

Ian

JJ Proudbody had already indicated at post #6 that the equipment might not need CE marking, if the equipment came into one of the excluded categories.

Thank you all for your input.

The machine was uplifted by the company selling it, and had a conformity engineer look at it.

Apparently it is unlikely to pass a CE test, so has been returned to the USA.

Ian