Had a question about non CE marked electrical items and I don't know the answer however I am sure someone out there does. Our company is looking to use a piece of kit that comes from China and is not CE marked. Its electrical and produces a small amount of heat. (We would eventually be looking to use it in up to 1000 locations) We have asked the supplier for their documentation in order to show the kit is safe. If we were to get an electrician to look the item over and they deem it safe to use and we complete a risk assessment, could we use it? If something went wrong and there was an incident involving the kit where would be stand with it not being CE marked? We are looking to use it - not supply it. Any advice would be gratefully appreciated :-)

The EC Consumer Safety reporting system "RAPEX" has lots of listings for Chinese manufactured electrical items found to be in breach of various safety directives and not only related to the way they had been put together but also for their materials of manufacture. Even if the manufacturer produces "paperwork" I would be very careful and validate the authenticity of the claims - from personal experience an iPad charging plug supplied from a major on-line retailer carried various attestations and test house markings but digging just a little deeper (reading the test house report product description) the item as certified had a removable fuse whilst the item supplied was moulded to give the appearance of having a fuse holder. If there are absolutely no viable CE marked alternatives you could consider having the item assessed by an accredited test house such as Intertek (other providers are available) - an electrician would not necessarily consider all requirements under the General Product Safety Directive, Low Voltage Directive, Restriction of Hazardous Substances (RoHS) in electrical and electronic equipment etc.

I remember several years ago being warned about a CE mark that meant China Export. The mark looked suspiciously like the CE mark we all know and the similaritywas no doubt down to chance. So I’d wonder if it did have the initials CE if indeed it was a CE mark we all think it is rather than the China Export mark. Things might have changed though and I’m sure if they have someone here will know. I’d be interested to know anyway.

By the description given, I'm not so sure the item would be classified as a 'machine'. The definition is something like ' a series of linked components, of which at least one moves' See the HSE web page for definitions http://www.hse.gov.uk/wo...directive-definition.htm

Comprehensive information on CE Marking---How a product complies with EU safety, health and environmental requirements, and how to place a CE marking on your product https://www.gov.uk/guidance/ce-marking

A few quick points. As has already been said, beware Chinese Export mark. The CE mark has a specific geometrical shape and relationship under the CE marking directive. So strictly speaking, even if, the product meets the requirements, if the mark is applied incorrectly, then it isn't CE marked. (Yes I am pedantic) Next, if it doesn't come under the Machinery directive, which (generally, ish) if it doesn't have moving parts it may well not do, it will almost certainly come under the Low Voltage Directive. There are things that are legitimate that don't need CE marking a BS1363 plug/socket for example are a national standard, thus no CE marking. However, almost (again generally ish) all other electrical equipment does. If you are importing this equipment into the EU and placing it on the market, which you are, even if it's for your own use, because this is placing on the market, then you will be deemed to be the manufacturer (in simple terms) so it will be down to you to CE mark it, which, can be done. PM if you wish.

KMS, if you are importing this item into the European Economic Area for use in connection with a business, then you are responsible for its conformity to all the applicable European Directives, including CE Marking. I suggest you find a Notified Body, not just an electrician, to advise on which Directives are applicable and whether the item meets the requirements, and if so you can draw up a Declaration of Conformity and affix the CE Marking. You might like to let your company directors know that failure to comply with the CE Marking requirements leaves them liable to a fine of up to £215k and imprisonment for up to 5 years (although I don't think that has happened yet!).

Now stillp, I didn't realise that the China Export mark was a myth I must confess! Yes EMC is another, but, from the description of the product, unless it's using a semiconductor controller, perhaps an SSR temp controller, for example then whilst it would need to comply a resistive element with a thermal switch or two, and an on off control would almost certainly comply! ;) Nice to see you back by the way. I need to chat to you off forum about a few things. Give me a week or two though to put my ideas together.

I remember from training that the china equivalent mark was CCC in an oval, but we were told not to trust this and that the importer was the one responsible for ensuring there was a CE mark before importing it into the EU. Therefore if manufacturer didn't do it then the importer had to. I think the previous china mark before ccc had "C" and "E" in it, but not sure. The placing on the market idea seems to be a problem for some. It was explained to us that when the item becomes an asset of the company, should the company be sold or sold off if it goes belly up, then this item is on the market. So it effectively is on the market the moment it becomes an asset, whether there is an intention to sell it or not. Seemed reasonable to me. Chris

Yes but no When the item is made, it then instantly becomes an asset. Surly if you bought a non CE marked piece of equipment and sat it on a shelf ( so an asset), even though it has not been used it still exists and so is on the market, surly you would not have to wait for it to be used, before it falls foul. Agree with the in house manufacture still being on the market. Chris

quote=Ian Bell2]Why would you buy an item of equipment, CE marked or not, if it is going to sit on a shelf? Seems like a poor financial decision!!

Many Thanks everyone. I may PM a few of you separately. Regards KMS

Chris, I suppose the instruction to not trust it was a good one, even if a little off-beam.