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Posted By holmezy
Hi All,
I thought that I understood the requirements for CE marking, but since I've been informed that the civil engineering people now have CE marks on plasterboards, cements etc, I'm not so sure!
We import a trolley, single axle with pnuematic rubber tyres, that has a clamping device that, when the workpiec is positioned, the weight of the workpiec closes the clamp sides and grips it. Used to move slabs and stone worktops about. No power involved. They are certified to a weight limit and are well built. We import from outside the EU and then sell it to our customers in the UK , does it need a CE mark, and if so why?
My initial thoughts are that its not required, but would like to be sure, or proved wrong
Thanks
Holmezy
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Posted By ChrisLFAnderson
Holmezy,
Yes
Because it is sourced from outside the "market" you are the one who carries the bucket. You are "placing on the market" within the EC work equipment which is also "machinery".
The Supply of Machinery (Safety) Regulations 1992 (SI 1992 3073) apply.
"Machinery" is defined (at Reg 4) therein as having at least one moving part, which fits your description.
Reg. 22 requires that the person who places the machinery on the market must make a "declaration of conformity" document to accompany each item, which confirms that all the necessary H&S requirements in the appendices to the Regs have been addressed. The document is usually signed by the CEO of the organization. The existence of this statement is confirmed on the machinery itself by means of the CE mark.
Hope this helps,
Chris
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Posted By RichardJ
To be machinery under SOM (Supply of Machinery)Regs it also needs a power source.For Excluded machinery see schedule 5 of Regs.
Excluded - 'Machinery whose only power source is directly applied manual effort unless it is a machine used for lifting and lowering loads'.
If there is only applied manual effort and you are not lifting or lowering the load, e.g only clamping it, then SOM regs are probably not applicable?
FYI. A lot of construction products are CE marked under the Construction Products Regs 1991 (nothing to do with SOM Regs).
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Posted By holmezy
Chris,Richard,
Thanks for the info. I was just about to give my understanding of the need for a power source or lifting etc, but Richard beat me to it!
I read Chris's reponse and then looked at the stapler on my desk. Its got moving parts, requires a force but is not powered, and it doesnt have a CE mark.
I think the CE marking system is either grossly misunderstood, ignored or abused. There are allsorts of stuff that have little CE stickers on them that, in my understanding (or lack of!), dont require CE marking. Also lots of folks think that the CE mark is equivilant to the old kitemark system and denotes that the machine is safe.
Thanks for the help.
Holmezy
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Posted By Adam Hammerton
For future reference, the European Commission have a handy web site (http://ec.europa.eu/enterprise/newapproach/standardization/harmstds/reflist.html) which lists all the EU directives requiring CE marking of materials and equipment, etc.
Adam
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