Technical Guidance Note 11

TOPIC: Product versus Component

ISSUE: 2

REVISION DATE: 27.1.98

PREVIOUS REVISION DATE: 17.2.95

BACKGROUND: There is considerable confusion concerning the overlap between a product (which should be CE marked) and a component (which should not be CE marked).

PROBLEM: Are items such as motors, PLCs and VME boards to be regarded as relevant apparatus as defined by regulation 7 (2) which should then be CE marked; or should they be regarded as components in which case they should not be CE marked.

GUIDELINES: Products with a direct function such as motors, PLCs etc should be regarded as components and should not be CE marked, except when they are sold directly to the final user. As a result, if a manufacturer can demonstrate that the component is only for use by OE manufacturers, then it does not have to satisfy the requirements of the EMC directive.

SUPPORTING INFORMATION:

This issue is more fully covered in the Commission’s Guidance to the EMC Directive.

Disclaimer
No responsibility or liability can be accepted by the EMC Test Laboratories Association or any of its officers or members for the contents, specifications and/or advice referred to or contained in this Technical Memorandum and/or action taken as a result of information contained in this Technical Memorandum. Note that:
1. The Association is not by supplying this Technical Memorandum providing professional advice or guidance to any specific party on any specific matter and no legal relationship is created by the provision of this Technical Memorandum.
2. Parties should take specific advice when dealing with specific situations and consult their own professional advisors in this regard.
3. Members are free to deviate from the above guidelines where they think it appropriate, unworkable, or not commercially viable. Under these circumstances, the EMCTLA Secretariat should be informed of the reasons for the deviation so that the matter can be reviewed.

© 1998 EMCTLA