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Getting CE marking on new motor
3

Getting CE marking on new motor

Getting CE marking on new motor

(OP)
We produce a handheld electric tool for sale in Europe, and it carries the CE marking.  We have found a new source for the armature and the field in China, but their products are not CE marked.  Must they be for inclusion into my product (I think so), and can anyone share their experience on the difficulty/ease of getting a Chinese supplier to self declare conformance of thier armature and field?  Many thanks.

RE: Getting CE marking on new motor

As far as I know, the producer of the final product is the one that shall declare conformity. It is your task to make sure that the complete tool is compliant and you shall apply the CE mark. There are several consultant companies available in the US to help you do the job. But you are also allowed to do it yourself.

I had much more trouble getting a UL mark on a product than I ever had with the CE mark.

BTW: I once heard that Chinese export products always have a CE mark - the Chinese thought that it means "Chinese Export"

RE: Getting CE marking on new motor

(OP)
Thank you for your input (and humor).  You are right about the final product needing to have conformity declared, but the ease with which that can be accomplished is at issue.  I can simply use an EN spec for tools like mine to comply with the machinery directive and low voltage directive so long as the "critical components" carry the CE mark.  I think these components are things like power cord, switch, and motor.  Otherwise I will need to demonstrate compliance with any number of specifications.  Or am I misunderstanding this?

RE: Getting CE marking on new motor

I cannot say for sure, really.

If your tool meets all insulation rules and the power cord etc is OK then I think that the armature and stator is more a question of reliability and quality - but not a question of safety.

The field and armature has to be hipot tested. Either by you or a testing house. It would, of course, be a lot easier if the manufacturer puts the CE mark on the parts. But regarding the amount of presence and checking needed by you (remember that the CE mark still is not very well understood in China) I think that you should do it on your side of the Pacific.

RE: Getting CE marking on new motor

CE approving for your handheld tool more complex vs. standard procedure. Of course CE certified parts (I hope that China has Standard Institute or something like that) may help. I'll suggest you to contact at R.H.Welch Jr., well-known motor designer and expert(rhwelch@stthomas.edu).

RE: Getting CE marking on new motor

To CE mark something with a motor, you usually also have to demonstrate compliance with the EMC Directive, usually by testing to (other) standards, not the safety standards that you use for the Machinery and Low Voltage Directives.

RE: Getting CE marking on new motor

Hello codys

CE marking applies to the finished product and is a declaration that the product complies with all relevant standards. This includes safety, low voltage directive, EMC etc. It is your responsibility to ensure that the product does comply to all requirements. There is no requirement that I am aware of for individual items to have individual complience requirements, but if you deem it necessary, then so beit.
Obviously, cords switches etc must comply with the appropriate standards, but that is a different issue from having individual CE marks.
In the case of UL and CSA, individual components must be approved before they can be included in the final product.
Be careful with any certification from China, there are some good and some bad certificates and it is very hard to differentiate. I heard of testing labs at a trade show that quoted a price for CE certification based on them doing the testing, and another price (double) for no testing!!
A company that I was doing some work with had a local plant and a p[lant in China. The Chinese wanted to mark their products with CE, UL and CSA on the grounds that the NZ product carrried these marks. They did not believe that they had to get their product tested and approved. The Chinese authority told them that the NZ operation just had to modify the certificates and add the Chinese operation and products.
Ultimately, it is your responsibility to ensure compliance, if you choose to accept a test certificate, you must be able to justify your decision.

Best regards,

Mark Empson
http://www.lmphotonics.com

RE: Getting CE marking on new motor

(OP)
Thank you all for your great tips.!  I consider this question well answered.

RE: Getting CE marking on new motor

(OP)
Hi blacksea,

You suggested I R.H.Welch Jr., a well-known motor designer and expert.  The email you gave is not drawing response.  Could you suggest an alternative? (is there any way to private message here??)  Thank you!

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