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CE marking

CE marking

(OP)
For one of the Package , purchased from Europe, CE marking is a Must as per European Directives and vendor has agreed to provide the same. But vendor has said that the Individual itmes say manually operated valves, that are installed inside the package need not be certified for CE marking since the whole package is CE marked. Actually vendor had not purchased the valves with CE marking .

Here is the transcript the Vendor is giving

Quote

Ball Valve CE / PED Markings

- Our valve distributor is having issues getting ball valves that are CE marked. If we can produce the MTR’s & Certificate of Compliance for the ball valves and a PED certificate for the factory that produced the valves would that be sufficient?

Looking through Directive 97/23/EC (Article 3, Section 1.3a and Section 3; and Annex II, Table 7) and our Piping Class AS20N it looks like all of our piping falls into the SEP Category. This would mean that our valves and piping do not need to be CE marked. Can you please confirm this? (calculations we did are given below)

System Design Pressure (PS): 13.5 barg

PED Fluid Group: 2

Max Pipe Size: DN 50

PS * DN = 675

Because PS * DN is less than 1000 our piping is in the SEP Category (Article 3, Section 3) and does not need to be CE marked.

Unquote:

But the Inspector is challenging that CE marking has to be done for each and every item inside the package. Which argument is correct?


RE: CE marking

For one of the Package , purchased from Europe, CE marking is a Must as per European Directives. No, not according to the law when the package is exported. That is important to understand.

When your vendor confirmed that he will supply CE marking for all the components and now he does not, ask him why. The fact that the valves do not have CE marking leads to the assumption that they are not bought from a European manufacturer. So, perhaps he wanted to save some money and now he tells you that the valves do not need the CE marking. Just a possibility.

RE: CE marking

As I recall from my years with PED, individual items need not be CE marked in a piping system falling into SEP category. Assemblies must not carry CE marking if SEP, which leads me to believe that there are other directives applicable to this particular one, if all the pressure equipment falls under Article 3 Paragraph 3 of the PED.

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