Labeling of Equipment

Further to my recent post, I thought a little clarification was required, the following has been taken from the Electrical Equipment (Safety) Regulations 2016 (EESR). Please use the link to obtain a copy completely free of charge https://www.legislation.gov.uk/uksi/2016/1101/contents the Low Voltage Directive can be found at https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32014L0035 again for free.

Labelling of electrical equipment 8.—(1) Before placing electrical equipment on the market, a manufacturer must—(a) ensure that it bears a type, batch or serial number or other element allowing its identification; and (b) ensure that it is marked with— i) the name, registered trade name or registered trade mark of the manufacturer; and (ii) a single postal address at which the manufacturer can be contacted. (2) Where it is not possible for information specified in 1(a) or (b) to be indicated on the electrical equipment, the manufacturer must ensure that the information is indicated on its packaging or in a document accompanying the electrical equipment. (3) The contact details referred to in paragraph (1)(b) must be in a language easily understood by end-users and market surveillance authorities. (4) The information referred to

CE marking 39.—(1) The CE marking must be affixed visibly, legibly and indelibly to the electrical equipment or to its data plate. (2) Where it is not possible or warranted, on account of the nature of the electrical equipment, to affix the CE marking in accordance with paragraph (1), the CE marking must be affixed to— (a) the packaging; and (b) the accompanying documents.

Although I have only used the Electrical Equipment (Safety) Regulations, you will find similar requirements in the Machinery and EMC Regulations and Directives to name but a few. The way in which the extracts are to be applied are 'literally' as in dictionary definitions. The Department of Trade and Industry produced a good example of this, in their Department of Trade and Industry document for the Electrical Equipment (Safety) Regulations 1994;

 The term 'electrical equipment' is not defined in the Low Voltage Directive and should therefore be given the ordinary dictionary meaning. 'Electrical' is defined as 'operated by means of electricity' or 'of or pertaining to electricity'. 'Equipment' is defined as 'apparatus' which is in turn defined as 'the things collectively necessary for the performance of some activity of function'. An item is only subject to the requirements of the Regulations if it is 'electrical equipment' as so defined.

From that it can be taken that if we have two contactors/relays and some controls we have now made a new item of electrical equipment that will be subject to the CE Marking requirements. Then if we go back to 'CE Marking section 39' from the EESR extract we have the term 'visible'. The only reason I pick on this term is due to the number of times I have found the labels on the inside of panels and equipment and the term 'Hidden' springs to mind. The find of the hidden label is often accompanied with the comment that the regulations and standards are all open to interpretation?

From the two links provided you will find that not following the legislation as intended, producing the CE mark as required and producing documentation as detailed will initially be treated as a non-compliance. for a non-compliance you will usually have a period of time to correct the departure if, however, the equipment is unsafe they detail other remedies that are available, with drawing equipment etc.

Not to go too far from my initial post, I have seen what Industrial Engraving Services Ltd have produced with respect to the correctly scaled CE mark and from my engraved business cards are more than happy to endorse them. They are open but as their name suggests they do not produce any retail products and are purely B2B and can be contacted via email [email protected] or phone 01446 700480.

If you are producing equipment as per the recent Government request for ventilators one of the main points they made was that the equipment had to comply with legislation. Labeling as can be seen is very much part of these requirements.

If you need any guidance of further information on CE Marking all company details are above.

Stay Safe and legal from all at CE Marking Ltd.