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Importing goods required a CE mark?
Post 1 of 12

Hi,

I'm about to import a light reflector in to the UK and want to make sure that I am doing everything by the book. The reflector housing incorporates a bulb holder that is CE certified, does anyone know if this is sufficient enough for me to supply this product within the EU without going to jail for negligence if anything was to go wrong? 

I would really appreciate some help from any CE guru's or anyone else that has had experience of this out there.

 

Many thanks,

Mark Brickstock

24 Jun 2008 11:53
Post 2 of 12
Quoting from [Silaris]:

Hi,

I'm about to import a light reflector in to the UK and want to make sure that I am doing everything by the book. The reflector housing incorporates a bulb holder that is CE certified, does anyone know if this is sufficient enough for me to supply this product within the EU without going to jail for negligence if anything was to go wrong? 

I would really appreciate some help from any CE guru's or anyone else that has had experience of this out there.

 

Many thanks,

Mark Brickstock



Hi Mark

CE in certification made within China Lab's may not all be accepted for our UK custom checks, if the Lab testing is small and unknown or hard to communicate to verify the certification before release of the goods into UK.

Not sure what your product really is, if you want to send me a clear pic and more details + spec sheet, i can check more, but remember light bulbs imported to UK would need a verified CE and Rohs, and most factoroies making these products in China would have these two certifications, as for your product if the Rohs were to be needed the cost to get this may cause a problem!

25 Jun 2008 16:42
Post 3 of 12
Quoting from [Strongman Products]:

Quoting from [Silaris]:

Hi,

I'm about to import a light reflector in to the UK and want to make sure that I am doing everything by the book. The reflector housing incorporates a bulb holder that is CE certified, does anyone know if this is sufficient enough for me to supply this product within the EU without going to jail for negligence if anything was to go wrong? 

I would really appreciate some help from any CE guru's or anyone else that has had experience of this out there.

 

Many thanks,

Mark Brickstock

Hi Mark

CE in certification made within China Lab's may not all be accepted for our UK custom checks, if the Lab testing is small and unknown or hard to communicate to verify the certification before release of the goods into UK.

Not sure what your product really is, if you want to send me a clear pic and more details + spec sheet, i can check more, but remember light bulbs imported to UK would need a verified CE and Rohs, and most factoroies making these products in China would have these two certifications, as for your product if the Rohs were to be needed the cost to get this may cause a problem!





Many thanks for your reply. Please see a picture of the product I wish to import by visiting this link: http://www.hydrolab.co.uk/light_hood.jpg . As you will see from the picture, the part that has been tested and CE certified is the bulb holder within the lighting hood (inside left). My supplier has forwarded me a copy of the certificate of conformity which was issued by a authorised test house based in Berlin, Germany. We will only be importing the light hood with bulb holder as you see it in the picture. My quesion in short is... will I get away with importing the light hood if only the bulb holder has the CE mark?
26 Jun 2008 02:34
Post 4 of 12
Quoting from [Silaris]:



Mark,

The Holder like you said has the certification now, but your hood don't, by adding the hood to the product means you need to test the complete product, if you send to UK and customs want to check, the CE report sheets would show it's only the holder not ther hood which has been tested and you would be in trouble.

You need to test the complete product to import that to UK, and SGS is the only test lab we use.

You would know that the hood plays a large part, saftey is very important, and the holder may have a max rating of 150W but the hood just 100W max, if holder you can sell without a cable, but the compete light you might sell with and the cable needs to be tested with the complete light for CE, this type of product would need many warning labels and clear instruction manual with fitting, where it can be used!, make sure the fuse rating is right for the cable.

26 Jun 2008 04:46
Post 5 of 12

Hi again,

It turns out after further investigation my supplier has a certificate for the product as a whole (bulb holder, hood and cable).

So now that my supplier can supply me with this, what would I need to make available to customs if this product was to be stopped during an import inspection?

Once again, many thanks in advance.

Mark

27 Jun 2008 02:54
Post 6 of 12
Mark,

There is way too much involved in this one to get a simple answer. Here is what you do.... Get them to send you an actual sample MARKED AS A SAMPLE!!!!! (ie not for commercial resale).

After that you get the thing tested by your local guys. There may well be too much lead or a couple of other metals that have strict new controls in the EU (eg lead). I can't tell from the photo what metal that may be. You also may be required to meet some "flame" type rules as well since this is going to have a light bulb involved which means heat (what type of outer coating does this product have for example that may react to heat or even fail under heat conditions)

Go to the rohs website and do a lot of reading then contact your local office. These guys realise that the whole compliance thing is confusing as heck and they ARE pretty dang good about helping you out.

rohs in the UK:

http://www.rohs.gov.uk/Default.aspx

You need to allow for the fact that the company in China possibly knows less about ROHS and CE and other EU rules than you do......... and taking the advice of someone on these boards as gospel is NOT a smart idea.!

 


27 Jun 2008 16:19
Post 7 of 12
I have some experience with a very similar product that I suspect may be used for the same purpose that your item is being used for.

First thing to consider is that the CE certification may not be relevant for you. On many occasions the factory does not do the testing but their customer does the testing. In that case the factory can certainly say that the item has passed CE testing and conforms with CE standards, but you will have no access to the original documentation as the factory does not own the rights to this.

Your main concern will be that should you start selling this product in your market and the question arise as to whether it is certified or not then you could run into trouble.

I agree with Foow that you should do the testing yourself to be sure.

For the testing here in Australia you need to provide three samples and the total costs for testing that type of product are going to be around AUD4-5,000. I believe that CE certification is cheaper to get especially if you get it done in China so check with SGS or some other inspection company and find out.

Then you will know the product meets your requirements and you will hold the documentation to ensure that you do not meet any legal problems in future.
28 Jun 2008 03:47
Post 8 of 12
Quoting from [Silaris]:

Hi again,

It turns out after further investigation my supplier has a certificate for the product as a whole (bulb holder, hood and cable).

So now that my supplier can supply me with this, what would I need to make available to customs if this product was to be stopped during an import inspection?

Once again, many thanks in advance.

Mark






Mark

First ask the factory you need the CE copy and the complete test report for this item, then let's see who has tested it and when!! you can then verify the certification, only when you see the report would you understand more.

Sometimes you have to have products tested in other countries, this depends on the product, and the importer, with many products i would deal with i like to make some working test myself, if you have the sample with you in UK, you are welcome to meet me and i can put it under our test machine, i can give you the report and apply test stickers to your item to show it's been check, and yes my test machine has the test certificate and i have C&G in testing and Managment, i can test these ....

  • Full visual inspection
  • Insulation test
  • Earth continuity test
  • Earth leakage test

If you have any problem with the cable and the earth on the hood we can find out with these tests, and you need to make check that the product can stay on for long term use too,  CE certificates from China can be given too easy with complete testing, and the fuse must be there to protect the cable and not the product!! so the correct rated fuse used is very important, UK spec is 3amp and 13amp only,, and 5 amp is not in the UK specs for appliances.

28 Jun 2008 17:11
Post 9 of 12
The only accurate advice so far in this topic is where Foow said "taking the advice of someone on these boards as gospel is NOT a smart idea!" (and you can now include me in that if you like).  
 
Mark, in answer to your specific question about positioning of the CE label – the lettering must be at least 5mm high and affixed to the product or its data plate. The main requirement of the EU Directive is that it be legible, visible and indelible. You don't need a second label for the hood as the CE label applies to the product as a whole. Just use your common sense in positioning the label - on the data plate or data panel on your product is the best location.  
 
"Visible" doesn't necessarily mean on the outside of the product. For the mobile phones we export to the EU, we place the CE label under the phone battery so it's visible only when the battery is removed. Get a copy of EU's "CE Marking Directive" if you want the full rules but you hardly need it if you stick the CE label on your data plate.    
 
In relation to CE conformity, you said "My supplier has forwarded me a copy of the certificate of conformity which was issued by an authorised test house based in Berlin".
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If Strongman and Egernia knew anything about CE conformity, they would have realised the critical significance of that statement and not got into all sorts of misleading and confusing crap.
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more ...
 
29 Jun 2008 17:48
Post 10 of 12
[cond from above]
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I take strong exception to amateurs passing themselves off as professionals to give CE conformity advice when your ability to stay out of prison and to avoid nasty fines depends on accurate advice.
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Egernia's Chinese labs would land you in more strife than you want to know about as they are not recognised in the EU for CE conformity purposes and what's the point of even raising it after you said a German lab  had already issued the certificate? Indeed, there is not one lab in China which is a "Notified Body" under EU law. 

 

Strongman's electrical C&G certificate is obtained in a one day course costing about 50 quid or the whole blown thing in 5 days for 500 quid. These are usually obtained by people with no prior electrical qualifications - to check workplace appliances for mainly Insulation and Earth integrity which any person with half a brain can learn to do in a day.
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Anyone who knows anything about CE conformity, knows that Germany is the epicentre for CE electrical conformity testing. I near fell off my chair laughing at the thought of a lowly C&G certificate guy like Strongman from the UK checking the CE conformity test results of a German test laboratory which are staffed by some of the world's best qualified electrical engineers.  [em2]
 

more ...
29 Jun 2008 17:49
Post 11 of 12
Mark, even though the Berlin lab you mentioned is likely what is called in EU law a "Notified Body" (meaning that the CE conformity is 100% ok) your posts tell me that your supplier has no "Authorised Representative" in EU.
 
That is serious as it means that you, the importer, must hold the manufacturer's Declaration of Conformity and its Technical File for the product for inspection by any EU member state on demand. You must hold this CE conformity file before you import and you must continue to hold it until up to 5 years after you last sell the product in EU.
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UK Customs and positioning of the CE label on your product is the least of your due diligence problem. The problem really starts after you start selling the product in any EU country - where the authorities can bang on your door at any time (up to 5 years after you sell the last product) demanding to see the technical files which prove CE conformity and which by EU law you must hold (if the manufacturer does not have an Authorised Rep holding them in EU as seems to be the case with your manufacturer).     
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I'll post more about this for you when I get a few moments because the holding of these files by you in EU is fundamental to your stated purpose of staying out of prison.  
29 Jun 2008 20:03
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