Selling non CE Marked Equipment

[The Soup Dragon]

We have been asked to be sales agent for a company from Turkey selling an electrical piece of equipment. It is currently not CE marked. I am not sure what the issues are surrounding this. I also read that CE marking has now been replaced in the UK ( not NI) with a new UKCA mark instead.

Any advice appreciated

 

[fisicx]

That’s correct. It’s now UKCA and you can’t sell it without certification.

 

[The Soup Dragon]

Isn't it possible to self certify?

 

[DontAsk]

Isn't it possible to self certify?

Yes, if you know what you are doing.

 

[fisicx]

This is a good place to start:

Placing UKCA or CE marked products on the market in Great Britain

What you need to do to comply with regulations which govern manufactured products placed on the market in Great Britain.

www.gov.uk

 

[The Soup Dragon]

Thanks Guys. Sounds like the risk of self certifying is if something goes wrong your head could on the block!

 

[DontAsk]

Thanks Guys. Sounds like the risk of self certifying is if something goes wrong your head could on the block!

For the EMC regs, for example the maximum fine is, or was last time I looked, £5000. Trading standards are probably too busy/understaffed to deal with things like this. Plenty of apocryphal evidence that complaints are often pushed back to the complainer to, e.g., upgrade their TV aerial and cabling to prevent interference, rather than chasing alleged interference source

It really depends on the nature of the equipment you are importing. If it could go wrong and expose someone to a harmful dose of X-rays then it's a completely different ball game.

 

[Kitsunae]

Thanks Guys. Sounds like the risk of self certifying is if something goes wrong your head could on the block!

Are you going to be the Authorised Representative as well? Because yes, that’s the point, to have someone local with their head on the block!

Just to clarify though - the manufacturer always self-certifies, unless you’re doing a special case like medical. The question is whether you get testing done first or can rely on existing certificates before doing so. Also make sure that you apply with all relevant regs - more than one can apply depending on what the product is. The regs will refer to technical standards that are the default method of compliance. Those are (crazily) not available for free in public.

 

[paulears]

I’ve never found a CE marked switch mode power supply that should have passed! Some so bad as to be destructive on the operation of other local devices. Wall wart style power supplies all have a stamp. That is all it is, I am convinced, a stamp. If they don’t kill you, or are very clearly likely to kill you, trading standards aren’t staffed to deal with it.

realistically, you will be the one liable, so you could do your own EET test on each item (EET replacing PAT) if done properly, the like an MOT, it would state that at that time of testing, it had no faults evident. I’ve no idea how a court would see this, but a safety test with evidence would show you at least cared, rather than a few dubious certificates in a filing cabinet.

 

[Kitsunae]

Testing of each item might not be a bad idea. You still need the certificates though - that’s the easiest thing for TS to check and declare non-compliance on.

 

[paulears]

For anyone with an electrical/electronic viewpoint on safety - if you have some time to kill, and a perhaps slightly odd sense of humour - look on youtube for the huge series of videos from Big Clive. https://www.youtube.com/c/Bigclive

He is a very clever man - slightly eccentric in the nicest way, but deadly serious about safety issues. People send him products, and he sources his own and pulls them apart to discover how safe they really are and has uncovered many CE marked products actually lethal, or very, very close if they get dropped or misused. Small things like the 5V going to your computer or phone passing within 1mm of the full 240V mains on a circuit board not very well designed making even a tiny bend or warp to the PCB make your phone live - really crazy stuff like this. He also deliberately mis-uses products to do unsusual things - like discovering ones that can remove the alcohol from flavoured drinks which he then changes - good for the booze lovers.

One of his most crazy devices tested was a baby bath heater, that essentiall passes the mains through the water to heat it - meaning if you put it in the bath, with the baby .................

He also likes to test things like lithium battery accessories to assess how much damage they can cause if you accidentally do silly things. You need to be a little technical to appreciate the irony of some of the devices, but it puts things like CE marking into an easy to understand perspective - and why the system was so deeply flawed.

 

[Kitsunae]

One of his most crazy devices tested was a baby bath heater, that essentiall passes the mains through the water to heat it - meaning if you put it in the bath, with the baby .................

I always thought the lack of power sockets in UK bathrooms was overkill, but perhaps not...

 

[fisicx]

Been watching Big Clive for years. Much more informative than most of the conspiracy junk YouTube thinks I’m interested in.