On 2006-11-20 09:41:36 +0000, John Beardmore said:

In message , Andy Hall writes
On 2006-11-20 08:38:41 +0000, AJH said:

Always assuming that there *is* a set of relevant standards.

Otherwise, the manufacturer can quite legitimately declare CE based on
some of the components.

There are a few classes of product, such as certain machine tools,
where the manufacturer is *required* to have certification from an
independent test house. However, for the most part, manufacturers and
importers are not required to do that - they can simply keep records
of their own tests if any.

Added to this, the teeth behind it are pathetic. In the UK, Trading
Standards are responsible for policing and bringing prosecutions in
respect of CE labelling. Very few have been brought and the penalty
is max. a £5000 fine or in extreme cases a 6 month holiday at one of
E2R's residences.
The risk is very low and even if caught, £5k can come out of the pencil budget.

In short, plenty of scope for the less than honest to abuse a system.



The only comment I would add to that, is if you are a small scale
producer just starting out, producing in very small volume, this is
another set of bureaucracy you really don't need !


I'm the last person to be in favour of any form of bureaucracy, but
OTOH, I have the nous to appropriately research for any major purchase
I would make.

The original intent of CE labelling was good, in principle, in that it
was meant to facilitate free movement of goods around the EU and to
prevent individual countries from erecting or maintaining trade
barriers through the use of their own standards for products that were
easy for their indigenous manufacturers to meet but difficult for
others to meet or have tested.

The idea of self certification was to reduce bureaucracy. In the
early 90s, I suppose that people didn't foresee the huge volumes of
product that would be dumped into the EU originating from countries
where cultural standards of honesty are not the same (let's say it that
way).

Hence we have a situation where the less than honest can get away with
it, and the honest large manufacturer can afford it.

It is difficult for a small manufacturer starting to meet standards and
bear the cost of testing, I agree.
On the other side, consumers do need to have some form of protection
and a metre stick by which to judge products that they buy.
Another solution could be trade associations. The problem here is that
so many have become discredited (e.g. FENSA) because of their lack of
willingness to pursue customer issues against members.

Either way, it's a cost of doing business. If consumers want a level
of protection, and I think most do, then there is a cost associated
with it that they will ultimately and quite reasonably have to pay.