4 Replies Latest reply on Dec 2, 2009 10:37 AM by gnevison

    What if RoHS becomes a CE mark directive?


      Module A from 768/2008 is the self-declaration procedure required for CE directives. This regulation affects the format of all new CE directives and so RoHS will be the first but it is likely that all CE directives will eventually adopt this "harmonised" approach.


      The main requirements are:Module A is the requirements placed on the manufacturer of products to ensure that these comply.

      • Paragraph 1 states that internal product control and product testing is used
      • Paragraph 2 lists the required contents of technical documentation which includes a product description, a list of standards used, results of calculations and examinations and any test results
      • Paragraph 3 requires the manufacturer to adopt procedures to ensure compliance and to monitor compliance
      • Paragraph 4 requires product labelling and a declaration of conformity.


      Clearly distributors are not manufacturers but this regulation specifies the obligations of distributors which are to ensure that products comply, that the correct documentation is available (DoC, use instructions in a suitable language etc) and that the product is marked correctly. Where a distributor supplies a product under their own trade mark, they have the responsibilities of the manufacturer.



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