Requirements for CE marking a component to go into an assembly (PED)

[ScottK]

noboost4you and I have been having a lengthy discussion via PM on CE marking to the PED (97/23/EC) and something came up that neither of us are very clear on at this point....

Let's say I'm an American manufacturer of a pressure accessory (not a safety device).
I have a customer who incorporates my pressure accessory into an assembly.
That customer is also an American manufacturer, but sells the assembly to the EU.
What is my responsibility under the PED?

Other information: If I was to sell the accessory directly to the EU I would at most be Category I, Module A (CE mark, self assessment). Most likely it would SEP - no CE mark required.

[Al Rosen]

Originally Posted by ScottK

noboost4you and I have been having a lengthy discussion via PM on CE marking to the PED (97/23/EC) and something came up that neither of us are very clear on at this point....

Let's say I'm an American manufacturer of a pressure accessory (not a safety device).
I have a customer who incorporates my pressure accessory into an assembly.
That customer is also an American manufacturer, but sells the assembly to the EU.
What is my responsibility under the PED?

Other information: If I was to sell the accessory directly to the EU I would at most be Category I, Module A (CE mark, self assessment). Most likely it would SEP - no CE mark required.

It think that it's the responsibility of the person who places the product on the market. You have no control over where your product is used once it is sold and out of your control. I'm basing this on the other directives that I have had experience with since I am not involved with the PED and on common sense, although common sense does not always prevail when government and regulations are involved.

[noboost4you]

Exactly. Once we sell it, it is out of our control. The Notified Body whom I've been in contact with has been trying to tell me that because of the end product, we need to certify our product to the highest degree. His reasoning is that even though it is considered a "pressure accessory" at first, once it is installed into a system containing piping and vessels, it should then be considered a vessel. I have yet to read anything in the PED stating exactly that.