CE Marking for LVD (Low Voltage Directive) Health and Beauty Products

[controlz]

Hey guys,

I really hope you can help as I've contacted our local body and even they were unable to provide me with a direct answer!

In summary, we import a range of Low Voltage products from China in the Health and Beauty category. All of the products we import conform to their appropriate directive and have legitimate CE marking from the factory. We are supplied with Declaration's of Conformity along with Technical Files and any other relevant documentation in order to prove this certification to be true.

We make no changes to the product whatsoever apart from have the factory print our logo onto the top. Based on my research, I understand we become the 'manufacturer' from this alone...

What I want to know is whether we are therefore required to compile our OWN technical files and declaration of conformity, or providing we have done our respective Due Diligence on the factory, and are in possession of all respective CE documentation, this is acceptable? (It would seem ridiculous to compile our own documents as they would be carbon copies).

Many Thanks!

 

[occounty]

Re: CE Marking for LVD (Low Voltage Directive)

What is your targeted market for these products?

Based on that,there can be couple of options to go with.

 

[controlz]

Re: CE Marking for LVD (Low Voltage Directive)

What is your targeted market for these products?

Based on that,there can be couple of options to go with.

We are based in the UK so this is our primary market, but we will be looking to expand further afield in the near future. (France, Germany etc)

 

[occounty]

In your case, you are termed as "Own Brand Labeller
(also referred to as Private Labeller)" and you are doing "Own Brand Labeling CE marking".

In CE world, you become,Own Brand Labeller (OBL) and original manufacturer becomes Original Equipment Manufacturer (OEM).

OBL and OEM, both bear joint responsibility for CE mark. Please refer to attached documents, for more details.It talks about the contract that should be in place between OBL and OEM.

Hope that helps.

 

[controlz]

Would the products require an authorised representative in the EU, or is that unnecessary since I'm based in the EU and would become the 'virtual manufacturer' due to our branding?

Also, would it be necessary to draft up a DoC in my company's name (which would in essence be a copy of their's), or providing I have their documentation, a basic OBL/OEM contract between us is perfectly acceptable?

 

[CharlieUK]

Few things:

- the product has a CE mark and a Technical File, which is great - but are they correct - have all applicable Directives been considered? Have appropriate Harmonised Standard been considered and applied?

CE marking is an "ongoing" process - do you have sufficient confidence in the Chinese factory to continue making the product without changes, or at least without changes that you are unaware of?

Basically - if your name is on it, you are the legal manufacturer and you'll be the one pursued if there are problems. You might well be able to pursue your supplier, but you're in the EU, the enforcement authorities are in the EU and the OEM is miles away.

I don't wish to sound negative or disparaging, but these are real risks you should be aware of.

My advice would be to get a professional review done of the product and Technical File.

Charlie