Reducing CE marking cost using manufacturer test reports

#1
We are going to source Bluetooth controlled led lights/sensors from a manufacturer in China. Can we use manufacturer CE mark technical file documents as it is with new EC declaration under our company and brand name and model numbers only? Or do we have to have new test reports under our brand and model numbers first and then have EC declaration under our brand and model numbers?

if we have to follow the retesting path, is there any way to reduce test cost for us since the manufacturer has done the same testing under their brand and model numbers?

appreciate your advice.
 
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JoshuaFroud

Involved In Discussions
#2
Hi Isrunk,

Are you planning on using the parts sourced from China with its own CE mark as part of another thing? or are you going to re-label and re-sell them?
 

CharlieUK

Quite Involved in Discussions
#4
When you stick your BRAND and MODEL number on the product, you become the "Manufacturer" and are fully responsible for compliance.
How you demonstrate that compliance, and satisfy yourself that products going through volume manufacture, are compliant is up to you.
You don't have to get stuff "re-tested", but you do need to be able to show how your stuff is compliant.
As a minimum, you get copies of all reports for safety, EMC, RF spectrum and EMF and DoC for RoHS
You may decide to do some audit testing for EMC and RoHS to build confidence in what you have been supplied
 
#5
When you stick your BRAND and MODEL number on the product, you become the "Manufacturer" and are fully responsible for compliance.
How you demonstrate that compliance, and satisfy yourself that products going through volume manufacture, are compliant is up to you.
You don't have to get stuff "re-tested", but you do need to be able to show how your stuff is compliant.
As a minimum, you get copies of all reports for safety, EMC, RF spectrum and EMF and DoC for RoHS
You may decide to do some audit testing for EMC and RoHS to build confidence in what you have been supplied
what is the proof that we need to show for the relationship between the manufacturer's and our model numbers? All manufacturer test reports are issued under their brand and model numbers. How can we use those test reports as it is when we draft new EC declaration under our brand and model numbers?
 

CharlieUK

Quite Involved in Discussions
#6
what is the proof that we need to show for the relationship between the manufacturer's and our model numbers? All manufacturer test reports are issued under their brand and model numbers. How can we use those test reports as it is when we draft new EC declaration under our brand and model numbers?
You won't find that defined anywhere, but things you should do / look at include:
- Get the manufacturer to confirm what the differences between the products are (even if it's just the label)
- get hold of some samples of the other unit and compare them visually to the one they make for you
- Check that they have applied the correct standards to the product - a starting point would be to check lists of Harmonised Standards
- obtain copies of all test reports for the original product - check the photographs show the actual product and check that the internal photographs are also correct
- Document that you are happy with the approach that you have taken - you are trying to do some "due diligence" and only you as the new manufacturer can determine when you are happy with the evidence that you have.
 
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