Relation of VDE mark with CE certification

[Harsh]

Hello Everyone,

I do work in a laboratory device (Centrifuge, Stirrer, etc.) manufacturing firm. One question is raised every time when there is a development of a new power cord supplier. We do get the CE certificate for DC power adaptors but not for the standalone sold power cords.

When I ask them to provide a CE certificate they provide me the VDE certificate. In the VDE certificate, there is mention of individual components like PVC cable, plug with earthing contact - non-rewirable moulded. Is it valid? As the standards which I can see in those certificates are mostly DIN & VDE standards & for CE compliance EN standards are mandatory.

According to my knowledge & research, I concluded that VDE is a quality mark that might be useful in proving CE compliance but it's not the standalone proof of compliance without EC declaration. Also, the VDE certification should be done for the finished product rather than the individual components. A CE certificate is also valid only if it has been declared on the basis of the appropriate testing according to the product category, applicable directives & their harmonized standards. CE compliance of individual components doesn't provide the surety of compliance of the final product.

When I researched a bit more for the VDE mark I noticed one thing VDE does provide CE declaration with the testing. For ready reference, I am attaching a screenshot of the same.



Is there something that I am still missing? If so then do let me know.

Thanks in advance.

 

[Ronen E]

The only CE marking directive that seems applicable to standalone power cords (if they are placed standalone on the EU market) is the Low Voltage Directive.

This Directive shall apply to electrical equipment designed for use with a voltage rating of between 50 and 1 000 V for alternating current and between 75 and 1 500 V for direct current, other than the equipment and phenomena listed in Annex II.

Not all products must have CE marking. It is compulsory only for most of the products covered by the New Approach Directives. It is forbidden to affix CE marking to other products.

CE marking

 

[Harsh]

Thank you Mr. Ronen for the info. LVD seems applicable which is why I am confused that a standalone VDE certificate would suffice the need or should be all together with the CE certificate.

 

[Ronen E]

If the manufacturer places these standalone power cords on the EU market it's legitimate to ask them to provide the EU declaration of conformity, or explain why the LVD is N/A in this case.

VDE is irrelevant to the above. There is no substitute in the NLF for a DoC.

 

[Harsh]

In our case, we do purchase this power cord from the supplier & send it with our product as a default accessory in Europe. Our product for example centrifuge is CE certified & has been tested according to the applicable EMC & Safety standards with the same power cord. Still, would there be a need for a separate CE certificate of the power cord as we are a Non-EU manufacturer?

Currently, we are developing a new Power Cord supplier. The current supplier is providing a CE certificate but the new suppliers don't. So, is it mandatory to have the CE-certified power cord as per the above-mentioned scenario?

 

[Ronen E]

To answer all these questions, it's necessary to understand
-- Where (inside/outside the EU) each business entity is based
-- Whether each item is placed STANDALONE (not as a component integrated in another item) on the EU market
-- Under whose name each item is placed on the market

If you provide the power cord as an integrated component in an item that you place on the EU market, it doesn't have to be CE marked. Your obligation is only to ensure (via any reasonable method) that it doesn't sabotage YOUR item's overall compliance (and hence its eligibility for CE marking). What counts in this case are actual properties and functioning. To remove doubt, I'd recommend in this case to have the cord packaged in/with your product, such that there is no question that it's an integral part of it. If that's not practical, you need to supply them together (2 separate items in the same delivery, e.g. inside the same shipping carton). If they are delivered separately it's already pushing it into a grey area (even if you say that they are one item because they're ordered together, or the likes).

If, on the other hand, you supply the power cord in the EU on it's own (say, as an accessory for your product line), CE marking is relevant to it. If you merely distribute it (i.e. on-sell as-is, with the original packaging, labeling etc.) you can only use CE marked cords (assuming that the LVD is actually applicable to that type of cord; I'm saying that because I'm not an expert on the LVD). If the cord manufacturer didn't CE mark it you can't supply it in the EU, unless you take responsibility as Manufacturer, which will mean you'll need to supply it under your own name, ensure that it meets all the applicable conditions for CE marking and then apply the CE mark.

 

[Harsh]

Thanks a lot, Mr. Ronen for the brief explanation.

 

[CharlieUK]

The VDE mark does show that the certified component/product has been tested at a laboratory approved by VDE and is a useful addition to the manufacturer's DoC
The validity of VDE marks can be checked at Online Search (vde.com)

 

[Harsh]

Yes, Mr. Charlie that is undoubtedly a useful addition but according to my understanding, this certificate is not valid standalone in Europe without a CE certificate because the certificate provided by our vendor for the power cord, contains VDE & DIN safety standards. And when it comes to the EC declaration of the product being placed in the European market the product should be tested with the applicable EN (European) harmonized standard & due to that, there is no way to correlate the VDE certificate with the EC declaration.

If I am still missing something please do let me know.

 

[CharlieUK]

The manufacturer is legally required to sign a Declaration of Conformity (DoC) when they intend to place it on the market in Europe
The only people who have a right to a copy of an LVD DoC are the manufacturer, the European "importer" and their "authorised representative" if there is one, and of course EU market surveillance.

Please remember that a DoC is not "proof" that a product complies, it's just the manufacturer saying that it does
If you are sourcing a mains lead outside of Europe and placing it on the market in Europe, then you are taking on legal responsibility for it's compliance, so my recommendation is that you obtain proof of compliance from your supplier or choose another supplier who will provide you with that proof