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Does our product qualify for CE Marking if it has UL and/or CSA approval?
Often we get the question: Our product already has a UL and/or CSA approval. Does that
mean that we can also automatically affix the CE Marking?
Unfortunately, that is often not the case.
There are differences between the CE marking certification process and the UL/CSA
certification. And for that reason, normally compliance with UL/CSA does not
automatically give the right to affix the CE marking. However, the UL/CSA certifications
may make the CE process much easier when the testing and certification were conducted
according to international standards similar to European harmonized standards relevant
for the particular product. In that case, it may be possible to skip (parts of) the expensive
product compliance testing.
Please note however that another part of the CE requirements is aimed at the
manufacturer's ability to prove CE compliance through a Technical File. This Technical
File needs to be compiled before the CE marking is affixed (it is a part of the approval),
and even after the product has been placed on the market, the Technical File needs to be
maintained and updated on a regular basis. The UL and CSA requirements for Technical
Files are different, so this would require some attention from your side as well.
Whether the existing UL/CSA files may be used for proving CE compliance can be
judged by our experts after a brief documentation review. We can also help you to
determine the most cost effective route to CE certification of your products. Let us know
when you are interested in our services.
Often we get the question: "Our product is not covered by any of the CE Marking
Directive and does not require CE Marking. However our distributor in Europe insists in
CE certification and the affixing of the CE Marking. What can we do?"
Our answer in such a case is as follows:
If your product is not within the field of application of any of the CE Marking Directives,
it is not allowed to affix the CE Marking. If you would affix the CE Marking anyway,
your company - and in case your company is located outside Europe - your European
importers, would be liable to prosecution for false application of the CE.
In an effort to meet all regulations but not being fully informed about the details,
sometimes distributors are insisting in having a CE Mark affixed to a product, even
although it is not required. However, when it has been established that your product does
not require CE, we recommend you to explain them that you are legally not allowed to
meet their request.