So battling this out with GPT4....
I remember dealing with the LVD in my old job. A lot of the multiplexed lamp matrix used 50VDC at the time. Later PSUs had lower voltages and had a green LVD sticker on them.
Parts seem to be excempt from CE approval even though the CE regulations state all devices.. but that isn't true on subsections . So GPT4 thinks selling direct to the customer is fine and don't need a EU representative. In effect the buyer or importer is responsible for himself...
I need to figure out why GPT4 thinks these things next...
Your understanding is correct. If you’re selling
parts for old computers, the
Low Voltage Directive (LVD) and other CE marking requirements may not apply to your products, provided they meet certain criteria. Here's why:
1. Parts vs. Standalone Products
- Standalone Products: CE marking is required for standalone products that have their own function (e.g., complete devices, appliances).
- Parts or Components: If the items you sell are not standalone products and are instead intended to be integrated into or used as parts of existing systems (e.g., upgrades for old computers), they typically do not require CE marking.
- Example: A replacement chip or an upgrade board for an Atari ST computer would likely fall under "components" rather than standalone products.
2. Low Voltage Directive (LVD) Applicability
- The LVD applies to electrical equipment designed for direct use within a specified voltage range (50V to 1,000V AC or 75V to 1,500V DC).
- If your parts operate below these voltage ranges (e.g., 5V or 12V typical for computer components), the LVD does not apply.
3. General Product Safety Regulation (GPSR)
- Your products must comply with the GPSR, which ensures that goods placed on the EU market are safe for their intended use.
- Unlike CE marking, GPSR compliance does not require you to affix a CE mark or appoint a Responsible Person (RP). Instead, you are expected to:
- Ensure the product is safe.
- Provide appropriate instructions or warnings to avoid misuse.
4. Selling to End Users
- Because you sell directly to end users for personal use, and your parts are not marketed as standalone devices, your products may fall outside the scope of CE marking entirely.
- End users are not classified as importers or distributors, so there is no expectation for them to ensure compliance beyond basic safety.
5. Key Considerations for Compliance
- Even if CE marking isn't required, you should:
- Clearly label your products as "spare parts" or "components for integration" to clarify their intended use.
- Include any necessary safety instructions or disclaimers (e.g., "Not for standalone use" or "Intended for use in Atari ST systems").
- Ensure the products do not present safety hazards (e.g., overheating, electrical faults) when used as intended.
6. When a Responsible Person (RP) Is Not Needed
- If your products do not require CE marking (because they are parts, not standalone devices), you do not need to appoint an EU Responsible Person.
- The absence of CE marking means your products are not subject to customs checks for CE compliance when entering the EU.
Recommendation
To minimize any potential issues when selling to EU customers:
- Label Clearly: Ensure your products are labeled as parts for specific systems, not standalone devices.
- Provide Safety Information: Include basic safety guidance to comply with GPSR.
- Communicate with Customers: Make it clear to EU customers that the products are intended as parts or upgrades and do not fall under CE marking requirements.
By following these steps, you can confidently sell your parts without needing CE marking or an EU Responsible Person.
-----------------------------------------------------
Almost made myself chuckle, what if I put a warning label on everything and say that this product should not be used under any circumstances and should be immediately returned to the manufacturer for safe disposal.... Surely that would cover every eventuality of use and misuse ?? :lol:
