Originally posted by: dougflorence
Misconception of what "Presumption of Conformity" means I think.
It means that a manufacturer can presume that their equipment is in conformity with the requirements of a Directive if it completely meets all the requirements of a Harmonised Standard for that Directive. Assessing compliance with standards would normally involve some lab testing to check insulation withstand voltages, surface touch temperatures, flammability etc.
And this was re-worded in 1994: my apologies. Now this is definitely clarified, and only applies where there are no Harmonized Standards (which is definitely not the case for lamps).
There is no presumption implied for purchasers.
Purchasers wouldn't know and should at first be directed to the retailer or manufacturer, only back to TS if they are not satisfied with the results of those initial enquiries?
I am not an expert on LVD so I would not want to say what standard is relevant here, but briefly looking in the LVD harmonised standards there are quite a few on luminaires.
Domestic purchasers have a reasonable expectation that a CE marking means that equipment will be safe, but distributors to retail suppliers and users covered by HSAWA have a duty to ensure that Equipment is safe, so they should assess whether a CE marking is credible and justified.
The CE marking regime is designed to not pose excessive burdens on responsible manufacturers. It provides a useful framework to define what is currently considered acceptable in the EU market. Sadly there are plenty of irresponsible, incompetent and ignorant manufacturers about; especially on the other side of the globe.
The product may not carry a CE Mark. UK permits the CE Mark to be placed in a prominent position on the instructions or packaging, so may well be discarded.
EUR ING Graham Kenyon CEng MIET TechIOSH
Principal and Proprietor,
G Kenyon Technology