Can mechanical equipment or other products outside the scope of the RoHS Directive bear the CE marking if it is requested by a customer? If not, is providing a DoC a reasonable alternative, so customers are confident in the manufacturing process?
Mechanical equipment may be within the scope of the RoHS Directive depending on its use or function. Mechanical equipment is only outside the scope of the RoHS Directive if it functions using kinetic energy instead of electrical currents or electromagnetic fields, or if it is incorporated into a product that does not require the use of electricity to perform an intended function. However, being outside the scope of the RoHS Directive does not mean a product is unable to bear the CE marking. The CE marking represents compliance with over 20 directives, covering a large variety of products, processes and substances beyond those regulated by the RoHS Directive. Bearing the CE marking is often a condition of EU market access, so it is advisable to ensure the technical file for the product is comprehensive.
In terms of business best practices, providing customers with a DoC regardless of a product’s CE certification status is a sound business decision.
Article current as of 2019-08-16.