LED Keyring Lights

[MSE]

We will soon launch a product which uses a simple LED Keyring lights (if you are unsure of what this is, I have attached a photo below). We will buy the light either from a European dealer or from a Chinese manufacturer, I have found the same product from both.

We are a VERY small company with limited resources and I would like to avoid having the CE responsibility if possible.

I have checked with the European dealer and they said that their product does not have a CE label on it. The Chinese manufacturer has told me that theirs has a CE labeling.

First question: We are not certain if this type of product requires CE labeling at all. Is anyone aware if such a product requires CE labeling?

Second question: If CE labeling is required is it enough to say on the package "Product imported by (European Dealer)" or "product manufactured by (Chinese manufacturer)"?

Or will we need to have the technical dossiers on file in our company in any case?

[frankliy]

First question: It requires CE labeling.
Second question: Ithink CE labeling is not enough for the rule of EU.

[hazu]

First a general remark for importers: You have to realize that company size is not a criteria for a CE responsibility. I can understand that possible costs may want you to avoid it. But, if you cannot bear the costs, choose not to sell the product (or get the manufacturer to do the CE marking).

The CE marking seems only to be relevant if the EMC directive applies. I am not sure that a product with so little power can be considered to be generating interference with other products. If the manufacturer claims to have CE, it may be worthwhile to check for which directive and whether they actually have test reports. Forgive me for being skeptical about the manufacturer's claim. I think the Chinese would sell their mother in law with CE marking if you would be interested...

[MSE]

Dear Hazu

Thanks for that response. But I would like to have more details about this statement:

I am not sure that a product with so little power can be considered to be generating interference with other products.

Can you please give me more details about what this means? This is in essence what our European dealer told us. She said it was a simple low-powered light so she believed that it did not require CE labeling. But I am not sure which directive either of you are refering to.

Thanks.

[hazu]

I am referring to the EMC Directive. This directive applies to fixed installations or 'apparatus'. Look at the definition of apparatus. Basically it is equipment that is liable to cause electromagnetic interference or be susceptible for electromagnetic interference.

In my view there is no hazard in this light being susceptible for interference. And I doubt it generates EMI.

You'll understand I cannot make a statement about your product without investigating it.

[Kelvinthm]

is it not possible that this product requires conformity to EN60825 as LEDs are classified as laser products. Again the power output is low and EN60825 recognises the differences, but it is a standard....

Regards the EMC, I agree that this device should not generate any interference, again it is low powered and also using a battery it operates on a DC voltage so no EMC emissions to be concerned with.