CE Marking conformity assessments and examination facilities for EMC, R&TTE and LVD are simply too expensive at around 500 to 5000 pounds for the small manufacturer making one offs or small runs. These facilities need to be made available to all small manufacturers at a reasonable price. I don’t think the examinations should be for free, but I do think that they should be made at a cost that is affordable, maybe for the same price as a car MOT examination. Ofcom, Universities and some technical colleges have the test equipment to make these assessments and examinations very easily. Such an examination could be made in 1 to 2 hours. I know Ofcom have regional offices all over the UK in the major cities for policing communications in those areas. It is also Ofcom that is responsible for monitoring compliance with the EMC and R&TTE directives. Without evidence of this compliance you cannot CE Mark your product and therefore you cannot place it on the market. Surely it must be possible to make a program or process where the small manufacturer can take new designs for assessment and examination at the regional Ofcom offices for a small fee that will cover the cost of the time used by the of Ofcom employee. This would not result in any further cost to the taxpayer, in fact if enough assessments were made Ofcom may make a profit, this would open the market up to small manufacturers with new inventions, innovations and ideas that would lead to more jobs and skills.

Why is this idea important?

Without going into the exact details, basically 99% of all electrical electronic products, except digital watches and torches, require EMC or LVD and sometimes R&TTE.

There are many manufacturers, innovators and inventors that cannot bring their ideas, their enterprise and their job creation to the market because of the unfair way the European directives are imposed on small manufacturers. I think everybody would agree that standards need to be in place to ensure products are safe to use and therefore in principle CE Marking is necessary. The fundamental problem is that the process for CE Marking is designed around the needs of very large enterprise that are making product runs of say 10,000 units or more to a mass market.

For the large enterprise the process works by them designing and building a prototype, then they use there own examination facilities with very expensive test equipment or outsource the examination at a cost of several thousand pounds. Once they have the examination certificate for the prototype, they then start production on manufacturing 10,000 units or more. It is not necessary under the CE regulations to examine any further units, only the prototype. The cost of CE Marking per unit is very small, usually lees than 1 pound.

For the small enterprise that has a great idea and product and they have found one or two customers and they want to build on the idea and improve there design as they sell each unit and in turn employ more people as they build the business, forget it, it’s not possible, this enterprise is effectively finished or has to break the law. This is what is killing the creativity and the jobs. The small enterprise cannot afford to pay thousands of pounds every time the product is invented, improved or updated. In my own experience I have found that the CE Mark EMC, R&TTE and LVD specifications at a hands on practical level are relatively easy to meet when designing and building the product. The difficult part is providing the independent assessment or evidence to prove that your product complies, this is the expensive part. If you don’t have this in a technical file your product is illegal and you can be fined or in extreme cases sent to prison.

Due to this there are many hundreds, even thousands of ideas, talent and business opportunities lost by the small manufacturer in the UK. The same rules simply cannot be fair or apply to a company of 1000 employees and a company of 5 employees. Lets remember all the great inventions came from people working in there attics, not anymore, it´s not possible. I have been fighting this situation now for 10 years and have much experience with it. If I can help any Minister or other person to formulate a plan to resolve this situation, I would be happy to share my experiences.

One Reply to “CE Marking imposed on small manufacturers over the last 10 years has killed Creativity, Productivity and lost Jobs!”

  1. I agree, the EU directives and the CE marking process was has massive grey areas, and areas where the directives make no sense – a good example of this is the Raspberry Pi. Even simple accessories designed for sale in the UK would be difficult to produce – the result is that there are large numbers of non CE marked items for sale by UK companies that likely should be. The process is also two faced:- RS Components originally blocked the initial sale of Raspberry Pis because it had no CE mark, but now sell Adafruit modules in the UK that have no CE mark (when strictly they should)?

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