Rewiring light fittings and ce marking?

[Blue Duck]

I've got a couple of really good quality bulkhead fittings on ebay but they arent selling....

I think because they are pl9 fittings that is scaring people off.

I was wondering if I removed a the ballast and lamp holders and replaced them with a porcelain ES holder  would that be acceptable???

 

[binky]

don't see why not

 

[Geoff1946]

Well you've touched on the answer in your title. You would invalidate the CE certification.  Personally I may consider doing it for my own use but not to sell.

For safety reasons alone you would have to define what lamp(s)  could be used in the modified fitting.    Then again, you can sell anything on e-bay!

 

[Evans Electric]

Go for  it Ducky . 

Caveat  emptor

 

[OnOff]

So if I sold this would I be selling a fitting? (I rather like it tbh):

 

[binky]

Effectively yes, but who will take any notice on e-bay? THe lamp holders are CE compliant, and I don't see much difference between this and fitting some of the mass produced items we all know are poorly made. By the time we have opned them up, dismantled bits to acces terminal screws and cabled them, we have mre or less re-built the ruddy things anyway.  Pat test and be done.

I've been converting some old rum and gin bottles, the conversion kit is off the shelf, so all standard stuff.

 

[Evans Electric]

How many times,     when installing a new light fitting ,    do I have to discard the pathetic tiny little  connector block  and replace with  "proper "  connectors  that will take  3 plate wiring .      This action , I presume ,  invalidates  all the CE  and warranty stuff  .     

 

[pewter]

some of you might remember a while ago when i asked on here regarding some electric commercial machinary that had no CE marks. The person who bought it was told by (cant remember who, BS people or soemthing) that CE mark is not a legal requirement, and nothing could be done about the people selling the equipment with no CE mark. It was screen printing equipment, heater with conveyor belt, another heater and somehting else. He got the seller to refund him in the end. He was unable to find any law which meant it had to have a CE mark.

 

[Sidewinder]

some of you might remember a while ago when i asked on here regarding some electric commercial machinary that had no CE marks. The person who bought it was told by (cant remember who, BS people or soemthing) that CE mark is not a legal requirement, and nothing could be done about the people selling the equipment with no CE mark. It was screen printing equipment, heater with conveyor belt, another heater and somehting else. He got the seller to refund him in the end. He was unable to find any law which meant it had to have a CE mark.

Supply of Machinery Safety Regulations, UK law (AKA Machinery Directive, EU law) would be the law that you need to refer to.

This accompanied by the General Product safety Directive if for personal use.

If the equipment as individual items pre-dates the implementation of the SMSR, then no CE mark is required.

If they are all stand alone, and then assembled into a "line" where they work together in a coordinated manner, then the assembly must be CE marked by the integrator, unless the assembly was originally assembled as one previously in the EU, or was originally assembled in the EU prior to the implementation of the SMSR.

The crux of the matter lie with when the equipment was originally placed on the market in the EEA.

...  Pat test and be done.

...

I've been converting some old rum and gin bottles, the conversion kit is off the shelf, so all standard stuff.

Unfortunately not acceptable in the eyes of the law.

 

[binky]

Thought you might say that @Sidewinder  :^O

Let me put an argument to you :-

I get  a job to wire up for example a industrial style old warehouse flat, bare brick and steel conduit type scenario. So off I go to the wholesalers, buy a load of steel conduit, terminal boxes etc etc and fit sockets, lights, switches etc etc to the customers plan, which in short, means I end up with a bigger version of the light fiting shown above. It's all effectively custom made, yet we don't CE mark it. OK we issue an EIC, but I don't really see the difference to making a light fitting out of standard components to wiring the flat? I can understand CE marking mass produced items for sale to the general public en-mass, but 1 off specials, as long as they are electrically safe, does CE marking really apply to such an item, or is it more of a case that the CE legislation has been left 'open-ended' as a 'catch-all'?

 

[Sidewinder]

On off's have been specifically, included, to ensure that suppliers cannot get away with making a single product which is unsafe on the basis that it is "only a one off".

The installation is not a product which is why it is not CE marked, however, it still comes under safety requirements, e.g HASAWA and EAWR, even though it is a domestic premises because as soon as someone who is employed enters the premises it becomes their workplace.

 

[binky]

Interesting, I have see quite a few lighting 'products' like this in trendy bars and restaurants, so much so that I was considering knocking a few up for the fun of it -  semi-retirement money spinner! I've fitted a few 'artist pieces' similar to the above to boot, seems to be quite a lot of that around with the trend for up-cycling. I quite often watch a programme about such things, and all they ever seem to do is get an electrician to wire it up.

Is there a form of CE marking that doesn't cost a fortune?

 

[roys]

Many years ago I can vaguely remember making a one off table lamp for a friend out of a bit of pyro shaped like a car coil spring, mounted on a wooden base block with a 20mm  conduit through box on it with a bit of 3 core flex with a torpedoe switch on it, other side brass bc lamp holder.

Looked industrial but smart even if I say so myself, wonder if it is still about, and mate was happy with it, mmmm guess I forgot to CE mark it.

 

[roys]

Sidey, think we mentioned this before when it came up:

on a regular basis we used to modify our control panels, fit remove  timers contactors relays etc, they used to be authorised through our own internal Management of Change process, but nothing about CE was ever mentioned. Should it have been?

I have been retired for a couple of years now so I don't know if things have changed or not, I am just curious about it. 

 

[Andy™]

, but nothing about CE was ever mentioned. Should it have been?

i think it would only need re-CE marked if it was a substantial change

 

[Sidewinder]

As soon as you modify something away from the original design the CE marking is invalid.

The "modifier" then takes on the full legal responsibility of being the manufacturer of the equipment.

Now there is a significance of change aspect, however, once a design is changed, the technical file can no longer be compiled by the OEM as the machine will not be as it was when it was designed.

Also, the modifier cannot compile a technical file as they will not have access to all the information required.

CE marking is just the application of the mark, it is the process that you need to go through to be able to demonstrate that the product is in compliance with the relevant requirements is the bit that is important.

There are many routes to compliance, the main two are, design, build and verify to harmonised standards, this is the recommended route.

Design and build your way, but, if it goes wrong, you need to be able to justify every design decision made, at a level to ensure that you can prove yourself competent and innocent.

Most people follow harmonised standards (or at least they claim to).

As far as lights like this go, it's not difficult, you just build in compliance with the relevant product standard, test accordingly and record, job done, bang your CE mark on, and the rest of the required information, and knock up some instructions, but, make sure that the CE mark is geometrically correct, because if it isn't then that's an offence in itself!!!

 

[Blue Duck]

From previous threads on this subject I guessed it would be a no go but thought I would ask anyway so thanks for your inputs gentlemen!  :Salute

I don't want run the risk of burning someone's house down and getting blamed for it so if anyone wants one for the cost of postage PM me.  

Seems odd though, I can buy all manner of ****e from Shenzhen and nobody gives a fork.

There are also a fair eBay sellers making good money for screwing bits of conduit together!

https://rover.ebay.com/rover/0/0/0?mpre=https%3A%2F%2Fwww.ebay.co.uk%2Fulk%2Fitm%2F162460297207

 

[Sidewinder]

Duck, if you import it into the EU yourself, then yes you can buy anything you like, but as the importer, you are then legally responsible for the product and its compliance with EU & UK legislation.