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Will customization/ product modification affect CE tested goods?

Discussion in 'Legal, Insurance, Employment and Health & Safety' started by eClaire, Aug 22, 2012.

  1. eClaire

    eClaire

    Joined:
    Jul 21, 2012
    Messages:
    9
    Hi there, good morning.

    I have a query regarding something I was thinking of doing and hope someone here can shed some light on any legalities or such.
    I wish to buy wholesale manufactured fairy wings and add my own touch to them, adding crystals and maybe some glitter patterns. If I do this however, will this compromise the CE testing that has already been approved on the product prior to me adding details? Will they need to go through testing again with the crystals attached?

    Also I want to attach some handmade fabric fairy wings to some dolls, (just simply 2 sides of patterned fabric sewn together in a wing shape) again will this affect the CE testing? If I use CE tested fabric to make the wings out of, and attach to a CE tested doll, would this be OK to do?

    Any advise is very welcome. Don't want to do anything I shouldn't.
    Thanks.
  2. Belle Bambini

    Belle Bambini

    Joined:
    Apr 19, 2012
    Messages:
    1
    I'm pretty sure that making any changes would mean that you'd need to have them tested again - the sewing of fabric on shouldn't be too bad if you use tested fabric - some suppliers may be able to give you a copy of a certificate to save you having the expense of testing it yourself or I work along side someone producing their own dolls who's going through the safety tests procedures and may be able to help. Your local Trading Standards should be very helpful if you give them a call :)
  3. Dean

    Dean

    Joined:
    May 22, 2008
    Messages:
    9,437
    I would say it would need retesting too, particularly if adding crystals that could become a choke hazard. There are a lot of people who 'customise' baby items and clothing with diamontes and the like and Trading Standards are not shy about going after them.
  4. Phari

    Phari

    Joined:
    Sep 10, 2010
    Messages:
    454
    I'm not sure if the law has changed but you used to be able to self certify your items. I used to make soft toys and as long as certain steps were taken eg. using safety eyes with the washers fitted correctly you could put a CE label on them. Maybe check with trading standards to see what they say.
  5. Andy777

    Andy777

    Joined:
    Apr 24, 2007
    Messages:
    23,457
    This is def. not the case with CE marks.

    CE marks can be issued ONLY by authorized companies/certification centres:

    http://ec.europa.eu/enterprise/newapproach/nando/
  6. Gary

    Gary

    Joined:
    Aug 22, 2009
    Messages:
    16,364
    I would also say that they would need to be retested, again I couldn't say for sure but part of the safety testing for toys isn't just in the material used (although that is part of it), but also in the stitching, size of parts, stress testing (as in how easily would they come off), as mentioned above, possible choking hazards, etc.

    Certainly not a path that you should go down unless you know for sure, and only somewhere like trading standards could tell you that.
  7. Phari

    Phari

    Joined:
    Sep 10, 2010
    Messages:
    454
    You can self cert if you are the manufacturer.


    There is a website that lists all the pros and cons of it called CESoultions.eu which might be able to help you eclaire
  8. Andy777

    Andy777

    Joined:
    Apr 24, 2007
    Messages:
    23,457
    No, you can't.

    Only certified experts/laboratories can do these tests and issue certificates.
  9. Gary

    Gary

    Joined:
    Aug 22, 2009
    Messages:
    16,364
    Even manufacturers that self certify the test will have to be carried out by somebody certified to do so in order to ensure it is compliant with regulations
  10. Phari

    Phari

    Joined:
    Sep 10, 2010
    Messages:
    454
    Can I self certify a product with CE certification ?

    Yes, CE marking by Self Certification can be performed in cases where harmonized standards cover all relevant safety aspects of a product. In accordance with the requirements of the applicable Directive, as manufacturer you can carry out the safety assessment procedures and compiling the required documentation. All documentation should be filled in the Technical File.

    Where compliance of a product with the applicable requirements has been demonstrated by that procedure, manufacturers shall draw up an EC declaration of conformity and a CE Mark shall be affixed as referred to the applicable directive.

    An application for a EC-type examination, performance of that examination and issue of the EC-type examination certificate shall be carried out by a Conformity assessment body (Notified body).
  11. Andy777

    Andy777

    Joined:
    Apr 24, 2007
    Messages:
    23,457
    Here you go.
  12. Phari

    Phari

    Joined:
    Sep 10, 2010
    Messages:
    454
    That is if you want to have an examination.
    If your product is low risk then you don't need to have it examined.
    Products which are deemed to be a greater risk have to be tested.


    Depending on the level of risk of the product, the CE marking is affixed to a product by the manufacturer or authorized representative who decides whether the product meets all the CE marking requirements. If a product has minimal risk, it can be self-certified where manufacturers a Declaration of Conformity and affixes the CE marking to their own product.
    Products considered to have a greater risk have to be independently certified by a notified body. This is an organization that has been nominated by a Member Government and has been notified by the European Commission. These notified bodies act as test labs and carry out the steps as listed in the directives mentioned above and then decided whether the product has passed. A manufacturer can choose its own notified body in any member state of the European Union but should be independent of the manufacturer and a private sector organization or a government agency.
  13. eClaire

    eClaire

    Joined:
    Jul 21, 2012
    Messages:
    9
    Hi
    Thank for all the replies and help. Thought it may need to be tested again. Simple idea, but may not be worth doing.
    I have contacted trading standards to see what they say about it all and will take it from there.
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