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list In: Regulations person Posted By: Renzo Cattaneo

CE what to do ?

Discussions about CE marking of products are intriguing.

Given that I happened to receive the request or criticism that eliquids were not CE marked I thought I would make a few remarks out loud...

Discussions about CE marking of products are intriguing. These days, then, the discussion is particularly heated because of an incident also reported in some minor newspapers. Without going into the merits of what seems to me to be a surreal presentation with little correlation to actual events, I find the issue raised to be as significant for those who work in the sector as it is for those who are merely 'consumers' and that these advertisements are the last thing we all need.
Given that I happened to receive the request or criticism that eliquids were not CE marked I thought I would make a few remarks out loud.
The first thing to know is that not everything sold in Europe needs to be CE marked. There are only categories of products that have to be marked, including electrical devices that fall under the low voltage legislation, i.e. DIRECTIVE 2014/35/UE the legislation specifies the scope first:
CHAPTER 1
GENERAL PROVISIONS
Article 1
Subject matter and scope
The aim of this Directive is to ensure that electrical equipment on the market fulfils requirements which provide a high level of protection for the health and safety of persons, domestic animals and property, whilst ensuring the functioning of the internal market.
This Directive applies to electrical equipment intended for use at a rated voltage between 50 and 1 000 V for alternating current and between 75 and 1 500 V for direct current, with the exception of the materials and phenomena listed in Annex II.
The first consideration: what is used in vaping generally falls under 'very low voltage', i.e. DC voltages below 75 volts, so why should it be CE marked?
A mechanical device, consisting of an enclosure suitable for housing a battery and a switch with electromechanical features designed for extra-low voltage why should it be marked, especially if we consider the fact that it is in most cases not sold with a user. I mean sold with a device that serves to mount a resistor which is referred to in electrical engineering as a 'user' but which for us is called an atomiser, i.e., a mechanical piece that coils (resistors, users as you prefer) can mount on, either already made or DIY manufactured by the vaper.
Actually, if we move from 'mechanics' to electronics, the matter becomes a little more complicated. The voltage ranges change, dropping in the case of alternating to 50 volts. It is not a slip of the tongue to speak of alternating current; have you noticed that a battery charger is included in many packages? The battery charger operates at mains voltage and must therefore be CE marked. The manufacturer rightly puts the CE mark on the whole package, what sense would it make to say 'the CE mark refers to the charger accessory that is included in the packaging' . There is also the case that the product comes with a lithium battery that must be CE marked, and at this point the CE mark is needed for that alone.
As always, however, we live in a complex world and there are other regulatory levels:EMC (Electro Magnetic Compatibility), the RoHS (Restriction of Hazardous Substances Directive) and the WEEE (Waste of Electric and Electronic Equipment).
In the case of EMC, which requires CE marking, it must be verified that the equipment complies with an appropriate level of electromagnetic compatibility with reference to the specific ISO, IEC standards that must be applied for the construction of the product
In the case of RoHS, which in turn requires CE marking, we are mainly talking about products that have no disposal problems due to the presence of metals such as lead, mercury, cadmium.
The WEEE (known in Italy as RAEE and regulated in Italy by DL n. 151/2005 ) instead talks about the use of hazardous substances and the disposal of waste such as electrical and electronic equipment among which we also find electronic cigarettes and in particular those with built-in batteries.
Among other things, current legislation stipulates that it is no longer mandatory to apply to a notified body for the CE marking, but the manufacturer is left to carry out the marking on his own responsibility.
As a clarification, the manufacturer or his authorised representative (if the manufacturer is not resident in the EU) must issue the Declaration of Conformity certifying compliance with directives and standards. The laboratory that possibly helps the producer/manufacturer in the fulfilment of the Declaration of Conformity and the consequent marking is not a certifying body even if it is a notified body. It only carries out consultancy activities, since the manufacturer's responsibility cannot be delegated, the laboratory issues a Certificate confirming the conformity of the examined product to the standards. The marking and all that it includes is the exclusive responsibility of the manufacturer since it also includes, as mentioned, the production control.
Proof of this is the fact that the Declaration of Conformity must include the production data: lot, batch, serial number, last 2 digits of the year of production.....
The Declaration of Conformity is supported, as a necessary document, by the Technical File that contains the technical information and that relating to the tests and analyses carried out; this document must also be made available by the manufacturer for possible inspections by the authorities (NAS, Guardia Finanza, Chamber of Commerce...). In addition, the consumer must be provided with the user manual.
The legislation has also introduced the concept of traceability, which means that the manufacturer's address must also be shown on the packaging.
Having said this somewhat technical premise, I would say that a few further considerations can be made: very often in vaping, devices are used in which the 'manufacturer' has not even considered subjecting the product to this entire validation operation, and 'driven' by enthusiasm, puts products on the market that have not undergone any checks.
The consumer/user thus exposes himself not only to the risks related to his own inexperience and fatality but also to the mistakes made by these improvised manufacturers, with the result of exponentially increasing the risk of an accident. To compare the inexperience of someone driving a sports car and not knowing how to drive it at 300 km/h is paradoxical to say the least. Like saying that an ironworker craftsman builds a 1000 hp monster, sells it, his customer crashes, and it is the fault of the incompetent driver. I have to laugh: I would say that one is a crook who sells products without any knowledge and respect for the consequences, the other is most likely a clueless fool. In any case, each has put his own spin on it.
So if you want to vape peacefully I would say that choosing products with manuals as well as all tested certifications and protections is the best choice. If for any reason a battery decides to fail and so does its protection, or the DIY-prepared coil is inadequate for its intrinsic characteristics, the system has imperfections ranging from variations in internal resistance to oxidised contacts, I think it is much more astute to avoid annoyance to use a small circuit that has undergone tests as the best choice for your own safety. There are very good and safe products that perhaps cost even less than certain productions that cannot even be described as homemade and that are designed to prevent the system from breaking down or to break down before damage is done to other parts as in the case of mechanical systems that do not offer protection.
Just as an example, there are tubes on the market that have microfuses that protect against overcurrents and effective safeties against unintentional activation, on the other hand, one sees boxes without any fire block and with protruding activation buttons intended for use with coil switches or tubes without adequate air vents and which are perhaps opposite the positive pin.
Electrical engineering is a subject that not only studies electrical phenomena from the point of view of Ohm's laws, but also the mechanical resistance that devices must possess in order to work under certain electrical power conditions. Electronics helps us, by imposing not only operating conditions but also conditions set as safety limits, to avoid taking risks. The electronic box in essence is not just a nice display even in colour now with smartphone-type apps. Do you remember that the first electronic tubes could not operate in subohm? We are talking about the Provari, for example. Today, if a box does not come close to allowing near short-circuit resistances, it is considered uninteresting (although going down in resistance the protection of the circuit itself is always an insurance policy in an electronic device). A nice mechanical tube or box with reed contacts, short, pushes ... (you can't see it but I'm laughing thinking about the word pushes) when I studied electrical engineering I was never told about this physical quantity, perhaps because the International System doesn't include the units of measurement "bout as much", "as ugly" "as scary", and I don't think because at the Milan Polytechnic they were unprepared and unaware of vaping..
Joking NOT aside, let's talk about serious things, the regulations are there, the construction criteria are known, the systems and measuring instruments are also known: why take the risk even if you are an expert, and all the more so if you are not familiar with the rules that vaping with certain systems requires you to know and use? Vaping was born to stop smoking, and now it is much more, not that this is a bad thing, but it is my opinion that if something is beautiful, we must all contribute to keep it that way by respecting ourselves first and not certain aberrant logics that are often just the result of unscrupulous profit-making policies... based on the concept of creating the need for what is not really needed.
I forgot to confirm that eliquids do NOT have to be CE marked, they have the privilege of being subject to TPD... LOL

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