Wrist Injury Despite Protective Gear

[yoos]

Anyway I think we all would prefer for Demon (and all others) to state all certificates explicitly, e.g. "CE certified EN 14120: 2003 + A1: 2007". This is especially important for things like knee protectors which may have different requirements for bicycles, motorcycles, snow and roller sports. Furthermore standards are updated from time to time and the protection improvement can be big enough for us to want to know the particular year.

[Eucner]

27 minutes ago, yoos said:

Or snowboarding wrist guards? Is there a different standard for those? 

The "EN ISO 20320:2020 Protective clothing for use in snowboarding — Wrist protectors — Requirements and test methods" is quite new. I don't know any wrist protector using it.

[Skeptikos]

@yoos, I specifically asked them about EN 14120, so there's no need for confusion. I think it's reasonable to assume that Demon are honest people who give out correct CE info about their products.

I'm not aware of any CE label applied for "very broad european standards". If you think that really exists, the onus should be on you to find the standards before you claim a product is adhering to them. At least demonstrate that they exist first. I've never seen or heard of anything like that.

[Eucner]

Ask for the EU Declaration of Conformity. It is a mandatory document in the EU and should be readily available.

[Skeptikos]

I don't need the official paperwork, but I'm sure Demon would be happy to answer your questions if you want to confirm. Just click the "ask a question" tab on the website or use the contact form.

[Eucner]

On 7/3/2021 at 12:38 AM, Skeptikos said:

@yoos, I specifically asked them about EN 14120, so there's no need for confusion. I think it's reasonable to assume that Demon are honest people who give out correct CE info about their products.

Demon Europe has placed Demon Flexmeter wrist guards on the EU market. They are legally obligated to have it CE marked, tested and provide EU Declaration of Conformity. The guards have a CE mark, but the declaration is not available. I've asked them to send me a copy of it several times. Finally they admitted not having it and asked to contact head office in the USA. I don't understand why they couldn't do it. From USA they don't reply to my emails. It seems that the CE marking on Demon Flexmeter wrist guard is fraudulent and they are not tested according to any EU standards. I still find guards working fine for our purposes.

[Skeptikos]

@Eucner, I asked Demon a while back about the CE test results and they told me the paperwork was lost or maybe never received when they bought the Flexmeters from the previous owner. I think they were originally owned by DocMeter.

The Flexmeters are really old and apparently were certified a long time ago. I don't know all the CE history, the requirement about Declarations of Conformity might not even have applied at that time.

Anyway, based on that, I doubt that the newer D3O version of the Flexmeters has even been tested, even though I think it still has the CE mark on the plastic. I don't think anything nefarious is going on, it just seems like they're a US-based company that's fumbling the EU requirements because they're not focused on Europe. If they're selling in Europe now then they should probably get that sorted out.

Edited April 5, 2022 by Skeptikos

[Eucner]

16 hours ago, Skeptikos said:

The Flexmeters are really old and apparently were certified a long time ago. I don't know all the CE history, the requirement about Declarations of Conformity might not even have applied at that time.

Personal protective equipment directive 89/686/EEC is from 1989. Skimeter, the original maker of Flexmeter, was established in 2001.

[Skeptikos]

3 hours ago, Eucner said:

Personal protective equipment directive 89/686/EEC is from 1989. Skimeter, the original maker of Flexmeter, was established in 2001.

OK. To clarify, this is the law that requires companies to have a declaration of conformity.

While I was looking it up I read that companies only need to keep the declaration of conformity for 10 years. I did some digging and found that Skimeter was advertising the Flexmeters on its website as far back as 2003. So by the time Demon United bought them it may not even have been needed anymore.

Still, I think it'd be interesting to see how the Flexmeters do on the updated tests, even though I'm sure they'd pass. Plus Demon United still needs to certify the D3O version. 20 years, the original flexmeter design is starting to sound pretty old

[Tawpie]

Also keep in mind that the presence of something that looks like a CE mark may actually be a "China Export" mark.

More importantly, the presence of a genuine CE mark does not signify compliance with any specific EN standard, only that (at least) the standard for importation into the EU is met. It doesn't necessarily imply product performance. Typically though, if you bother to test to an actual performance standard, marketing will want to print the EN reference number underneath the CE mark and will liberally splash it around the marketing materials... marketing folks are just that way.

[Skeptikos]

18 minutes ago, Tawpie said:

More importantly, the presence of a genuine CE mark does not signify compliance with any specific EN standard, only that (at least) the standard for importation into the EU is met. It doesn't necessarily imply product performance.

It really kind of does. You have to test your product to the relevant standard (for a wrist guard, that's EN 14120) to get the CE certification. If something is sold as a motorcycle jacket in the EU, it's required to have motorcycle certifications. That's kind of the point of the law.

If you're looking at the cheapest products on Amazon and AliExpress I'm sure you can find some fraudulent CE markings and blatant misrepresentations. (Please don't buy that gear.) But since we're talking about Skimeter and Demon United here ... well obviously they're legit.

[Eucner]

49 minutes ago, Skeptikos said:

OK. To clarify, this is the law that requires companies to have a declaration of conformity.

No, the concept of declaration of conformity is even older. Starting from 1989 the Declaration of Conformity was needed also for personal protective equipment. 

50 minutes ago, Skeptikos said:

While I was looking it up I read that companies only need to keep the declaration of conformity for 10 years.

That is all the time product is on the market and additional 10 years. Technical documentation and DoC needs to be updated every time product is significantly changed or updated, like adding D3O pads.

1 hour ago, Tawpie said:

More importantly, the presence of a genuine CE mark does not signify compliance with any specific EN standard, only that (at least) the standard for importation into the EU is met.

It depends on product groups. Some products don't need CE mark and some do. There are products that need very strict mandatory testing procedures and manufacturing validations. The seller is responsible to know what needs to be done with their products. The DoC is an easy way to check it they had any clue.

[Skeptikos]

22 minutes ago, Eucner said:

No, the concept of declaration of conformity is even older. Starting from 1989 the Declaration of Conformity was needed also for personal protective equipment.

Ok then, "To clarify, this is the law that requires [skateboard gear] companies to have a declaration of conformity." Didn't mean to argue that declarations were invented in 1989 😂

26 minutes ago, Eucner said:

That is all the time product is on the market and additional 10 years.

You need to cite a source for that, because the article I linked on an official European Union website says, "For imported products, the importer must ensure that the product is accompanied by the DoC and must keep a copy of it for 10 years after the product has been placed on the market."

It's a subtle difference, but the Flexmeters were "placed on the market" in the early 2000s. No one would use this wording to mean 10 years after the last item was sold.

[Eucner]

2 hours ago, Skeptikos said:

You need to cite a source for that, because the article I linked on an official European Union website says, "For imported products, the importer must ensure that the product is accompanied by the DoC and must keep a copy of it for 10 years after the product has been placed on the market."

Law text can be sometimes difficult to follow. The requirement applies too each product, not a group of products.

[Skeptikos]

On 4/6/2022 at 6:22 PM, Eucner said:

Law text can be sometimes difficult to follow. The requirement applies too each product, not a group of products.

So you're saying if Demon United sells 100 Flexmeters, they need 100 declarations for them? I don't want to be mean, but maybe you should look for a translation into Finnish just in case you misinterpreted that

[Eucner]

3 hours ago, Skeptikos said:

So you're saying if Demon United sells 100 Flexmeters, they need 100 declarations for them?

Yes, of course. If Demon sells 100 Flexmeters, each of them need to have a Declaration of Conformity. If these all are similar, so can DoC's be similar (ie copies). If there are different types of Flexmeters or updated models, they need corresponding DoC's.

[Paul A]

[Paul A]

Why is the CE mark important?

CE marking indicates that a product has been assessed by the manufacturer and deemed to meet EU safety, health and environmental protection requirements.

It is required for products manufactured anywhere in the world that are then marketed in the EU.

 

 

Can you self certify CE mark?

The CE marking procedure is one of self-certification. Generally, you can do everything yourself and the steps below will guide you through the process.

However Conformance, and a small number of other consultancies, exists because the CE marking process can be extremely complicated and time consuming.

 

 

 

How do I verify a CE mark?

The easiest way to check that a product has CE marking is to look for the symbol.

It should be on the product itself, or on the packaging or information that came with it.

If you suspect that a manufacturer is misusing the CE mark, you can request a certificate of conformity and/or a declaration of performance.

 

 

How long does a CE mark last?

three years

 

 

How long is a CE certificate valid?

Under the current system, CE certificates issued by Notified Bodies are generally valid for three years.

The validity period may only be one year for some high risk devices.

Edited April 8, 2022 by Paul A
formatting

[Skeptikos]

On 4/8/2022 at 3:12 AM, Eucner said:

Yes, of course. If Demon sells 100 Flexmeters, each of them need to have a Declaration of Conformity. If these all are similar, so can DoC's be similar (ie copies). If there are different types of Flexmeters or updated models, they need corresponding DoC's.

Again, citation needed. Where is your citation? It's a waste of my time to rebut random baseless claims, so I'm going to stop replying until you actually provide some evidence.

[Eucner]

5 minutes ago, Skeptikos said:

Again, citation needed. Where is your citation? It's a waste of my time to rebut random baseless claims, so I'm going to stop replying until you actually provide some evidence.

So you do trust Demon when they tell all different, contradicting lies to you, but don't trust me when I tell you the truth. Clicking few times from link you provided https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2016.272.01.0001.01.ENG

Quote

As for ‘making available’, the concept of placing on the market refers to each individual product, not to a type of product, and whether it was manufactured as an individual unit or in series. Consequently, even though a product model or type has been supplied before new Union harmonisation legislation laying down new mandatory requirements entered into force, individual units of the same model or type, which are placed on the market after the new requirements have become applicable, must comply with these new requirements.

[Skeptikos]

1 hour ago, Eucner said:

So you do trust Demon when they tell all different, contradicting lies to you, but don't trust me when I tell you the truth. Clicking few times from link you provided https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2016.272.01.0001.01.ENG

This is crazy talk. I don't trust you because you're a rando on the internet who just a few months ago was badly misreading the CE certification wikipedia article. You have no relevant expertise or credibility.

I trust Demon United for obvious reasons. They're an established company with a good reputation, and they haven't told me any lies. They partner with D3O and make quality stuff, like the Flexmeters.

 

Thank you for finally citing a source, though.

The phrase "making available" is not what we were discussing. But the next section (2.3) is about "placing on the market", so that's helpful:

Quote

As for ‘making available’, the concept of placing on the market refers to each individual product, not to a type of product, and whether it was manufactured as an individual unit or in series.

So you got that right, and I misinterpreted my link from earlier. It is 10 years after they put the last item on the market. The wording is weird, but in the context of all the legal details I can see why they say it that way.

As for having a DoC for each item, that part you're wrong about. Here's the relevant info from section 4.4:

Quote

The declaration may take the form of a document, a label or equivalent, and must contain sufficient information to enable all products covered by it to be traced back to it.

The model declaration of Decision No 768/2008/EC contains:

1. A number identifying the product. This number does not need to be unique to each product. It could refer to a product, batch, type or a serial number.

If your interpretation was correct, every safety gear company would be breaking the law, because none of them provide a DoC for each individual item.

 

So yes, it looks like Demon United needs to get their paperwork in order. But the idea that they're lying about CE certification, as opposed to just being a small US company messing up the EU paperwork, is completely ridiculous. I have no idea what your beef with them is.

Edited April 9, 2022 by Skeptikos

[Eucner]

43 minutes ago, Skeptikos said:

This is crazy talk. I don't trust you because you're a rando on the internet who just a few months ago was badly misreading the CE certification wikipedia article. You have no relevant expertise or credibility.

I've written many times here about EU legislation.  I do make errors like everybody else. What case are you referring?

45 minutes ago, Skeptikos said:

I trust Demon United for obvious reasons. They're an established company with a good reputation, and they haven't told me any lies. They partner with D3O and make quality stuff, like the Flexmeters.

On 7/3/2021 at 12:38 AM, Skeptikos said:

@yoos, I specifically asked them about EN 14120, so there's no need for confusion. I think it's reasonable to assume that Demon are honest people who give out correct CE info about their products.

Without technical files and DoC it didn't happen. 

51 minutes ago, Skeptikos said:

The phrase "making available" is not what we were discussing. But the next section (2.3) is about "placing on the market", so that's helpful:

My quote was from the section 2.3.

53 minutes ago, Skeptikos said:

As for having a DoC for each item, that part you're wrong about. Here's the relevant info from section 4.4:

I never said all products needs to have an unique DoC, just that every product needs to have a DoC.

[Skeptikos]

36 minutes ago, Eucner said:

My quote was from the section 2.3.

Oh my mistake, you did good work there 👍 and I searched through that long document a little carelessly

37 minutes ago, Eucner said:

I never said all products needs to have an unique DoC, just that every product needs to have a DoC.

You said they need 100 declarations for 100 items. They don't, there's only 1.

39 minutes ago, Eucner said:

Without technical files and DoC it didn't happen.

Well, you can see the CE mark on old videos and pictures from when they were sold by Skimeter, so it sounds like you're accusing Skimeter of fraud. Occam's razor says someone's just been careless with the paperwork.

 

I really like the CE standards, but one nice thing about living in the US is that none of this matters here 😄

[Skeptikos]

1 hour ago, Eucner said:

I've written many times here about EU legislation.  I do make errors like everybody else. What case are you referring?

Oh you know what, I'm confusing you with Yoos. Yikes, sorry about that. You have some credibility then. I'll try not to give you a hard time anymore 😅

[Eucner]

On 4/10/2022 at 1:32 AM, Skeptikos said:

You said they need 100 declarations for 100 items. They don't, there's only 1.

No I didn't. You are twisting my words around. You can look at this in two ways: from product to DoC or from DoC to product. Each product needs to have one DoC, but one DoC can cover multiple similar products.