Lamp

[BarryF]

Hello. (newbie here, so sorry if this has been asked before). I have come up with a design for a lamp which I've been told would sell. I am keen to explore this. However, the lamp uses a GU10 ceramic base fitting. When I went to buy them in bulk, I came across a few pages trying to sell me a 'New Regulation' version of the GU10 ceramic base which uses three levels of insulation and a cord-grip. But this won't fit into the aperture that I have left myself in the design. Does anyone know if it's perfectly 'legal' to use standard GU10 ceramic bases? I would like to CE mark them. Thanks very much in advance for any help. (I have tried the BSI but they didn't even reply).

 

[MikeG.]

Welcome Barry.

To be honest, you may be better off on an electrician/ electrical engineers forum with that question.

 

[jeremyduncombe]

If you have not already done so, you need to read “The Electrical Equipment ( Safety ) Regulations 2016l. I suggest you take professional advice before proceeding ( yes, I know this will cost money ! ).
If you wish to apply CE marking to your lamps, you must keep written evidence that they comply with all relevant safety legislation. If you use imported electrical components, especially if imported from outside the EU, it is your responsibility to ensure that they are safe and compliant. The 2016 regulations set out the relevant procedures and documentation - but I am afraid they do not answer your question directly.

 

[AndyT]

I think you need to see into the future, guess or wait.

If the UK leaves the EU, there might be an alternative scheme, the UKCA mark.

More info here

https://www.gov.uk/guidance/prepare-to- ... ter-brexit

 

[BarryF]

Yes, the first thing I did was speak to a sparkie, but they only get involved in fitting stuff, not regulations on fittings. I also read up, but I just can't seem to find any regulation appertaining to it. The Brexit thing is very interesting. I got a reply from the BSI today...telling me to ask the government! The manufacturer of bits that go into it is ready to go, but I'm holding them up because I don't want to go ahead and make it, only to find out it doesn't comply! I would have lost quite a bit of money.

 

[CHJ]

If the older style of the GU10 ceramic base has indicated a need to provide an extra heat shield I would see it as prudent to go with the new style if you must use Halogen filament bulbs.

Personally I would have thought that for future proofing the sales potential the incorporation of cooler running more efficient LED elements would be prudent.

 

[Lons]

If the older style of the GU10 ceramic base has indicated a need to provide an extra heat shield I would see it as prudent to go with the new style if you must use Halogen filament bulbs.

Personally I would have thought that for future proofing the sales potential the incorporation of cooler running more efficient LED elements would be prudent.

There isn't a problem using LED in place of filament bulbs in a GU10 fitting, I have them in a number of rooms in the house however they do still run pretty hot and from experience over the years the fittings deteriorate and start to crumble. Not such an issue in the ceilings where they don't fail until you come to change a bulb but personally I'd be a bit nervous using them in a lamp where hands can get a lot closer to live wiring.

However I don't know!

 

[BarryF]

Chas, I intend to ONLY supply these lamps for LED bulbs. They run at around 4-5 watt (rarely 7 watt) and are warm, but you can put your hand on them. I think the older style LED 4 watt bulbs (that came out about four years ago) ran warmer. I think the new style turns more of the electrical energy into light, so you get more lumens for your watts...hence less heat.

The 'New Regulation' type has a shroud on the base of the ceramic holder which incorporates a cord-grip, so I'm thinking that it's something to do with being able to pull on the bulb, and thus expose live wires. This new type does also come with new heat-resistant sleeving, but it's the cord-grip which I think is the change. The cord-grip really messes up my design! My design is still safe, since the base is screwed in, but I'd still have to comply if that's the road they've gone down. Trouble is, I can't find out!

 

[BarryF]

To anyone else reading this who still have GU10 halogen bulbs - I STRONGLY advise you to switch to LED. We removed every halogen bulb in our home some years back, and we actually saw our energy bill drop! The light some modern LED bulbs give out is fantastic. The one sitting on my desk in front of me uses just 5 watts, gives out 520 lumens, and costs around £5, sometimes less.

 

[Lons]

To anyone else reading this who still have GU10 halogen bulbs - I STRONGLY advise you to switch to LED. We removed every halogen bulb in our home some years back, and we actually saw our energy bill drop! The light some modern LED bulbs give out is fantastic. The one sitting on my desk in front of me uses just 5 watts, gives out 520 lumens, and costs around £5, sometimes less.

+1
They've improved dramatically in the last few years since I first bought and halved in price to boot.

Same with outside PIR security lights, I have 6, all now replaced with 10 wt LED, a much whiter light but just as effective.

PS anyone want some halogen GU10, I have a drawer full of the damn things. #-o

 

[RichardG]

It is the manufacturers responsibility to check that what they are supplying meets the necessary standards to give it a CE approval. If you are the manufacturer then the fact that you’re asking a question here means you would be considered as “not competent” to assess the design for a CE approval and must seek a third party to approve the product.

I’ve been through this a few times in my previous life and we always employed a third party to carry out the assessment, why? because it moves the liability to another party if an end user gets electrocuted, burns their house down etc. etc. I would strongly recommend you do the same.

 

[CHJ]

Chas, I intend to ONLY supply these lamps for LED bulbs. ………

The 'New Regulation' type has a shroud on the base of the ceramic holder which incorporates a cord-grip, so I'm thinking that it's something to do with being able to pull on the bulb, and thus expose live wires. This new type does also come with new heat-resistant sleeving, but it's the cord-grip which I think is the change. …….

Presume your design has a cord grip incorporated?
How are you ensuring that only LED replacement filaments are fitted and someone does not fit a halogen filament in them in the future, are you relying on a warning notice, is it incorporated in the design?

Just being devils advocate but all things needed to consider self certify CE or equivalent.

I've only ever had to comply with COSHH regulations (still have a copy of the documentation for some 4000 items) but I know it lead to a lot of sole searching just to fill out and reprise the documentation to show reasonable due diligence.


There are some notes on the subject of electrical item approval by JPT in a thread associated with electrical items linked in the Turning Section Help sticky

 

[BarryF]

RichardG. Thanks for that, that's good advice. It could be money well spent.

Chas, yes a warning notice. There are many lamps now that stipulate LED bulbs due to heat. People (consumers) have been aware of this for decades. There are MANY lampshades where a label indicates maximum wattage of bulb. I wll check out your link - thanks.

 

[TheTiddles]

It is the manufacturers responsibility to check that what they are supplying meets the necessary standards to give it a CE approval. If you are the manufacturer then the fact that you’re asking a question here means you would be considered as “not competent” to assess the design for a CE approval and must seek a third party to approve the product.

I’ve been through this a few times in my previous life and we always employed a third party to carry out the assessment, why? because it moves the liability to another party if an end user gets electrocuted, burns their house down etc. etc. I would strongly recommend you do the same.

It really doesn't! Liability rests with whoever "places it onto the market", all the 3rd party does is give you someone to recoup your loss against should their advice be unsound. Which isn't useful if you are in jail.

If it was me, I'd adjust your design to use a low voltage lamp, and recommend the use of a COTS adapter that will already be CE marked and just plug in, therefore your product will be outside of the low voltage directive and probably not need CE. Or if you want to supply that PSU the technical file is just that you have used an already listed appliance unmodified and then your file just has that DoC and a drawing of the design and an assembly process listed.

But always do your homework and check any advice given.

Aidan

 

[BarryF]

I can't do that I'm afraid, as it's a wall lamp.

 

[Lons]

I can't do that I'm afraid, as it's a wall lamp.

So if that means the lamp is a fixture to the wall with no exposed cable I can't see any reason for a cable grip is at all necessary as the wire can't be pulled.

 

[BarryF]

Yes, I see your point.