Julian G4ILO wrote:
Don't forget that, aside from CE marking, you are deemed to be
techniclly competent as an Advanced licence holder and can
therefore build your own kit and operate it within the terms of
your licence. You are right in saying that you can import your
own kit for your own use and if you sell it, it is not as a
business for general sale of lots of these.
Coincidentally the December RadCom EMC column, page 43, has a
discussion that is relevant to this.
It explains that the regulations apply to goods that are "placed on the
market" or "taken into service". New goods sold commercially are
"placed on the market" but (the article states) it is clear from
examples like very noisy (and CE marked!) Chinese made switch mode wall
warts sold on eBay that the local Trading Standards are doing nothing
about enforcement (and from personal knowledge they have neither the
manpower nor the technical competence to do so.) Second hand goods sold
on eBay or at a flea market are not "placed on the market". However,
the purchaser is "taking it into service" and therefore becomes
responsible for its EMC compliance.
Although, as you say, we as radio hams should be competent to decide
whether our equipment meets the standards or not, the average person
buying a wall wart battery charger or whatever certainly isn't.
Therefore this whole CE marking busines seems to me to be a total waste
of time, as it is either unenforced or unenforceable.
Sorry, I don't agree. Overall, I think the European EMC regulations have
been a success - so much so that we take them for granted. It's always
the leakage around the system that gets the publicity, and it only takes
one small thing like an unfiltered wall wart to cause problems for us.
The vast majority of electronic and electrical appliances coming into
European homes are 'mainstream' products from European companies, or
from international companies with substantial business operations in
Europe. Regardless of where they were actually manufactured, these
products do comply with all the relevant product standards. European
radio amateurs have definitely benefited from this. The RFI mailing list
has frequent horror stories from the USA that just don't happen over
here any more.
As licensed amateurs we are personally responsible for EMC compliance,
the only difference being that we don't have to provide formal
demonstrations or documentation.
For kits and ready-made amateur radio equipment imported from outside
Europe, practical experience is that personal importers are never asked
to demonstrate compliance. I can certainly confirm that as an exporter
of kits and boards to the rest of Europe, the USA and around the world -
in over a thousand transactions, never a single challenge.
According to Wayne's posting a couple of weeks ago, Elecraft has already
done the testing to demonstrate compliance with the relevant European
standards - which the K3 passed easily, of course. As soon as all the
necessary documentation has been assembled, they will immediately become
legally entitled to attach a CE sticker (they don't have to file it with
anyone else). But, quite rightly, that isn't Elecraft's main priority
just now.
For K3s being imported into Europe at present, that leaves only the most
trivial technicality: a product that does in fact meet all the relevant
European standards, but doesn't have a CE marking to say so.
Worrying about such little things is a symptom of severe K3 deprivation!
Fortunately, there is also a complete cure for this condition :-)
As soon as the documentation does comes into existence, the owners of
unmarked K3s will become legally entitled to attach a CE sticker
themselves. They don't need any documentation to do this; it is
sufficient to know that valid documents exist. They'll be in the bottom
of a locked filing cabinet, in a cellar on a planet called Aptos.
--
73 from Ian GM3SEK
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