Our company regularly exchanges failed equipment for replacement equipment for our customers. We then charge them a repair fee and repair the returned material. They keep the unit we sent them for exchange. This supports the need of our customers to have minimum downtime, and eliminates non value-added shipping and administrative costs on both ends of the transaction.
We have a significant amount of equipment now located in the EU to be used for exchange purposes. This equipment is old but repaired. It is NOT CE marked, nor would it meet EMC or LVD requirements without modification. In some cases, the exchange equipment has more capabilities than the returned equipment. 1. Does the exchange of this equipment constitute a repair of existing equipment? 2. Will Member States prohibit the free movement of this equipment? 3. Does all the equipment for exchange have to comply with current directives, or only those in force when the equipment was first shipped into the EU? 4. Are there other implications? Thank you in advance for your replies. Bob Collier [email protected]

