Hi Phil.

You wrote:

> Can anyone help with the following EMC question?
> 
> It concerns equipment shipped to a customer prior to 1996 [ not EMC
> tested and not expected to comply ].
> 
> We want to upgrade the equipment on the some customers' sites to add new
> functions.This will  involve adding some new PCBs & a new wiring loom .
> The equipment is still not expected to comply with EMC regs.    Is this
> acceptable?
> 
> If, instead of doing the work on the customers site, we brought it back
> to our factory and did the same work here. Would this be acceptable?
> 
> If, to save the customer down time, we modified  a similar piece of
> equipment in our factory and then swapped it for the customer's
> instrument. Would this be acceptable? Does it depend where the equipment
> we modify comes from ?(i.e. It could be unsold factory stock or could
> have been returned from a (different) customer).


Assuming that the customer is in the EEA, the situation seems to be this:

a)  If you 'repair' the equipment to bring it to the same 
performance/standard as before the repair, no compliance is required.

b)  If you 'upgrade' the equipment, or 'refurbish' the equipment to a 
higher performance/standard, then the extra bits need to be 
compliant.

Whether the work is done at the customers site, or at your site, or
on the moon is not relevant,  what matters is where the equipment
will be put into service.  The significant point being that if it's
put into service in the EEA after the 1st Jan 96, the added bits
must comply.  If the modifications are substantial, then the whole 
equipment should be compliant as the term 'modified' becomes a bit 
nebulus.

Second hand equipment that has already been in use in the EEA before the 1st 
Jan 96 need not be CE marked, if it has not been modified. 

New stock items from your stores that have not been 'placed in the supply 
chain' must be CE marked when delivered.

That a tuppence worth.

Chris Dupres
EMC Specialist. VG Microtech.
[email protected]
tel +44 (0) 1825 761077
fax +44 (0) 1825 768343
'Opinions expressed are personal, not necessarily Corporate'

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