Mike,
I remember seeing a similar question answered here a while back which
asked if the product was shipped out of Europe and repaired, should
the CE Marking be applied prior to re-entry into the EC. If my memory
is correct, the answers were
1. No CE Marking required if components are replaced with like
components and functionality of the end product remains the same;
2. CE Marking is required if the failed components are replaced with
parts which improve the product or add new functions.
3. CE Marking is required if new "options" are added to the product
which add new functions to the end product.
The question is, does this same rationale apply to products which are
upgraded/repaired within the EC ? My opinion would be "why wouldn't
the same rationale apply?". What is the difference between making the
upgrade inside or outside the EC, other than the fact that EC
authorities have a better chance of seeing the product if it shipping
out of the EC ?
Kendall Wilcox
[email protected]
______________________________ Forward Header __________________________________
Subject: Field Retro Options into Noncompliant Machines
Author: [email protected] at SMTP-MAIL
List-Post: [email protected]
Date: 7/26/96 5:42 PM
Here's a real and present puzzler for us.
We are a maker of large industrial equipment.
We have a number of existing units in the field in Europe. They
were shipped before January 1996, and do not conform to the EMC
requirements. Customers now wish to order various options and
upgrades to the units.
We are trying to determine in which cases we can simply ship
and install the option/upgrade and remain in legal compliance,
and in which cases we must also remove and replace the
electronic controls and bring the ENTIRE machine into
compliance with the EMC directive.
Here are some sample cases:
1) ADD AN OPTION WHICH ALLOWS MACHINE TO PERFORM FUNCTION
IT COULDN'T PREVIOUSLY DO.
The option requires that additional control circuitry be added
to the electronics control cabinet.
2) ADD AN OPTION THAT DUPLICATES AN EXISTING FUNCTION;
e.g. allowing the machine to process 4 raw materials rather
than 3, or deliver to 4 outlets rather than 3. The option
requires adding a few electrical devices to the machine, but
wires into existing control circuits.
3) ADD AN ADJACENT MACHINE THAT WORKS IN TANDEM WITH THIS
MACHINE AND COMMUNICATES WITH IT; e.g. a robotic feeder to
eliminate manual loading of the machine. The new, adjacent
machine fully complies with all CE directives.
QUESTION:
For each case above, do we have to bring the entire old machine
into compliance with the EMC directive when we add the option?
Why?
I think the answers, repectively, are Yes, No and No, but I
cant tell you why, and therefore am uncomfortable with the
possible legal liability of being wrong.
Any help, opinions, reasoning from you folks would be greatly
appreciated!
Mike Sherman
FSI International
[email protected]
(612) 361-8140 phone
(612) 448-2825 fax
