Jim, assuming that the essential safety requirements and fuctionality of your product have not changed, there is no 'placing in the market' after the repair. Therefore there is no requirement to CE mark according to LVD, if the product has brought in to an EU country before 1/1997. An already CE marked product would not need to be re-certified. The sending of the product outside the EU for repair does not impact this situation under the above stated assumptions.
>Subject: Dilema: Repared Units, To CE mark or NOT > > >The one year lapse between the EMC and LVD requirements for the CE mark means >that some units >that are CE marked do not meet the LVD requirements , I do understand that the >should have meet the LVD >requirements since 1973. The original documentation is the DOC that is sent >with >the instrument. This indicates > the applicable Directives for the product. > > >I think the forum has already covered the repair of non-CE marked eqiupement >that was put into >service prior to the effectivity date of the Directives. > >However, a unit may be sent back (out of the EU) that is CE marked for only th >EMC directive. If it is repaired >and sent back to the EU, should the CE mark be left on? > >My feeling is that the mark should be removed unless it can be modified during >the repair to meet the LVD. The >repair paper work would then need to be visible to customs so that they do >not >stop the product. > >We are currently looking for an interpretation on this issue. > >NOTE: > I am clearly not a safety or compliance engineer. I am a product engineer >trying to determine the needs of >my customers. This forum has been a great help and I apologize for the lack >of >expertise. Thanks. > >Jim Stafford Mit freundlichen Gruessen/Best regards, V. Gasse
