This is a tricky question. I can see that there are three cases that can be considered.
Case 1: Unit is repaired and returned to the original customer. I find nothing written that says you cannot do this. The unit is being placed back in service, it is not being placed in service the first time. It is not being placed on the market. That was done when it was sold to the customer. The customer still owns it. The retention of ownership by the customer is a very key element here. Case 2: Unit is repaired and sold to a another customer as refurbished or used equipment. This is not allowed per the Commission's explanitory document on the the EMC Directive. Case 3: Unit is repaired and placed in inventory in Europe as a replacement unit if and when any customer's unit fails. I am inclined to say that this is the same situation as Case 2. Ownership of the unit has changed. Richard Woods Sensormatic Electronics My comments alone and not those of my company. >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
