Brian Your obligation is to ensure that all products placed on the market, in whatever configuration, comply. There is no stipulation as to how you place products and configurations on the market.
Whether you need to CE mark the upgrade itself depends on what the upgrade is. If the upgrade is a component (or components) that have no functionality on their own then it in itself does not need to be CE marked but you must ensure that the instrument when fitted with the upgrade continues to comply. Normally this would be done when developing the upgrade by investigation and testing if required of the instrument + upgrade combination. As noted by others you would then need to update or issue a new Delcaration of Confirmity covering the new product configuration. Assuming that you are confident that any installation instructions provided to the customer are straightforward and do not allow any risk that the upgrade could be fitted in such a way as to compromise the compliance of the instrument then all is fine. Your customer does not need to get the instrument re-tested. I would say that your obligation is to take all reasonable steps to ensure that the instrument when fitted with the upgrade (following the instructions you provide) continues to comply and that you have documentation to support this argument (ie technical file, Declaration, etc) if asked to defend your claim. Best regards Nick Evans Genesys -----Original Message----- From: [email protected] [mailto:[email protected]] On Behalf Of Brian Harlowe Sent: 02 August 1999 16:57 To: [email protected] Subject: Upgrades Please can you give me some opinions on the following. I have a customer who has one of our Scientific instruments that he wishes to upgrade. If I supply him with CE marked everything to allow him to carry out this up grade and I also provide him with a detailed manual on how to install and connect up these items to be emc compatible. Do my responsibilities end there and does the customer have to get the instrument re tested and CE mark it? Regards Brian Harlowe * opinions expressed here are personal and in no way reflect the position of VG Scientific --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to [email protected], [email protected], [email protected], or [email protected] (the list administrators). --------- This message is coming from the emc-pstc discussion list. To cancel your subscription, send mail to [email protected] with the single line: "unsubscribe emc-pstc" (without the quotes). For help, send mail to [email protected], [email protected], [email protected], or [email protected] (the list administrators).
