Alexandru,
The declaration of incorporation is a document specific to the machinery
directive (Annex IIb) and doesn't apply to the EMC, LVD, or other directives.
The EMC Directive does not apply in this case since, as you pointed out, the
product in question has not been taken into service. There should be no problem
importing the product into Europe.
Now that you and the rest of the group have stopped laughing I will revisit
my last statement. Theoretically there is no problem as far as the EMC Directive
is concerned since it does not apply. Realistically there is no way for customs
to know this 'a priori' so they may well hold it up if there is no mark or
declaration. What normally works is to make a statement, similar to the framing
of your question, that states the product has not been declared to the EMC
Directive but it will be prior to being taken into service. This statement can
be made on the "Declaration of Incorporation" sheet (assuming that this is a
"machine" and is being declared under Annex IIb for the Machinery Safety
Directive). As a separate section addressing EMC (as many people do when they
are declaring they meet the EMC Directive for a partial machine). This has the
advantages of being on a piece of paperwork the inspector is expecting to see
and having the relevant names, addresses, and contact information if questions
arise. You can also make up a separate "(Non) Declaration of Compliance" which
should provide some form of the statement above, the Manufacturer's name,
address, and contact person, the manufacturer's European representative's name,
address, and contact person, and the name, address, and contact for the customer
where the installation is taking place.
- Paul McCoy -
Alexandru Guidea wrote:
> I sent this message last week, without receiving any feedback. I'll try
> again, believing this is a common problem. Maybe the answer is so trivial
> that it doesn't deserve any attention.
>
> Dear group,
> This issue might have been discussed in the past, however, I couldn't find
> useful references in the group's archive.
>
> Here is the question:
>
> An installation is assembled and taken in service only on the customer's
> site, in Europe. Parts composing the installation do not carry the CE label.
> The TCF will be completed after the installation will be tested in-situ for
> EMC. The equipment will be taken into service following the issuance of the
> DoC and CE marking.
> How can the equipment be shipped to an EU country without risking annoyance
> to the customs?
> Has any legal basis the "Declaration of Incorporation"?
>
> Thanks for your help.
>
> Alexandru Guidea
>
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