Just to clarify what you are saying.... A product can be considered "placed on the market" when it is "sold" to your own wholly owned distribution company provided that company is in the EU. Presumably the goods have to be in a finished state and packed etc.
It would not be good enough to place them in your "finished goods" warehouse, a transaction has to take place even if it is a paper only one within your own company. Chris Colgan Compliance Engineer TAG McLaren Audio Ltd The Summit, Latham Road Huntingdon, Cambs, PE29 6ZU *Tel: +44 (0)1480 415 627 *Fax: +44 (0)1480 52159 * Mailto:[email protected] * http://www.tagmclarenaudio.com > -----Original Message----- > From: [email protected] [SMTP:[email protected]] > Sent: 16 May 2001 14:17 > To: [email protected] > Subject: RE: EMCD query > > > Georg, we appeared to have a difference of opinion. You said that placing > on > the market took place when the products were transferred from the > manufacturing plant to the warehouse even if both locations were owned by > the same company. I had said that the warehouse could not be under the > same > control. I went back to review the "Guide to the implementation of > directives based on the New Approach and the Global Approach" and found > that > you are correct. Clause 2.3.1 defines "placing on the market" and footnote > 31 says "the distribution chain can also be the commercial chain of the > manufacturer." > > Thanks for teaching me something today. This will also help us with our > inventory of ITE when the standards change. > > Richard Woods > > ---------- > From: Georg M. Dancau [SMTP:[email protected]] > Sent: Wednesday, May 16, 2001 8:15 AM > To: Mowbray, John H > Cc: [email protected]; '[email protected]' > Subject: RE: EMCD query > > Hallo all, > > I think the answer to this question is quite simple (see Art 3 EMCD) > > Member States shall take all appropriate measures to ensure > that > apparatus as referred to in Article 2 may be placed on the > market > or taken into service only if it complies with the requirements > laid > down by this Directive when it is properly installed and > maintained > and when it is used for the purposes for which it is intended. > > The key words are "placed on the market" or "taken into service". > I.E. the products have to compy with the valid requirements at the > moment > of "placing on the market". > An equipment sold and delivered to a branch of the same company in > the EU > is "placed on the market" anc can remain on the market for an > indefinite > period of time., > > In your case, Ron, you would have to deliver the products to a > company in > Europe. This company could ba a branch of Hypercom. > > Best regards > > George > Nachricht geschrieben von "Mowbray, John H" > > > > If these products are in a European warehouse then they can be sold > as they > are presently in the distribution system, but if the warehouse is > outside > of > the EU then they must comply with the new requiremetns to be sold > after > July > 1, 2001. > > John Mowbray, P. Eng. > Senior EMC Engineer > NCR Canada, Waterloo > 580 Weber St. N. > Waterloo, Ontario, Canada > N2J 4G5 > 519 884 1710 X5371 > FAX: 519 884 0610 > email: [email protected] > > > -----Original Message----- > From: [email protected] [mailto:[email protected]] > Sent: Tuesday, May 15, 2001 4:26 PM > To: [email protected] > Subject: RE: EMCD query > > > > Ron, my understanding is that if these products were placed in > distribution > - e.g., not under your control - they can remain there for a > virtually > unlimited time until sold as is. However, if the products are still > in a > warehouse under your control, then you have two options: > > 1. Ensure that they are compliant with the norms that are in > effect on > the date of sale, or > 2. Obtain an opinion from a Competent Body that the as is > product is > compliant with the essential requirements > > Good luck! > > Richard Woods > > ---------- > From: Ron Pickard [SMTP:[email protected]] > Sent: Tuesday, May 15, 2001 3:58 PM > To: [email protected] > Subject: EMCD query > > > Hello to all, > > This is directed to all the EMC Directive experts on this > list. I > need your help. > > It has just come to my knowledge that a sizable quantity lot > of > finshed ITE products have been built > and being stored in a warehouse. These products, facing > obsolesence, > are 100% compliant with the > current EMCD requirements (EN55022:1994 & EN50082-1:1992) > and have > been in stock for about a year > now. These are new products, but were built about 1 year > ago. I can > not find any reference to this > situation in either the EMCD itself or the latest > guidelines. > > My question is, do these products need to be brought into > compliance > with the new EMCD requirements > coming on 1-July, or can these products still be shipped > after > 1-July as is? Bringing these products > into compliance with the new requirements may be cost > prohibitive. > > As it would be much preferred to sell these products as > opposed to > scrapping them, I am posting this > to see if there was something that I overlooked. > > Comments? References? > > Thanks in advance. > > Best regards, > > Ron Pickard > [email protected] > > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > Visit our web site at: > http://www.ewh.ieee.org/soc/emcs/pstc/ > > To cancel your subscription, send mail to: > [email protected] > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Michael Garretson: [email protected] > Dave Heald [email protected] > > For policy questions, send mail to: > Richard Nute: [email protected] > Jim Bacher: [email protected] > > All emc-pstc postings are archived and searchable on the web > at: > http://www.rcic.com/ click on "Virtual Conference > Hall," > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ > > To cancel your subscription, send mail to: > [email protected] > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Michael Garretson: [email protected] > Dave Heald [email protected] > > For policy questions, send mail to: > Richard Nute: [email protected] > Jim Bacher: [email protected] > > All emc-pstc postings are archived and searchable on the web at: > http://www.rcic.com/ click on "Virtual Conference Hall," > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ > > To cancel your subscription, send mail to: > [email protected] > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Michael Garretson: [email protected] > Dave Heald [email protected] > > For policy questions, send mail to: > Richard Nute: [email protected] > Jim Bacher: [email protected] > > All emc-pstc postings are archived and searchable on the web at: > http://www.rcic.com/ click on "Virtual Conference Hall," > > > > > > ----------------------- Internet Header > -------------------------------- > Sender: [email protected] > Received: from ruebert.ieee.org (ruebert.ieee.org [199.172.136.3]) > by siaag1ab.compuserve.com (8.9.3/8.9.3/SUN-1.9) with ESMTP > id > HAA15596; > Wed, 16 May 2001 07:48:13 -0400 (EDT) > Received: by ruebert.ieee.org (8.9.3/8.9.3) id HAA20737; Wed, 16 > May > 2001 07:41:12 -0400 (EDT) > Message-ID: > <d74c689b5f7fd211887700e0292651ec08287...@scatrnte01.canada.ncr.com> > From: "Mowbray, John H" <[email protected]> > To: "'[email protected]'" <[email protected]>, > [email protected] > Subject: RE: EMCD query > Date: Wed, 16 May 2001 07:41:06 -0400 > MIME-Version: 1.0 > X-Mailer: Internet Mail Service (5.5.2653.19) > Content-Type: text/plain; > charset="iso-8859-1" > Sender: [email protected] > Precedence: bulk > Reply-To: "Mowbray, John H" <[email protected]> > X-Resent-To: Multiple Recipients <[email protected]> > X-Listname: emc-pstc > X-Info: Help requests to [email protected] > X-Info: [Un]Subscribe requests to [email protected] > X-Moderator-Address: [email protected] > > < > > > > ------------------------------------------- > This message is from the IEEE EMC Society Product Safety > Technical Committee emc-pstc discussion list. > > Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ > > To cancel your subscription, send mail to: > [email protected] > with the single line: > unsubscribe emc-pstc > > For help, send mail to the list administrators: > Michael Garretson: [email protected] > Dave Heald [email protected] > > For policy questions, send mail to: > Richard Nute: [email protected] > Jim Bacher: [email protected] > > All emc-pstc postings are archived and searchable on the web at: > http://www.rcic.com/ click on "Virtual Conference Hall," ************************************************************** Please visit us at www.tagmclarenaudio.com ************************************************************** The contents of this E-mail are confidential and for the exclusive use of the intended recipient. If you receive this E-mail in error, please delete it from your system immediately and notify us either by E-mail, telephone or fax. You should not copy, forward or otherwise disclose the content of the E-mail. TAG McLaren Audio Ltd The Summit, 11 Latham Road Huntingdon, Cambs, PE29 6ZU Telephone : 01480 415600 (+44 1480 415600) Facsimile : 01480 52159 (+44 1480 52159) ************************************************************** Please visit us at www.tagmclarenaudio.com ************************************************************** ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: [email protected] with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson: [email protected] Dave Heald [email protected] For policy questions, send mail to: Richard Nute: [email protected] Jim Bacher: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.rcic.com/ click on "Virtual Conference Hall,"
