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]
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