The Commission's guide to the implementation of directives ("blue book")
indicates that a device placed into service for the manufacturer's own use
is not placed on the market. In the link below, see section 2.3.1 for
Placing on the Market and 2.3.2 for placing in service. Specifically note
the third bullet in section 2.3.2.
http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/document/
chap02.pdf
<http://europa.eu.int/comm/enterprise/newapproach/legislation/guide/document
/chap02.pdf>
Richard Woods
----------
From: Kevin Harris [SMTP:harr...@dscltd.com]
Sent: Wednesday, January 31, 2001 3:58 PM
To: 'wo...@sensormatic.com'; emc-p...@majordomo.ieee.org
Subject: RE: RTTE & Placing in Service
You are right Richard.
More directly to your point here is a quote taken from
http://europa.eu.int/comm/enterprise/rtte/interp.htm
and then click on question 12
In the context of the new approach "placing on the market" is defined as: «
A product is placed on the Community market when it is made available for
the first time. This is considered to take place when a product is
transferred from the stage of manufacture with the intention of distribution
and/or use on the Community market . Moreover, the concept of placing on the
market refers to each individual product, not to a type of product, and
whether it was manufactured as an individual unit or in series".
Now the quote is in the middle of a fairly muddled analysis and perhaps
should be taken with a grain of salt but what I get from that is it seems
like a sale need not take place to be taken into service and therefor you
would have to notify.
Best Regards,
Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2
Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020
Email: harr...@dscltd.com <mailto:harr...@dscltd.com>
-----Original Message-----
From: wo...@sensormatic.com [mailto:wo...@sensormatic.com]
Sent: Wednesday, January 31, 2001 2:04 PM
To: emc-p...@majordomo.ieee.org
Subject: RE: RTTE & Placing in Service
Thanks for that info Kevin. I think that publication only
affects needing a
Notified Body per Annex III. The -3 lists the essential
test suites, so it
is no longer necessary to ask a Notified Body to identify
them.
Richard Woods
----------
From: Kevin Harris [SMTP:harr...@dscltd.com]
Sent: Wednesday, January 31, 2001 2:07 PM
To: 'wo...@sensormatic.com'; emc-p...@majordomo.ieee.org
Subject: RE: RTTE & Placing in Service
Hi Richard,
I think it all becomes a moot point on Feb 7. I was looking
at the ETSI site
yesterday and they indicate there that EN 300-220-3 will be
published in the
OJ for the R&TTE directive on that date. EN 300-220-3 is
the harmonised EN
covering the essential requirements under Article 3.2 of the
directive
Best Regards,
Kevin Harris
Manager, Approval Services
Digital Security Controls
3301 Langstaff Road
Concord, Ontario
CANADA
L4K 4L2
Tel: +1 905 760 3000 Ext. 2378
Fax +1 905 760 3020
Email: harr...@dscltd.com <mailto:harr...@dscltd.com>
-----Original Message-----
From: wo...@sensormatic.com
[mailto:wo...@sensormatic.com]
Sent: Wednesday, January 31, 2001 12:43 PM
To: emc-p...@majordomo.ieee.org
Subject: RTTE & Placing in Service
Consider a low power radio transmitter
subject to EN 300 220
that is to be
used only by the manufacturer's service
organization and
will not be placed
on the market for sale. EN 300 220 is a
harmonized standard,
but the
operating frequency is not harmonized.
It appears that the provisions in Article 6
do not apply
since the product
will not be placed on the market. Article 7
contains the
provisions for
putting into service. Notification to the
spectrum
authorities (from Article
6) does not appear to be a requirement even
though the
frequency is not
harmonized. It appears that it is sufficient
to comply with
the essential
requirements and apply the CE marking which
must include the
alert symbol
per Annex VII since the frequency is not
harmonized.
A member state may restrict the placing in
service, but only
for the three
reasons specified in Article 7.2: efficient
use of the
spectrum,
interference and public health. It appears
there is no
legal requirement to
notify the state prior to placing in
service. Thus, any
restriction would
occur due to the state determining that one
of the three
reasons apply to
one or more devices after it being placed in
service. While
it may be argued
that it is a good idea to notify the states
anyway, it does
not appear to be
a legal requirement.
Comments?
Richard Woods
-------------------------------------------
This message is from the IEEE EMC Society
Product Safety
Technical Committee emc-pstc discussion
list.
To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc
For help, send mail to the list
administrators:
Jim Bacher:
jim_bac...@mail.monarch.com
Michael Garretson:
pstc_ad...@garretson.org
For policy questions, send mail to:
Richard Nute: ri...@ieee.org
-------------------------------------------
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.
To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc
For help, send mail to the list administrators:
Jim Bacher: jim_bac...@mail.monarch.com
Michael Garretson: pstc_ad...@garretson.org
For policy questions, send mail to:
Richard Nute: ri...@ieee.org
-------------------------------------------
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.
To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc
For help, send mail to the list administrators:
Jim Bacher: jim_bac...@mail.monarch.com
Michael Garretson: pstc_ad...@garretson.org
For policy questions, send mail to:
Richard Nute: ri...@ieee.org
