Wow! I've been telling clients that even a Beta test is allowed, as long as
absolutely no revenue is derived from it. Can't sell it. Can't rent it.
With no revenue, it is an exhibition, a test.
Is this wrong?
- Robert -
Robert A. Macy, PE [email protected]
408 286 3985 fx 408 297 9121
AJM International Electronics Consultants
619 North First St, San Jose, CA 95112
-----Original Message-----
From: Massey, Doug C. <[email protected]>
To: IEEE - PSTC FORUM (E-mail) <[email protected]>
List-Post: [email protected]
Date: Thursday, December 27, 2001 6:20 AM
Subject: RE: Non-compliant product put into EU marked
>
>Article 8.2 of the RTTED (1999/5/EC) allows exemptions for ".. trade fairs,
>exhibitions, demonstrations, etc.". It also requires that a "visible sign
>clearly indicates that such apparatus may not be marketed or put into
>service until it has been made to comply."
>
>Beta testing at a customer site does not fall under the Art. 8.2
exemptions.
>A sales team demonstrating the product to a customer could be exempt for
the
>period of their demonstration. However, you can't call a large scale Beta
>test a demonstration - the Beta test is 'putting into service'.
>
>IMHO, it's in clear violation of the RTTED.
>
>Doug Massey
>Lead Regulatory Engineer
>LXE, Inc.
>
>-----Original Message-----
>From: [email protected] [mailto:[email protected]]
>Sent: Monday, December 17, 2001 5:05 PM
>To: [email protected]
>Subject: SV: Non-compliant product put into EU marked
>
>
>
>As far as I know the product shall be produced in a large scale. The reason
>for putting it on the marked for a time limiting period is (again as far as
>I know) to run the product ( beta version) in a test installation and
>thereafter will it go through the entire test program (EMC, LVD, etc). It
>seems that they did not manage to do the testing before the 1 month test
>period on the field.
>
>Again, I feel they are not doing things in the consecutive order and I also
>think they are no allowed to put in on the marked, even the short period.
>
>Amund
>
>-----Opprinnelig melding-----
>Fra: Tania Grant [mailto:[email protected]]
>Sendt: 17. desember 2001 19:33
>Til: [email protected]; [email protected]
>Emne: Re: Non-compliant product put into EU marked
>
>
>Is the manufacturer serious, or completely ignorant?
>
>If serious, I would disassociate from them as much as possible. If merely
>ignorant, and you have some sort of association with them, I would
recommend
>that you educate them fully.
>
>Another thought, -- is this product slated for mass distribution, even for
>only a month, or is it going to another location or a particular customer
>for some special in-house use or application? What does this customer
>think? Are they aware, and do they agree to this? The Directives do
have
>special provisions for certain special applications where non-compliant (or
>is it merely "untested" !) product can be shipped to Europe, but I believe
>that under those circumstances, the name of the manufacturer and product
>model name or designation has to be "published" broadly in the EU. I
don't
>remember the details. If anyone can shed more light, that would be very
>nice.
>
>[email protected]
>
>----- Original Message -----
>From: <[email protected]>
>To: <[email protected]>
>Sent: Sunday, December 16, 2001 2:06 PM
>Subject: Non-compliant product put into EU marked
>
>
>>
>> Hi all,
>>
>> You place a radio product into the EU marked with the following status:
>>
>> - Not been EMC, radio or safety tested (the previous model was tested and
>> compliant, major modifications have later been implemented)
>> - The product will only be in the marked for a time limiting period ( 1
>> month)
>> - During the time limiting period it will be operating as in a normal
>> condition
>> - No CE mark on the product and no DoC
>>
>> I mean that you can't do this. You have to confirm that you fulfil the
>EMC,
>> radio and safety requirements, DoC in place, even that the product just
>will
>> be in the marked for 1 month and thereafter withdrawal.
>>
>> Any other comments from the list members ?
>>
>> Best regards
>> Amund Westin, Oslo/Norway
>>
>>
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