If a European based manufacturer buys a 60 Hz only product from outside the EU, and it is shipped into the EU to be built into, tested with, or made part of a larger unit or tool, the whole of which will be then be exported to a non-EU country, is CE Marking required?
My initial answer is NO as the equipment is neither intended to be placed on the market in the EU, nor will it require free movement within the EU. In the LVD, Article 12 covers this by stating, "This Directive shall not apply to electrical equipment intended for export to third countries. The EMC Directive does not have the same wording nor does it address the topic at all, at least not as far as I found. So the question is if you ship a 60Hz only product into the EU that is intended to be re-exported by the firm that bought it from you to a non-EU country do you test the product for CE Compliance (EMC and LVD or Machinery or Medical) and mark it? If not, is there some piece of regulation, information, etc., that can be used to justify to the customer why there is no CE Mark, and that they can use with the local AHJ or Customs folks? Is there anything that you are aware of from any of the EU countries or the Commission itself that deals with this? Is there a bond required when the product is imported which is then cleared when it is exported? Your expert opinions and comments are eagerly anticipated. Thanks, Steve Brody [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: Ron Pickard: [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://ieeepstc.mindcruiser.com/ Click on "browse" and then "emc-pstc mailing list"
