Yes John,
The wording of the directive says nothing about
inventory, or old stock. It's the right of the
manufacturer to use the old directive
as a legal instrument until the end of the
transition period.
He just need to make up new papers though
when he continues selling after the 2009 date.
Regards,
Gert Gremmen
Approvals manager
-
ce-test, qualified testing
+ Independent Consultancy Services
+ Compliance Testing and Design for CE
according to:
Electro magnetic Compatibility 89/336/EC
Electrical Safety 73/23/EC
Medical Devices 93/42/EC
Radio & Telecommunication Terminal
equipment 99/5/EC
+ Improvement of Product Quality and reliability
testing
Website: www.cetest.nl (english) //
www.ce-test.nl (dutch)
Phone : +31 10 415 24 26
Fax : +31 10 415 49 53
Disclaimer
Aan dit bericht kunnen geen rechten worden
ontleend. Het bericht is alleen bestemd
voor de geadresseerde. Indien dit bericht niet
voor u is bestemd, verzoeken wij u dit
onmiddellijk aan ons te melden en de inhoud van
het bericht te vernietigen.
This message shall not constitute any obligations.
This message is intended solely for
the addressee. If you have received this message
in error, please inform us
immediately and delete its contents.
From: [email protected]
[mailto:[email protected]]
Sent: dinsdag 4 januari 2005 21:37
To: Gert Gremmen
Cc: [email protected]; [email protected]
Subject: RE: New EMC directive
> I do not fully agree with both of you Mike and
John,
> The directive enters into force on Jan 20th of
2005
and the actual legal date of application would
(for
manufacturers) per member state depend on the
actual
date of implementation in national law.
The target date of becoming into force is then
20-07-2007,
when all national legislations must comply.
Article 16 says clearly that member states should
publish
all regulations to make this legislation start per
2007.
"they shall apply those provisions per
20-july-2007"
Gert: I fully agree on the above, but the issue is
whether or not, we will be allowed to place
on the market products compliant with provisions
of the existing EMC Directive and manufactured
after July 2007. Article 15 (Transitional
Provisions) reads "The Member States SHALL NOT
IMPEDE
the placing on the market and/or the putting into
service of equipment which is in compliance
with provisions of Directive 89/336/EEC and which
was PLACED ON THE MARKET BEFORE 20 July
2009". In this Transitional Provisions there is no
one word about any other dates than July
2009.
Mike: I do not believe that the transitional
period of 2 years was established to allow the
manufacturer to sell inventory produced prior July
2007. Article 15 clearly refers to "placing
on the market or taking into service", with no
references to any manufacturing dates, so based
on the official definition of "placing on the
market" and provisions of the Article, I believe,
during the grace period the manufacturer (or its
representative) will be allowed to place on
the market products manufactured before and after
July 2007. Otherwise, what would be reason
for this Article.
John Radomski
Principal Engineer
Schneider Automation
N. Andover, MA
This message is from the IEEE Product Safety Engineering Society
emc-pstc discussion list. Website: http://www.ieee-pses.org/
To post a message to the list, send your e-mail to [email protected]
Instructions: http://listserv.ieee.org/listserv/request/user-guide.html
List rules: http://www.ieee-pses.org/listrules.html
For help, send mail to the list administrators:
Scott Douglas [email protected]
Mike Mcantwell [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.ieeecommunities.org/emc-pstc
