> 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


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