Gregory, There shouldn't be any problem with what you want to do. This is a business-to-business transaction that does not constitute 'placing on the market'. Consequently, CE marking is not required on the product, and if it is subsequently exported from the EU as part of a system, then CE marking will not be required then. Generally Customs are not the enforcement agency for either the Low Voltage Directive or the EMC Directive, so shouldn't be interested in whether the product is CE marked or not. However, I understand that this may be used as guidance by Customs in certain countries, so it may be prudent to ensure that the shipping documentation states clearly that the product is "Not for distribution in the EU" and "For re-distribution outside the EU only". As has already been pointed out, standards that are written for 230V equipment only do not apply to equipment for other supply voltages. But you shouldn't be worrying about technicalities relating to CE marking as you do not need to do this. Obviously, your customer will need to meet regulatory requirements for whatever country he intends to supply the system into, so I would be asking what countries those are and making sure that your printer has all the necessary approvals for that.
Best regards Neil R. Barker CEng MIET HonFSEE MIEEE Manager Quality Engineering e2v technologies (uk) ltd 106 Waterhouse Lane Chelmsford Essex CM1 2QU UK Tel: (+44) 1245 453616 Fax: (+44) 1245 453571 Mob: (+44) 7801 723735 P Please consider the environment before printing this email. From: [email protected] [mailto:[email protected]] Sent: 10 October 2007 17:38 To: [email protected] Subject: Question on distribution of non-EU equipment from within EU Ladies and Gentlemen We have a customer located in the EU that wishes to bundle one of our printer products with a system, including a PC and other equipment, and distribute it worldwide. Things work smoothly when they are configuring the system for another 230V country, inside or outside the EU. Obviously a DoC already exists covering the 230V version of the printer, which properly bears a CE mark. The issues arise when they envision a bundle for a market where they need to configure the system for a 100-127 V input. They want the 115V input printer to meet all of the requirements of the Low Voltage Directive, even though the product will never be installed in an EU country. In most cases it will be shipped to North America. A DoC has not been created for the 115V product because there has not been a need for it. Both input voltage versions of the product are covered by a valid CB certificate and report, as well as the necessary country safety and EMC approvals for the normally intended markets where they will be sold. The application of some of the harmonized standards that are written specifically for 230V products makes it a bit more difficult to apply them to a 115V model, but we have done this in the past and then used a Notified Body to review the report and issue a statement supporting the approval. The problem with this approach is the added cost and the time delay associated with additional approvals on a product that is already compliant with all of the requirements of the countries in which it is being marketed I have to believe there is a procedure to get a product that is not intended for distribution in the EU shipped to a location within an EU country so it may be bundled with other components and shipped to the ultimate customer outside the EU without going through the unnecessary steps to apply a CE mark to a product that is never marketed in an EU country. Any advice, or pointers to similar discussions in the archive are greatly appreciated. Gregory H. McClure Lexmark Product Safety 859 232 3240 office 859 232 6882 fax Sent by E2V TECHNOLOGIES PLC or a member of the E2V group of companies. A company registered in England and Wales. Company number: 04439718. Registered address: 106 Waterhouse Lane, Chelmsford, Essex, CM1 2QU, UK. - 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/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 Cantwell [email protected] For policy questions, send mail to: Jim Bacher: [email protected] David Heald: [email protected] All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc ______________________________________________________________________ This e-mail has been scanned by MCI Managed Email Content Service, using Skeptic(tm) technology powered by MessageLabs. For more information on MCI's Managed Email Content Service, visit http://www.mci.com. ______________________________________________________________________
