John,
Thank you for the reply.
Of specific concern are the harmonic and flicker current requirements. The
limits can be scaled 230/115 to utilize the standard but since the US and
Canada have never adopted them it is not a common test on a 110-127 V
product except in special cases. Therefore there is no guarantee that the
North American design will comply, and redesigning it would not be
preferable.
I will review the LVD as suggested and point out the areas suggested to our
marketing team and the customer. With some help from our import / export
folks, we should be able to get this resolved.
I spend most of my time in the safety standard these days and leave the EMC
standards to my counterparts in the other lab. Maybe I should get back to
my roots and spend a little more time over there occasionally.
Regards,
Gregory H. McClure
Lexmark Product Safety
859 232 3240 office
859 232 6882 fax
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John Woodgate
<[email protected]
o.uk> To
Sent by: [email protected]
[email protected] cc
Subject
10/10/2007 03:47 Re: Question on distribution of
PM non-EU equipment from within EU
In message
<of2fddee18.3f6d22a6-on85257370.0056d32c-85257370.005b6...@lexmark.com>,
dated Wed, 10 Oct 2007, [email protected] writes:
>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,
Which ones? You should not need to do it.
>
>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.
Yes, there is. You need to read the Directive, beginning with Article 3.
Your product is not placed on the market or taken into service within
the Community, so the EMC Directive doesn't apply to it.
You need to describe in detail on Customs documentation exactly what
will happen to the product from the time it enters the EU from outside
(if it does) to the time it leaves.
You almost certainly need to read the national implementations of the
Directive in the countries that the product will enter, as well.
--
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
There are benefits from being irrational - just ask the square root of 2.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
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