Brian,
Thanks, this particular product is not a switchable or universal design. We
have some products that we did exactly what you describe.
The two versions use dedicated power supply designs so the power rating
labels are specific for the 110-127 V and 220 - 240 V ranges.
I believe the solution lies in the intricacies of import / export as well,
which is not my strong suit either.
Gregory H. McClure
Lexmark Product Safety
859 232 3240 office
859 232 6882 fax
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"Brian O'Connell"
<oconnellb@tamura
corp.com> To
Sent by: <[email protected]>
[email protected] cc
Subject
10/10/2007 04:05 RE: Question on distribution of
PM non-EU equipment from within EU
Perhaps this can be 'confined' to just a marking issue.
Had a similar requirement from a customer. Designed the label such that
there were two distinct sections of logos and ratings. The 230V input
ratings were segregated from the 120V input ratings, with the CE mark was
only in the section with the 230V ratings.
The manual was appended to indicate destination-specific ratings,
certifications, and compliance requirements. The 'universal' voltage
markings will not conflict with the D of C.
Perhaps others more familiar with import/export can comment on any
potential problems this approach.
luck,
Brian
> -----Original Message-----
> From: [email protected] [mailto:[email protected]]On Behalf Of
> [email protected]
> Sent: Wednesday, October 10, 2007 9:38 AM
> 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
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