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 - 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. ______________________________________________________________________
