In message <[email protected]>, dated Mon, 4 
Jan 2010, Bill Owsley <[email protected]> writes:

>Does the concept of "placed on the market" determine when the 
>timing might be marked?

For manufacturers, yes. DoCs must be correct when the products leave the 
manufacturer. If the DoC includes data that is not mandatory, that 
should be correct as well.

>For example, our distribution center (we still "own" the product) 
>delivers, as in sells, or "places on the market", to a retailer during 
>the time frame of the previous directive, but the retailers 
>distribution and sales to consumers is running slow so that they still 
>have products declared to the old directive but are now in the new 
>directive time frame by any (pick one) length of time.  (some of our 
>products have a really long life sitting our shelves for 20+ years 
>until sold.)

Yes, that's what the 'year of grace' is about. One year should be OK for 
high-volume consumer electronics and appliances, and everything else is 
too low volume to be of great concern, unless, as I wrote, there IS a 
known serious issue.
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
I should be disillusioned, but it's not worth the effort.

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