I might have interpreted what you wrote wrongly but for Europe there isn't any grandfathering clause, so products from the year dot that are still on the market must meet current standards. Outside of the EU things are somewhat different and grandfathering is often accepted Rich
________________________________ From: James, Chris [mailto:[email protected]] Sent: Tuesday, September 29, 2009 7:09 AM To: [email protected] Subject: Re: [PSES] EU Directives: Placing on the market - legally binding definition I think confirmation of the intent is inherent in the grammar and structure of the blue book definition – suggest you consult a lawyer if you doubt it. Chris ________________________________ From: [email protected] [mailto:[email protected]] On Behalf Of Charlie Blackham Sent: 29 September 2009 11:16 To: [email protected] Subject: EU Directives: Placing on the market - legally binding definition Section 2.3.1 of the “Blue Book” (h tp://ec.europa.eu/enterprise/newapproac /legislation/guide/document/1999_1282_en.pdf <http://ec.europa.eu/enterprise/newappr ach/legislation/guide/document/1999_1282_en.pdf> ) defines Placing on the market as: A product is placed on the Community market when it is made available for the first time. This is considered to take place when a product is transferred >from the stage of manufacture with the intention of distribution or use on the Community market (30). Moreover, the concept of placing on the market refers to each individual product, not to a type of product, and whether it was manufactured as an individual unit or in series. I’m looking for the most “legally binding” pronouncement that “the concept of placing on the market refers to each individual product, not to a type of product”. In effect I’m looking for a citation to dispel the argument that “our product was placed on the market in the year dot, and hasn’t changed, so we do not have to apply/meet new harmonised standards following DOCOPOCOSS of standards against which product was initially assessed.” Is there one better than the “guidance” in the Blue book? Regards Charlie - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]> ________________________________ This message (including any attachments) may contain confidential information intended for a specific individual and purpose. If you are not the intended recipient, delete this message. If you are not the intended recipient, disclosing, copying, distributing, or taking any action based on this message is strictly prohibited. - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <[email protected]> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.org/ 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]>
