I think the only correct answer is "it depends." Perhaps the best practical answer is "You should always be concerned to the extent you learn how a particular regulation treats spare parts"
Each destination country regulation will treat spare parts differently. Some regulations are silent, some are clear, some are ambiguous, some make allowances provided you do a bunch of other work (e.g., to prove the part being imported is really going to repair a product that already complies). And it can go beyond what a particular regulation says, because of the part's appearance to Customs officials. A repair part for a product might appear to be, for example, a common consumer item. The main regulation may allow for the repair part, but the customs officials might see a stand alone consumer product and ask for proof of conformance. Agency actions and interpretations in a country are not always coordinated. Regards, Lauren Crane KLA-Tencor -----Original Message----- From: Scott Douglas [mailto:[email protected]] Sent: Thursday, October 24, 2013 10:30 PM To: [email protected] Subject: [PSES] Repair Parts Hypothetical Question. A company sells a product to a customer in a foreign country. That product may or may not have been compliant to the destination country's requirements at the time of sale. Question is, can repair parts for the product be shipped to that country without concerns? Looking forward to the arguments on both sides. Regards, Scott - ---------------------------------------------------------------- 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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) 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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) 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]>
