Amund The Blue Guide cover this
Products which have been repaired (for example following a defect), without changing the original performance, purpose or type, are not to be considered as new products according to New Approach directives. Thus, such products need not undergo conformity assessment, whether or not the original product was placed on the market before or after the directive entered into force. This applies even if the product has been temporarily exported to a third county for the repair operations. Such operations are often carried out by replacing a defective or worn item by a spare part, which either is identical, or at least similar, to the original spare part (for example modifications may have taken place due to technical progress, or discontinued production of the oldpart). If the repair activity involved export/import activity, make sure the paperwork is clear. Regards Charlie From: Amund Westin [mailto:[email protected]] Sent: 12 March 2014 05:18 To: [email protected] Subject: [PSES] SV: [PSES] Spare parts and EMC directive Thanks to all who replied. Just want to add a comment ... Let's say that an apparatus is not in production anymore. The spare part could be the apparatus main board. If is identical with the original main board, we should expect that the EMC performance of the apparatus is still unchanged after the spare part has been installed. But what if the EMC requirements have been changed (more severe) since the apparatus originally was EMC tested. It's not possible to re-test the apparatus because it's not in production anymore and it's impossible to test the main board as a standalone unit. I assume you have to make an evaluation that deals with the consequence of new EMC requirements and thereafter let a Notified Body make an opinion. Such an evaluation should only include the spare part. The apparatus itself is already on the marked and new EMC requirements do not have any impact on it. But, maybe the evaluation is an easier task if it includes the complete apparatus. Does it sound as a reasonable route to follow? Best regards Amund Fra: Ted Eckert [mailto:[email protected]] Sendt: 11. mars 2014 17:48 Til: [email protected]<mailto:[email protected]> Emne: Re: [PSES] Spare parts and EMC directive The EMC Working Party issued a guidance document regarding aftermarket parts and spare parts in relation to the EMC and EMC Vehicle Directives. This document gives a clearer statement on the applicability of 2004/108/EC to spare parts. The document is written in regards to automotive parts, but it gives a better idea of how the EMC Directive should be interpreted. http://ec.europa.eu/DocsRoom/documents/4543/attachments/1/translations/en/renditions/native I realized that this does not directly answer the question since it is automotive related. I am only offering it as evidence that the current interpretations regarding spare parts continue to be similar to the previous interpretations. Ted Eckert Compliance Engineer Microsoft Corporation [email protected]<mailto:[email protected]> The opinions expressed are my own and do not necessarily reflect those of my employer. -----Original Message----- From: John Woodgate [mailto:[email protected]] Sent: Tuesday, March 11, 2014 9:07 AM To: [email protected]<mailto:[email protected]> Subject: Re: [PSES] Spare parts and EMC directive In message <[email protected]<mailto:[email protected]>>, dated Tue, 11 Mar 2014, Amund Westin <[email protected]<mailto:[email protected]>> writes: >Can?t find any spare part discussion in latest EMC guideline (2010), >but I find some text in the old 89/336/EC guideline. A strange omission. However, at the practical level, if you are supplying spare parts, make that clear on the invoice: These goods are spare parts for our product model XYZ. -- OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk<http://www.jmwa.demon.co.uk> Nondum ex silvis sumus John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK - ---------------------------------------------------------------- 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]<mailto:[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]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher: <[email protected]<mailto:[email protected]>> David Heald: <[email protected]<mailto:[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]<mailto:[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)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[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]<mailto:[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)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <[email protected]<mailto:[email protected]>> Mike Cantwell <[email protected]<mailto:[email protected]>> For policy questions, send mail to: Jim Bacher <[email protected]<mailto:[email protected]>> David Heald <[email protected]<mailto:[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]>
