Scott, Many second-hand products will have difficulty meeting current requirements. This is a problem for products which have been used outside the EU when they are imported into the EU for the first time, but for second hand products which are already within the EU (i.e. those which were originally sold into the EU when they were new), the rules for new products do not apply when they are sold as second hand.
Nick. > On 28 Oct 2016, at 15:00, Scott Xe <scott...@gmail.com> wrote: > > Hi Nick, > > Thanks for your useful advice! > > The Blue Guide’s one refers to refurbished products adequately. > > If imported second hand products are treated as newly introduced products > into EU and thus meet the latest directives. It seems the second hand > products is unfit for this law. How can the second hand products survive in > the EU? > > Regards, > > Scott > > > From: Nick Williams <nick.willi...@conformance.co.uk > <mailto:nick.willi...@conformance.co.uk>> > Date: Friday, 28 October 2016 at 1:22 AM > To: Scott Xe <scott...@gmail.com <mailto:scott...@gmail.com>> > Cc: <EMC-PSTC@LISTSERV.IEEE.ORG <mailto:EMC-PSTC@listserv.ieee.org>> > Subject: Re: [PSES] 2nd hand or refurbished products > > Funnily enough, I’ve recently been looking into this. So far as the product > safety directives are concerned, the answer is in the Blue Guide which says: > > “ Products which have been repaired or exchanged (for example following a > defect), without changing the original performance, purpose or type, are not > to be considered as new products according to Union harmonisation > legislation. Thus, such products do not need to undergo conformity assessment > again, whether or not the original product was placed on the market before or > after the legislation entered into force. This applies even if the product > has been temporarily exported to a third county for the repair operations. > Such repair operations are often carried out by replacing a defective or worn > item by a spare part, which is either identical, or at least similar, to the > original part (for example modifications may have taken place due to > technical progress, or discontinued production of the old part), by > exchanging cards, components, sub-assemblies or even entire identical units. > If the original performance of a product is modified (within the intended > use, range of performance and maintenance originally conceived at the design > stage) because the spare-parts used for its repair perform better due to > technical progress, this product is not to be considered as new according to > Union harmonisation legislation. Thus, maintenance operations are basically > excluded from the scope of the Union harmonisation legislation. However, at > the design stage of the product the intended use and maintenance must be > taken into account” > > Bear in mind, however (since I know you are located in the States) that the > directives which apply are those which are in force on the day the prodict > first comes into Europe, even if it has been used outside the EU before that. > In other words, second hand equipment sourced outside the EU is treated as if > it were new on the day it crosses the border. > > Nick. > > >> On 27 Oct 2016, at 18:11, Scott Xe <scott...@gmail.com >> <mailto:scott...@gmail.com>> wrote: >> >> Are EU chemical directives such as packaging directive, RoHS, REACH and >> safety directives applied to 2nd hand or refurbished products? >> >> Thanks and 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 <emc-p...@ieee.org> 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 <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
