This question has been raised many times over the years, and the same reference was quoted and the same conclusion was reached - and I can't remember anyone posting that they followed this approach and yet then had issues with the relevant customs departments failing to allow products back into the EU (I hope that remains true for repaired products from the UK after Brexit!).
John E Allen W. London, UK From: Charlie Blackham [mailto:[email protected]] Sent: 13 March 2017 21:06 To: [email protected] Subject: Re: [PSES] EU Requirements question Michael This is a "horizontal" issue and is addressed in Section 2.1 of The Blue Guide: ...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... I would recommend that the shipping forms and customs documents make it clear that product is being shipped for/following repair. Regards Charlie Charlie Blackham Sulis Consultants Ltd Tel: +44 (0)7946 624317 Web: <https://outlook.hslive.net/owa/redir.aspx?C=02be3bf3e3a544d1bdf7b6c99fbd12f 5&URL=http%3a%2f%2fwww.sulisconsultants.com%2f> www.sulisconsultants.com Registered in England and Wales, number 05466247 From: Sundstrom, Mike [mailto:[email protected]] Sent: 13 March 2017 20:57 To: [email protected] Subject: [PSES] EU Requirements question Hello everyone, I have a question regarding the shipment of customer bought unit (old compliance before RE_D) back to the EU after RE_D. If a customer ships in old compliant equipment for repair how do I get it back to them in the EU if it isn't compliant with the new standards now in effect (RE_D)? What directive/standard allows this? Thanks, Michael Sundstrom Garmin Compliance Engineer 2-2606 (913) 440-1540 KB5UKT "Never give up on a dream just because of the time it will take to accomplish it. The time will pass anyway." 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