Re: Re: [Elecraft] K3 CE

2007-11-16 Thread David Cutter
You only self-certify if you intend to place new goods onto the EEC market, 
ie you are a manufacturer or importer.


David
G3UNA

- Original Message - 
From: Julian G4ILO [EMAIL PROTECTED]



Couldn't we just self-certify it?


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Re: Re: [Elecraft] K3 CE

2007-11-15 Thread d.cutter
Don't forget that, aside from CE marking, you are deemed to be techniclly 
competent as an Advanced licence holder and can therefore build your own kit 
and operate it within the terms of your licence. You are right in saying that 
you can import your own kit for your own use and if you sell it, it is not as a 
business for general sale of lots of these.

David
G3UNA
 
 
 From: Julian G4ILO [EMAIL PROTECTED]
 Date: 2007/11/14 Wed PM 04:31:17 GMT
 To: elecraft elecraft@mailman.qth.net
 Subject: Re: Re: [Elecraft] K3 CE
 
 On Nov 14, 2007 3:42 PM,  [EMAIL PROTECTED] wrote:
  It is acceptable for an importer to certify products as long as he does so 
  within the legal requirments.  He can then quite legally fix the 
  appropriate CE label and provide a Certificate of Compliance.   I could not 
  comment as to whether W  S follow the requirments.  Anyone has the right 
  to view the Certificate of Compliance for any product within the EC.  The 
  importer then becomes the responsible vendor.
 
 But if I'm importing it to use, not to sell, does this matter? The
 body responsible for CE marking here is Trading Standards. They are
 unlikely to even find out about it since I am not a trader. Toby makes
 a valid point as concerns resale, but being pragmatic, we don't live
 in a bureaucratic police state where officials go through the small
 ads checking on what people are selling, so whether it's legal or not,
 it's certainly going to be under the radar.
 
 I think the only issue that may concern Elecraft is if it is likely
 that imports are going to be stopped at customs and returned at their
 expense. If it's OK for goods to be certified at this end then it
 obviously isn't illegal to import uncertified goods therefore customs
 isn't going to be bothered.
 -- 
 Julian, G4ILO K2 s/n: 392  K3 s/n: ???
 G4ILO's Shack: www.g4ilo.com
 Zerobeat Ham Forums: www.zerobeat.net/smf
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Re: Re: [Elecraft] K3 CE

2007-11-15 Thread d.cutter
You are not a vendor, merely a kit builder, you are not in business.  However, 
it's an interesting question.

David
G3UNA
 
 From: [EMAIL PROTECTED]
 Date: 2007/11/14 Wed PM 04:08:41 GMT
 To: [EMAIL PROTECTED]
 CC: Julian G4ILO [EMAIL PROTECTED],  elecraft elecraft@mailman.qth.net
 Subject: Re: Re: [Elecraft] K3 CE
 
 Hallo,
 
  The importer then becomes the responsible vendor.
 
 Which might be interesting if one ever decided to sell her/his K3, which was
 imported as a Kit and built in Europe?
 
 I wonder...
 
 vy 73 de toby
 

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Re: Re: [Elecraft] K3 CE

2007-11-15 Thread Julian G4ILO
On Nov 15, 2007 8:24 AM,  [EMAIL PROTECTED] wrote:
 Don't forget that, aside from CE marking, you are deemed to be techniclly 
 competent as an Advanced licence holder and can therefore build your own kit 
 and operate it within the terms of your licence. You are right in saying that 
 you can import your own kit for your own use and if you sell it, it is not as 
 a business for general sale of lots of these.

Coincidentally the December RadCom EMC column, page 43, has a
discussion that is relevant to this.

It explains that the regulations apply to goods that are placed on
the market or taken into service. New goods sold commercially are
placed on the market but (the article states) it is clear from
examples like very noisy (and CE marked!) Chinese made switch mode
wall warts sold on eBay that the local Trading Standards are doing
nothing about enforcement (and from personal knowledge they have
neither the manpower nor the technical competence to do so.) Second
hand goods sold on eBay or at a flea market are not placed on the
market. However, the purchaser is taking it into service and
therefore becomes responsible for its EMC compliance.

Although, as you say, we as radio hams should be competent to decide
whether our equipment meets the standards or not, the average person
buying a wall wart battery charger or whatever certainly isn't.

Therefore this whole CE marking busines seems to me to be a total
waste of time, as it is either unenforced or unenforceable.
-- 
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf
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Re: [Elecraft] K3 CE

2007-11-15 Thread dj7mgq
 Therefore this whole CE marking busines seems to me to be a total
 waste of time, as it is either unenforced or unenforceable.

Without wanting to pass judgement on the sense of CE Markings or lack thereof,
one must not forget, that (at least in DL) if you want to use a new rig in a
new car, then it *must* have a CE Marking.

This according the DARC (the German version of the RSGB).

vy 73 de toby



PS: For the German speakers out there...

Source: http://www.darc.de/
-
Funkgeräteeinbau in Kraftfahrzeuge wesentlich erleichtert

Nach einer Mitteilung des Kraftfahrtbundesamtes 
in Flensburg wurde durch eine Bekanntmachung im 
Verkehrsblatt die Richtlinie 2004/104/EG im 
Bundesgebiet in Kraft gesetzt. Diese Richtlinie 
ersetzt die 95/54/EG. Das bedeutet, dass alle 
neuen Funkgeräte in Kraftfahrzeuge eingebaut 
werden dürfen, die ein CE-Zeichen oder ein 
E-Zeichen tragen! Eine E-Zulassung der 
Transceiver ist damit nicht mehr erforderlich.
 
Die CE-Kennzeichnung reicht aus, wenn eine 
Bescheinigung beiliegt, dass das Funkgerät 
nicht im Zusammenhang mit der Störfestigkeit 
(sicherheitsrelevante Funktionen) steht. Als 
neue Funkgeräte sind die zu bezeichnen, die 
ab dem 11. Januar 2005 in Verkehr gebracht 
wurden. Insbesondere betroffen sind hiervon PKW und 
LKW mit Erstzulassungsdatum ab dem 1. Oktober 2002 
sowie Krafträder und Trikes mit Erstzulassungsdatum 
ab dem 17. Juni 2003. So genannte Altgeräte (vor 
dem 11.1.2005) werden von der Richtlinie 2004/104/EG 
nicht mehr erfasst und müssen lediglich die 
Vorschriften zum Zeitpunkt ihres erstmaligen 
Inverkehrbringens erfüllen. Einer Weiterverwendung 
durch wieder Einbau, auch in neuen Kraftfahrzeugen, 
steht nichts im Wege. 
-
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Re: Re: [Elecraft] K3 CE

2007-11-15 Thread Stewart Baker
In the past the authorities were concerned with amateurs causing interference
to domestic radio/television reception and all other government services.
Now it is the amateur that has the problem.

We now have to contend with radio interference to our hobby from:-
TV's (LCD  Plasma), Cable TV, PLT, HomePlug, Switch Mode PSU's either
freestanding (wall warts) or in-built(Computer), electronic controls in anything
from a central heating boiler to a sewing machine . et .al.

It's a bit ironic that, as rigs such as the K3 are now being sold with a superb
receive performance that many amateurs are unable to use due to increasing 
radio spectrum pollution.

Many items sold into the domestic market would appear to be either non -
compliant, or have a test standard applied that is most advantageous to their
products. A lot of items are able to cause HF interference because, the only
radiated emissions testing required is carried out above 30MHz. Below 30MHz only
the conducted interference on the supply lead is tested.

In the UK the enforcing agency is the Trading Standards. They are lacking in
funding, manpower and technical knowledge to deal with anything other than life
threatening issues (i.e. Lead paint on toys).

As far as the EMC part of CE goes, it promised a lot, but has delivered very
little

Stewart G3RXQ
Member RSGB EMC Committee

On Thu, 15 Nov 2007 08:51:20 +, Julian G4ILO wrote:
 On Nov 15, 2007 8:24 AM, [EMAIL PROTECTED] wrote:
 Don't forget that, aside from CE marking, you are deemed to be techniclly
 competent as an Advanced licence holder and can therefore build your own
 kit and operate it within the terms of your licence. You are right in
 saying that you can import your own kit for your own use and if you sell
 it, it is not as a business for general sale of lots of these.

 Coincidentally the December RadCom EMC column, page 43, has a
 discussion that is relevant to this.

 It explains that the regulations apply to goods that are placed on
 the market or taken into service. New goods sold commercially are
 placed on the market but (the article states) it is clear from
 examples like very noisy (and CE marked!) Chinese made switch mode
 wall warts sold on eBay that the local Trading Standards are doing
 nothing about enforcement (and from personal knowledge they have
 neither the manpower nor the technical competence to do so.) Second
 hand goods sold on eBay or at a flea market are not placed on the
 market. However, the purchaser is taking it into service and
 therefore becomes responsible for its EMC compliance.

 Although, as you say, we as radio hams should be competent to decide
 whether our equipment meets the standards or not, the average person
 buying a wall wart battery charger or whatever certainly isn't.

 Therefore this whole CE marking busines seems to me to be a total
 waste of time, as it is either unenforced or unenforceable.


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Re: Re: [Elecraft] K3 CE

2007-11-15 Thread Julian G4ILO
This is, unfortunately, so true. It is getting to the stage when I
wonder how much longer it is possible for someone in my situation to
operate a stealth station in a crowded urban housing estate. It is
not the limited size of my antennas that is the problem but the
interference I have to contend with. I can turn off my electrics and
it makes little difference to the noise level, which is often S3-S5 on
the K3's rather stingy S meter.

As for the situation in Germany, well if that's the law and people
will actually check up on it then you have to go along with it. But
only a politician could bring about a situation where it is an offense
to use equipment that doesn't have a worthless sticker on it. And CE
certification is worthless unless it guarantees that the equipment
meets a worthwhile standard.

I think the only solution that would solve the interference problem
would involve type approval of equipment by independent tester.
Clearly you can't rely on all manufacturers to self-certify with any
degree of honesty. And given the lack of enforcement in the UK there
is no reason for anyone to do more than pay lip service to the
regulations. No doubt you can buy rolls of self adhesive CE stickers
from some Chinese vendor on eBay...

But despite the benefits to us hams of type approval, I'm not sure I'd
like the extra costs and restricted range of products such a measure
would result in. I can remember just how expensive modems were in the
80s when they had to be type approved by the monopoly telecoms
provider.
-- 
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf

On Nov 15, 2007 10:16 AM, Stewart Baker [EMAIL PROTECTED] wrote:
 In the past the authorities were concerned with amateurs causing 
 interference
 to domestic radio/television reception and all other government services.
 Now it is the amateur that has the problem.

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Re: Re: [Elecraft] K3 CE

2007-11-15 Thread dj7mgq
 As for the situation in Germany, well if that's the law and people
 will actually check up on it then you have to go along with it.

Actually what I sent to the reflector was about the German implementation of a
European Union regulation, i.e. it is also the law in the France, Italy,
Spain, Poland, Sweden, Malta, Greece, the U.K. etc.

To see more about 2004/104/EG you could take a look at:
http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32004L0104:EN:NOT

Commission Directive 2004/104/EC of 14 October 2004 adapting to technical
progress Council Directive 72/245/EEC relating to the radio interference
(electromagnetic compatibility) of vehicles and amending Directive 70/156/EEC on
the approximation of the laws of the Member States relating to the type-approval
of motor vehicles and their trailersText with EEA relevance

If the above makes sense or not: This is one reason why it is important that at
least the factory built K3s have a CE Marking. 

vy 73 de toby
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Re: [Elecraft] K3 CE

2007-11-15 Thread Ian White GM3SEK

Julian G4ILO wrote:


Don't forget that, aside from CE marking, you are deemed to be
techniclly competent as an Advanced licence holder and can
therefore build your own kit and operate it within the terms of
your licence. You are right in saying that you can import your
own kit for your own use and if you sell it, it is not as a
business for general sale of lots of these.

Coincidentally the December RadCom EMC column, page 43, has a 
discussion that is relevant to this.


It explains that the regulations apply to goods that are placed on the 
market or taken into service. New goods sold commercially are 
placed on the market but (the article states) it is clear from 
examples like very noisy (and CE marked!) Chinese made switch mode wall 
warts sold on eBay that the local Trading Standards are doing nothing 
about enforcement (and from personal knowledge they have neither the 
manpower nor the technical competence to do so.) Second hand goods sold 
on eBay or at a flea market are not placed on the market. However, 
the purchaser is taking it into service and therefore becomes 
responsible for its EMC compliance.


Although, as you say, we as radio hams should be competent to decide 
whether our equipment meets the standards or not, the average person 
buying a wall wart battery charger or whatever certainly isn't.


Therefore this whole CE marking busines seems to me to be a total waste 
of time, as it is either unenforced or unenforceable.


Sorry, I don't agree. Overall, I think the European EMC regulations have 
been a success - so much so that we take them for granted. It's always 
the leakage around the system that gets the publicity, and it only takes 
one small thing like an unfiltered wall wart to cause problems for us.


The vast majority of electronic and electrical appliances coming into 
European homes are 'mainstream' products from European companies, or 
from international companies with substantial business operations in 
Europe. Regardless of where they were actually manufactured, these 
products do comply with all the relevant product standards. European 
radio amateurs have definitely benefited from this. The RFI mailing list 
has frequent horror stories from the USA that just don't happen over 
here any more.


As licensed amateurs we are personally responsible for EMC compliance, 
the only difference being that we don't have to provide formal 
demonstrations or documentation.


For kits and ready-made amateur radio equipment imported from outside 
Europe, practical experience is that personal importers are never asked 
to demonstrate compliance. I can certainly confirm that as an exporter 
of kits and boards to the rest of Europe, the USA and around the world - 
in over a thousand transactions, never a single challenge.


According to Wayne's posting a couple of weeks ago, Elecraft has already 
done the testing to demonstrate compliance with the relevant European 
standards - which the K3 passed easily, of course. As soon as all the 
necessary documentation has been assembled, they will immediately become 
legally entitled to attach a CE sticker (they don't have to file it with 
anyone else). But, quite rightly, that isn't Elecraft's main priority 
just now.


For K3s being imported into Europe at present, that leaves only the most 
trivial technicality: a product that does in fact meet all the relevant 
European standards, but doesn't have a CE marking to say so.


Worrying about such little things is a symptom of severe K3 deprivation! 
Fortunately, there is also a complete cure for this condition   :-)


As soon as the documentation does comes into existence, the owners of 
unmarked K3s will become legally entitled to attach a CE sticker 
themselves. They don't need any documentation to do this; it is 
sufficient to know that valid documents exist. They'll be in the bottom 
of a locked filing cabinet, in a cellar on a planet called Aptos.




--

73 from Ian GM3SEK
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Re: Re: [Elecraft] K3 CE

2007-11-15 Thread Julian G4ILO
On Nov 15, 2007 11:45 AM, Ian White GM3SEK [EMAIL PROTECTED] wrote:

 As soon as the documentation does comes into existence, the owners of
 unmarked K3s will become legally entitled to attach a CE sticker
 themselves. They don't need any documentation to do this; it is
 sufficient to know that valid documents exist. They'll be in the bottom
 of a locked filing cabinet, in a cellar on a planet called Aptos.

Couldn't we just self-certify it?

On Nov 15, 2007 12:02 PM,  [EMAIL PROTECTED] wrote:

 If the above makes sense or not: This is one reason why it is important that 
 at
 least the factory built K3s have a CE Marking.

OK, Toby, I think we'll never agree on the importance of abiding by
laws that are not enforced. Here, the police can't even be bothered to
do anything about drunken and rowdy behaviour or crazy driving by
young people in the town centre at weekends. The thought of them
bothering to check if a radio has a CE sticker is simply unimaginable.

-- 
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf
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Re: Re: [Elecraft] K3 CE

2007-11-15 Thread d.cutter
In the case of vehicles it will be e marking (lower case).

David
G3UNA

 
 From: [EMAIL PROTECTED]
 Date: 2007/11/15 Thu AM 09:24:45 GMT
 To: elecraft elecraft@mailman.qth.net
 Subject: Re: [Elecraft] K3 CE
 
  Therefore this whole CE marking busines seems to me to be a total
  waste of time, as it is either unenforced or unenforceable.
 
 Without wanting to pass judgement on the sense of CE Markings or lack thereof,
 one must not forget, that (at least in DL) if you want to use a new rig in a
 new car, then it *must* have a CE Marking.
 
 This according the DARC (the German version of the RSGB).
 
 vy 73 de toby
 
 
 
 PS: For the German speakers out there...
 
 Source: http://www.darc.de/
 -
 Funkgeräteeinbau in Kraftfahrzeuge wesentlich erleichtert
 
 Nach einer Mitteilung des Kraftfahrtbundesamtes 
 in Flensburg wurde durch eine Bekanntmachung im 
 Verkehrsblatt die Richtlinie 2004/104/EG im 
 Bundesgebiet in Kraft gesetzt. Diese Richtlinie 
 ersetzt die 95/54/EG. Das bedeutet, dass alle 
 neuen Funkgeräte in Kraftfahrzeuge eingebaut 
 werden dürfen, die ein CE-Zeichen oder ein 
 E-Zeichen tragen! Eine E-Zulassung der 
 Transceiver ist damit nicht mehr erforderlich.
  
 Die CE-Kennzeichnung reicht aus, wenn eine 
 Bescheinigung beiliegt, dass das Funkgerät 
 nicht im Zusammenhang mit der Störfestigkeit 
 (sicherheitsrelevante Funktionen) steht. Als 
 neue Funkgeräte sind die zu bezeichnen, die 
 ab dem 11. Januar 2005 in Verkehr gebracht 
 wurden. Insbesondere betroffen sind hiervon PKW und 
 LKW mit Erstzulassungsdatum ab dem 1. Oktober 2002 
 sowie Krafträder und Trikes mit Erstzulassungsdatum 
 ab dem 17. Juni 2003. So genannte Altgeräte (vor 
 dem 11.1.2005) werden von der Richtlinie 2004/104/EG 
 nicht mehr erfasst und müssen lediglich die 
 Vorschriften zum Zeitpunkt ihres erstmaligen 
 Inverkehrbringens erfüllen. Einer Weiterverwendung 
 durch wieder Einbau, auch in neuen Kraftfahrzeugen, 
 steht nichts im Wege. 
 -
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Re: [Elecraft] K3 CE

2007-11-15 Thread Ian White GM3SEK

Julian G4ILO wrote:



As soon as the documentation does comes into existence, the owners of
unmarked K3s will become legally entitled to attach a CE sticker
themselves. They don't need any documentation to do this; it is
sufficient to know that valid documents exist. They'll be in the bottom
of a locked filing cabinet, in a cellar on a planet called Aptos.


Couldn't we just self-certify it?



Not just out of thin air. Somebody, somewhere has to do the work.


--

73 from Ian GM3SEK
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Re: [Elecraft] K3 CE - needs e marking too for mobile use

2007-11-15 Thread Julian G4ILO
On Nov 15, 2007 2:15 PM, Dave G4AON [EMAIL PROTECTED] wrote:

 In the EU anything added to a car, including radio equipment, must also carry 
 an e mark in addition to a CE mark.

 More work for Eric and Wayne!

Wouldn't that apply only if it is fitted to the vehicle, not perched
on the seat and operated while the vehicle is parked?

-- 
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf
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Re: [Elecraft] K3 CE - needs e marking too for mobile use

2007-11-15 Thread dj7mgq
 In the EU anything added to a car, including radio equipment, must also carry
 an e mark in addition to a CE mark.

According to 2004/104/EG, not anymore. A CE Marking plus the correct
documentation from the car manufacturer is all that is needed now.

vy 73 de toby
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Re: [Elecraft] K3 CE - needs e marking too for mobile use

2007-11-15 Thread d.cutter
Yes, only if the equipment is a permanent part of the vehicle, like the 
radio/stereo/etc does it need the e mark.

David
G3UNA

 
 From: Dave G4AON [EMAIL PROTECTED]
 Date: 2007/11/15 Thu PM 02:59:07 GMT
 To: elecraft@mailman.qth.net
 Subject: [Elecraft] K3 CE - needs e marking too for mobile use
 
 Julian, G4ILO, wrote:
 
 
 Wouldn't that apply only if it is fitted to the vehicle, not perched
 on the seat and operated while the vehicle is parked?
 
 Yes, I am fairly certain that is the case.  For a flavour of the 
 legislation, see:
 http://www.hants.gov.uk/regulatory/tradingstandards/auto.html
 
 Phew...
 
 73 Dave, G4AON
 
 K3/100 kit now shipped via UPS, ordered 30 April 2007
 
 
 
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Re: [Elecraft] K3 CE - needs e marking too for mobile use

2007-11-15 Thread Julian G4ILO
On Nov 15, 2007 2:59 PM, Dave G4AON [EMAIL PROTECTED] wrote:

 Yes, I am fairly certain that is the case.  For a flavour of the
 legislation, see:
 http://www.hants.gov.uk/regulatory/tradingstandards/auto.html

This is interesting:

Which items do not need to be e-marked?

[snip]

* Equipment installed in their own vehicle by persons who are able
to demonstrate competence (for example radio amateurs). However,
equipment designed by a commercial producer for use by radio amateurs
is not exempt.

So I could install my home built radio in my car, and presumably my
built-from-a-kit K2 or 3, but if you buy it ready made it needs to be
marked.

Heck, would our lives really be worse if we didn't have people whose
jobs it is to come up with this stuff?

-- 
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf
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Re: [Elecraft] K3 CE

2007-11-14 Thread dj7mgq
 Hope the K3's coming into the EU have now got CE certification.

I still haven't open mine yet (it arrived at work a couple of hours ago), so I
don't know for sure, but Eric wrote that they would not deliver any factory
built K3s until he was finished with the CE certification process. And that the
kit did not need a CE Marking and could not be certified anyway.

Mine is a kit.

vy 73 de toby

PS: You can find Elecraft's statements about CE Markings in the archives of the
reflector.



 Hope the K3's coming into the EU have now got CE certification.
 
 Stewart G3RXQ
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Re: [Elecraft] K3 CE

2007-11-14 Thread Julian G4ILO
On Nov 14, 2007 12:05 PM, Stewart Baker [EMAIL PROTECTED] wrote:
 Hope the K3's coming into the EU have now got CE certification.

It matters not a jot to me. As Toby has said, it doesn't affect kits
anyway. But if WS can import any MFJ product (which definitely are
not CE certified - I think someone on this reflector confirmed it) and
then certify it themselves, I don't see why lack of certification
should be an obstacle to anyone in the UK receiving the K3 they
ordered, even a built one.

-- 
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Re: Re: [Elecraft] K3 CE

2007-11-14 Thread d.cutter
It is acceptable for an importer to certify products as long as he does so 
within the legal requirments.  He can then quite legally fix the appropriate CE 
label and provide a Certificate of Compliance.   I could not comment as to 
whether W  S follow the requirments.  Anyone has the right to view the 
Certificate of Compliance for any product within the EC.  The importer then 
becomes the responsible vendor.

David
G3UNA


 
 From: Julian G4ILO [EMAIL PROTECTED]
 Date: 2007/11/14 Wed PM 01:32:02 GMT
 To: elecraft elecraft@mailman.qth.net
 Subject: Re: [Elecraft] K3 CE
 
 On Nov 14, 2007 12:05 PM, Stewart Baker [EMAIL PROTECTED] wrote:
  Hope the K3's coming into the EU have now got CE certification.
 
 It matters not a jot to me. As Toby has said, it doesn't affect kits
 anyway. But if WS can import any MFJ product (which definitely are
 not CE certified - I think someone on this reflector confirmed it) and
 then certify it themselves, I don't see why lack of certification
 should be an obstacle to anyone in the UK receiving the K3 they
 ordered, even a built one.
 
 -- 
 Julian, G4ILO K2 s/n: 392  K3 s/n: ???
 G4ILO's Shack: www.g4ilo.com
 Zerobeat Ham Forums: www.zerobeat.net/smf
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Re: Re: [Elecraft] K3 CE

2007-11-14 Thread dj7mgq
Hallo,

 The importer then becomes the responsible vendor.

Which might be interesting if one ever decided to sell her/his K3, which was
imported as a Kit and built in Europe?

I wonder...

vy 73 de toby
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Re: Re: [Elecraft] K3 CE

2007-11-14 Thread Julian G4ILO
On Nov 14, 2007 3:42 PM,  [EMAIL PROTECTED] wrote:
 It is acceptable for an importer to certify products as long as he does so 
 within the legal requirments.  He can then quite legally fix the appropriate 
 CE label and provide a Certificate of Compliance.   I could not comment as to 
 whether W  S follow the requirments.  Anyone has the right to view the 
 Certificate of Compliance for any product within the EC.  The importer then 
 becomes the responsible vendor.

But if I'm importing it to use, not to sell, does this matter? The
body responsible for CE marking here is Trading Standards. They are
unlikely to even find out about it since I am not a trader. Toby makes
a valid point as concerns resale, but being pragmatic, we don't live
in a bureaucratic police state where officials go through the small
ads checking on what people are selling, so whether it's legal or not,
it's certainly going to be under the radar.

I think the only issue that may concern Elecraft is if it is likely
that imports are going to be stopped at customs and returned at their
expense. If it's OK for goods to be certified at this end then it
obviously isn't illegal to import uncertified goods therefore customs
isn't going to be bothered.
-- 
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
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Zerobeat Ham Forums: www.zerobeat.net/smf
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Re: [Elecraft] [K3] CE Mark

2007-11-06 Thread David Woolley

Toby Deinhardt wrote:


  No CE mark seen but I dont think it needs one in Kit form.

For the kit version likely not, but, afaik, anyone who ordered an 


Although it might be technically legal (speculation), I very much doubt
that the kit exemption envisaged a pre-aligned sub-assembly kit, like 
the K3.  As far as I remember, the equivalent position for PCs is that 
board level components have to have individual EMC certification.  In 
that case, they can be certified based on using extremely good cases, 
etc., but the K3 components are only intended to be used in a K3, so 
that loophole won't work.




--
David Woolley
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Re: [Elecraft] [K3] CE Mark

2007-11-06 Thread Toby Deinhardt

Although it might be technically legal (speculation), I very much
doubt that the kit exemption envisaged a pre-aligned sub-assembly kit,


As much as I hate to bother Eric right now, maybe he could give us a
short update on the CE Marking certification status of the K3. Eric was
looking into the legal situation and preparing to have the K3 certified
back in April/May (shortly after the announcement).

It would be a real pity if this creates problems for anyone on our side
of the the Atlantic.

vy 73 de toby



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Re: [Elecraft] [K3] CE Mark

2007-11-06 Thread David Cutter
An interesting parallel with home-build PCs, but the difference is that PC 
boards are sold separately on the open market and in theory can be connected 
with many other manufacturers' boards to make up a system; as such I would 
interpret them as products within their own right. The K3 boards are not on 
the open market as products, they are only viable when coupled together, ie 
unique to the final unit which is the K3.  This is a kit of unique parts for 
one use,  not a collection of various manufacturers' products.   IMHO.


David
G3UNA


- Original Message - 
From: David Woolley [EMAIL PROTECTED]

To: Elecraft List elecraft@mailman.qth.net
Sent: Tuesday, November 06, 2007 9:17 PM
Subject: Re: [Elecraft] [K3] CE Mark



Toby Deinhardt wrote:


  No CE mark seen but I dont think it needs one in Kit form.

For the kit version likely not, but, afaik, anyone who ordered an


Although it might be technically legal (speculation), I very much doubt
that the kit exemption envisaged a pre-aligned sub-assembly kit, like the 
K3.  As far as I remember, the equivalent position for PCs is that board 
level components have to have individual EMC certification.  In that case, 
they can be certified based on using extremely good cases, etc., but the 
K3 components are only intended to be used in a K3, so that loophole won't 
work.




--
David Woolley
Emails are not formal business letters, whatever businesses may want.
RFC1855 says there should be an address here, but, in a world of spam,
that is no longer good advice, as archive address hiding may not work.
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Re: [Elecraft] [K3] CE Mark

2007-11-06 Thread Eric Swartz - WA6HHQ, Elecraft

Hi David,

Since the K3 kit requires 7 to 8 hours of customer assembly of our 
components following the detailed steps in our 60 page assembly manual, 
and because it does involve customer alignment and set up of the PLL, 
filters etc (via the front panel interface) it clearly does fall under 
the amateur radio kit CE exemption. We do some of the alignment for you, 
but you certainly get to do some too. Any your quality of 
assembly/test/alignment directly impacts the final performance of the 
radio. This is not your father's four board plug together home built PC :-)


Also, the regular CE statement of conformity  for built products 
requires  us to maintain manufacturing quality information and processes 
on the final built product. Something that is impossible for us to do on 
a customer built kit, since we have no control over the customer. While 
we certainly have designed the K3 to exceed any requirements in this 
area, it is clear that if the final assembly is done by the customer 
that we have no way of absolutely guaranteeing or controlling this. 
That's another reason for the creation of the exemption for amateur 
radio kits. The regulators obviously felt that since the builder's were 
licensed amateur radio operators in most cases, they were trained in the 
art and would maintain a reasonable level of quality on their own. Thus 
its impossible for a manufacturer= to issue a CE statement on any 
amateur radio kit.


And as far as Toby's question on CE for the built K3 - Yes, we will not 
ship built K3s for sale to the EC until we have finished the test suite 
for CE on them. We had to wait until we were shipping to run the tests 
on actual production units. We're completing this testing now. 
Fortunately the CE statement of conformity is a self certification by 
the manufacturer (us) and does not require any regulatory filing or 
approval through bureaucratic channels etc.


As a side note: Some of tests required for CE are pretty bizarre when 
applied to a ham radio transceiver - As an example the radio must be 
tested for spurious emissions from the radio in receive mode even though 
the acceptable levels for spurious and on channel signals in transmit 
far exceed these RX test values. It looks like most of the regulations 
were written for commercial radio equipment that was intended for use by 
non-technical users from the general public. Fortunately, we easily 
exceed these requirements. Just a lot of formal testing and paperwork to do!


73, Eric   WA6HHQ
-


David Woolley wrote:

Toby Deinhardt wrote:


  No CE mark seen but I dont think it needs one in Kit form.

For the kit version likely not, but, afaik, anyone who ordered an 


Although it might be technically legal (speculation), I very much 
doubt  that the kit exemption envisaged a pre-aligned sub-assembly 
kit, like the K3.  As far as I remember, the equivalent position for 
PCs is that board level components have to have individual EMC 
certification. 


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Re: [Elecraft] [K3] CE Mark

2007-11-06 Thread Eric Swartz - WA6HHQ, Elecraft

Hi David,

I agree with this point too. All of the components of the K3 are 
designed only for use inside that radio and not as general general 
options for other manufacturer's products. The boards are not stand 
alone products.


73, Eric  WA6HHQ


David Cutter wrote:
An interesting parallel with home-build PCs, but the difference is 
that PC boards are sold separately on the open market and in theory 
can be connected with many other manufacturers' boards to make up a 
system; as such I would interpret them as products within their own 
right. The K3 boards are not on the open market as products, they are 
only viable when coupled together, ie unique to the final unit which 
is the K3.  This is a kit of unique parts for one use,  not a 
collection of various manufacturers' products.   IMHO.


David
G3UNA


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Re: [Elecraft] [K3] CE Mark

2007-11-06 Thread David Ferrington, M0XDF
In what way do you envision?
Its reached at least one 'G' now - I don't care about CE at all - it isn't
worth the paper its printed (or often not) on.
I've come across quite a lot of imported gear with a CE - no way does it
meet even the most basic standard.

Sorry, this came out confrontational - its not meant to be. But frankly - I
just want my K3 and I don't care about 'useless' certification.


On 6/11/07 21:50, Toby Deinhardt [EMAIL PROTECTED] sent:
 It would be a real pity if this creates problems for anyone on our side
 of the the Atlantic.
-- 
A bit of fragrance always clings to the hand that gives the rose.
-Chinese proverb


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Re: [Elecraft] [K3] CE Mark

2007-11-06 Thread Toby Deinhardt

Hallo David,

AFAIK, you as the importer of electronic devices are responsible for 
conformity with EU regulations, whether they make sense or not. It is 
easy to imagine an official, with nothing better to do, causing serious 
problems for the importer of said equipment.


A lot of what is in the CE marking requirements, imvho, make good sense, 
but there is no real mechanism to enforce them, especially because the 
CE Marking uses a self certification system. It is far too easy for 
producers and/or European importers/distributors to fudge on their 
certification and conformity. Which, as you correctly noted, often makes 
the CE Marking almost worthless.



Sorry, this came out confrontational - its not meant to be. But frankly - I
just want my K3 and I don't care about 'useless' certification.


I also want my K3 (kit) but would hate to see Elecraft and/or Elecraft's 
customers run into any problems, just because a CE Marking was missing.


vy 73 de toby

PS: I am not a lawyer, so any and all of the above could be wildly false.

PPS: I did not take your mail as confrontational. No worries here.
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Re: [Elecraft] [K3] CE Marking, Update Software

2007-10-13 Thread David Woolley

Julian G4ILO wrote:

bands permitted in the destination country. There is nothing to stop
anyone constructing a transmitter that can transmit on any frequency,
therefore it is illogical to restrict a kit simply because the design
has the capability to do so.


But, on my reading of admittedly confusing wording [A], that is what the 
UK amateur radio licence does do so for use by Foundation licensees.  It 
doesn't, in itself, restrict possession [B], or construction.


Whilst constructing a transceiver probably isn't illegal for an 
unlicensed user, there are many things that require relatively limited 
technology (firearms, drugs) that are illegal even to produce without a 
licence, that may have very limited issue.




Such restrictions interfere with the ability of operators who wish to
take their radios abroad to operate in countries where different


Only full licence holders can do this without getting an independent 
licence from the foreign country.



limits apply. They also restrict the ability to use radios to generate
low levels of RF on other frequencies for test purposes, e.g. as a
stable signal generator.

Of course, where countries impose import restrictions on built
equipment that require such restrictions there is nothing that can be
done about it. But why enforce limitations where they are not


Whilst one would need to consult a lawyer to be sure of the actual legal 
position, which may well have a loop hole, I don't think the amateur 
radio kit exemption to the CE marking rule was ever intended to cover 
the K3 case.  It was intended to cover the case where actual compliance 
is, to a significant extent, dependent on the builder.  One of the K3 
kit's selling points is that this is not the case.  I think it also 
exists because the self training element of amateur radio is considered 
desirable, and learning the ability to create something compliant from 
parts which are not intrinsically compliant is part of that self 
training.  Being able to assemble an Ikea book case doesn't really make 
you a trainee cabinet maker.


If there is a loop hole, it is better that Elecraft not exploit it 
because exploited loopholes generally get closed in the next round of 
legislation after the legislators become aware of them.



required? Back when I was first licensed, analogue VFOs were not able
to be strictly confined within the licensed band, and operators were
expected to use a crystal calibrator to ensure that they stayed within


Back when you were first licensed, there was no Foundation licence.

[A] The current licence restricts kits constructed by Foundation users 
to those which satisfy the interface definition for amateur radio 
equipment for CE marking purposes.  As that definition is just a 
schedule of frequencies, etc., like that in the back of the licence, not 
a statement of requirements, one has to try and work out what the, 
presumably junior, drafter actually intended.


Especially if one considers earlier versions of the licence, which don't 
rely on references to external documents, I believe that the intent is 
that the only allowed kits for that class of licence are those which are 
designed to be incapable of operating outside the parameters in the 
interface definition.


The 2003 version of the Foundation Licence 
http://www.ofcom.org.uk/static/archive/ra/publication/ra_info/br68f/br68f.htmuses 
the following wording, which clearly indicates the kit must be designed 
for amateur bands only use:


 4(1) The Licensee shall only use transmitting equipment conforming
  to EC standards *or commercially available kits transmitting
  inside amateur bands only*.

(I believe there is a legal principle that every word counts, so the 
inside amateur bands only must refer to the kits, not the operation, 
as that restriction is imposed on operation elsewhere in the licence 
(2(1)a).)


I believe the satisfy IR 2028 part of the current licence is an 
attempt by someone at a more formal definition of the amateur bands only 
requirement.


[B] I think the Wireless Telegraphy Act may restrict possession with 
intent to use, but I doubt that many cases are brought - if they are it 
is probably more likely for radar detectors, or when some other 
equipment was proven to be used illegally.  (See 
http://www.legislation.gov.uk/acts/en2003/03en21-h.htm for an indirect 
reference.)  One presumes that the intent being to do so only after 
upgrading the licence would be a valid defence.


I am not a lawyer, so this is not legal advice.


--
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Re: [Elecraft] [K3] CE Marking, Update Software

2007-10-13 Thread Julian G4ILO
Well, you may be strictly right David, but I'm a free marketeer, I
believe in less state control and regulation. I believe that the EU is
a bureaucratic nightmare that adds to business costs and benefits
no-one except the fat cat bureaucrats on the EU payroll. If a loophole
exists I say exploit it while it's there. I say exactly the same to my
accountant. :)

We in the UK would be better off out of the EU anyway. We are far
closer, culturally and commercially, to the USA than to Europe. But
let's not argue about that on this reflector. (The Lounge over at
Zerobeat Forums would be an acceptable place, if you really want to.)

-- 
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf


On 10/13/07, David Woolley [EMAIL PROTECTED] wrote:

 If there is a loop hole, it is better that Elecraft not exploit it
 because exploited loopholes generally get closed in the next round of
 legislation after the legislators become aware of them.


and a lot more.
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Re: [Elecraft] [K3] CE Marking, Update Software

2007-10-12 Thread Julian G4ILO
Supplementary question: If the answer to 1 is No, what will be the
impact of this on those of us from EU who have ordered kits, for which
I understand CE marking is not required (not that anyone in the UK
seems to bother about CE marking even for built stuff - see earlier
thread.) Will products be shipped to EU in the same order that orders
were placed, or will there be an extra delay in shipping?

-- 
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Ham-Directory: www.ham-directory.com


On 10/12/07, Toby Deinhardt [EMAIL PROTECTED] wrote:


 1) Does the K3 have a CE marking (yet)?

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Re: [Elecraft] [K3] CE Marking, Update Software

2007-10-12 Thread David Pratt

In a recent message, Julian G4ILO [EMAIL PROTECTED] wrote ...

Will products be shipped to EU in the same order that orders
were placed, or will there be an extra delay in shipping?


One of my concerns, Julian, is the possible delays caused by Elecraft 
customising each K3 for its destination country.


For example, in the UK our 40 metre band is 7000-7200kHz and NoV permit 
holders for 60 metres have seven minibands of which only three are 
common with the USA. We can also use narrow modes on 60 metres.


I should like to know whether these differences will have any impact on 
the despatch of the K3s to countries outside the USA.


73
--
David G4DMP
Leeds, England, UK
--


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Re: [Elecraft] [K3] CE Marking, Update Software

2007-10-12 Thread Julian G4ILO
I agree. I made the point, several months ago, that kit versions at
least should not have the transmit capabilities restricted to the
bands permitted in the destination country. There is nothing to stop
anyone constructing a transmitter that can transmit on any frequency,
therefore it is illogical to restrict a kit simply because the design
has the capability to do so.

Such restrictions interfere with the ability of operators who wish to
take their radios abroad to operate in countries where different
limits apply. They also restrict the ability to use radios to generate
low levels of RF on other frequencies for test purposes, e.g. as a
stable signal generator.

Of course, where countries impose import restrictions on built
equipment that require such restrictions there is nothing that can be
done about it. But why enforce limitations where they are not
required? Back when I was first licensed, analogue VFOs were not able
to be strictly confined within the licensed band, and operators were
expected to use a crystal calibrator to ensure that they stayed within
the band limits. It seems like another area where the nanny state
has gone too far.

-- 
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Ham-Directory: www.ham-directory.com


On 10/12/07, David Pratt [EMAIL PROTECTED] wrote:

 One of my concerns, Julian, is the possible delays caused by Elecraft
 customising each K3 for its destination country.
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