RE: Non-compliant product put into EU marked
Robert said: With no revenue, it is an exhibition, a test. What if a company decided to give away a thousand radiocommunications devices in London, and set up the required infrastructure to make them work, all for free? No revenue - but the devices sure did get put into service. Article 7.1 says this should happen only if the product complies with the essential requirements. It's my interpretation that a Beta test is 'putting into service'. Perhaps that's due to my experience - WLAN's - where a Beta test would be a large installation complete with Access Points, and (at least) dozens of clients. Hard to call that anything other than 'putting into service'. A customer agreeing to be a Beta test site probably would also be purchasing the equipment eventually, if not right away. Often equipment installed for beta test is left in service at the site. I'll grant you that Article 8.2 might be interpreted to include beta testing (call it a demonstration?), but I think beta testing will usually violate the spirit if not the text of the article. The article is intended to allow sales/promotional activities in advance of compliance. I think it also depends on how one defines 'beta test'. I'd like to hear how others interpret the RTTED on this point. It's a grey area, for sure. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: Robert Macy [mailto:m...@california.com] Sent: Thursday, December 27, 2001 9:56 AM To: Massey, Doug C.; IEEE - PSTC FORUM (E-mail) Subject: Re: Non-compliant product put into EU marked Wow! I've been telling clients that even a Beta test is allowed, as long as absolutely no revenue is derived from it. Can't sell it. Can't rent it. With no revenue, it is an exhibition, a test. Is this wrong? - Robert - Robert A. Macy, PEm...@california.com 408 286 3985 fx 408 297 9121 AJM International Electronics Consultants 619 North First St, San Jose, CA 95112 -Original Message- From: Massey, Doug C. masse...@ems-t.com To: IEEE - PSTC FORUM (E-mail) emc-p...@majordomo.ieee.org List-Post: emc-pstc@listserv.ieee.org Date: Thursday, December 27, 2001 6:20 AM Subject: RE: Non-compliant product put into EU marked Article 8.2 of the RTTED (1999/5/EC) allows exemptions for .. trade fairs, exhibitions, demonstrations, etc.. It also requires that a visible sign clearly indicates that such apparatus may not be marketed or put into service until it has been made to comply. Beta testing at a customer site does not fall under the Art. 8.2 exemptions. A sales team demonstrating the product to a customer could be exempt for the period of their demonstration. However, you can't call a large scale Beta test a demonstration - the Beta test is 'putting into service'. IMHO, it's in clear violation of the RTTED. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: am...@westin-emission.no [mailto:am...@westin-emission.no] Sent: Monday, December 17, 2001 5:05 PM To: emc-p...@majordomo.ieee.org Subject: SV: Non-compliant product put into EU marked As far as I know the product shall be produced in a large scale. The reason for putting it on the marked for a time limiting period is (again as far as I know) to run the product ( beta version) in a test installation and thereafter will it go through the entire test program (EMC, LVD, etc). It seems that they did not manage to do the testing before the 1 month test period on the field. Again, I feel they are not doing things in the consecutive order and I also think they are no allowed to put in on the marked, even the short period. Amund -Opprinnelig melding- Fra: Tania Grant [mailto:taniagr...@msn.com] Sendt: 17. desember 2001 19:33 Til: am...@westin-emission.no; emc-p...@majordomo.ieee.org Emne: Re: Non-compliant product put into EU marked Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant
Re: Non-compliant product put into EU marked
I read in !emc-pstc that Robert Macy m...@california.com wrote (in 000e01c18ee6$984ba0c0$8be10...@robert.macy.california.com) about 'Non- compliant product put into EU marked', on Thu, 27 Dec 2001: Wow! I've been telling clients that even a Beta test is allowed, as long as absolutely no revenue is derived from it. Can't sell it. Can't rent it. With no revenue, it is an exhibition, a test. Is this wrong? Yes, it is wrong. An extensive beta test means putting into the field numerous samples of a product which may be unsafe and/or may cause interference to safety-of-life systems. The exemption for exhibitions etc. is on the balance of probability that ONE unit is unlikely to cause a problem. This is the implication of the Directive wording about 'taking into service', which stands *in parallel* with 'placing on the market'. In other words, if you do EITHER of those things, the Directive applies. -- Regards, John Woodgate, OOO - Own Opinions Only. http://www.jmwa.demon.co.uk After swimming across the Hellespont, I felt like a Hero. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
Re: Non-compliant product put into EU marked
Wow! I've been telling clients that even a Beta test is allowed, as long as absolutely no revenue is derived from it. Can't sell it. Can't rent it. With no revenue, it is an exhibition, a test. Is this wrong? - Robert - Robert A. Macy, PEm...@california.com 408 286 3985 fx 408 297 9121 AJM International Electronics Consultants 619 North First St, San Jose, CA 95112 -Original Message- From: Massey, Doug C. masse...@ems-t.com To: IEEE - PSTC FORUM (E-mail) emc-p...@majordomo.ieee.org List-Post: emc-pstc@listserv.ieee.org Date: Thursday, December 27, 2001 6:20 AM Subject: RE: Non-compliant product put into EU marked Article 8.2 of the RTTED (1999/5/EC) allows exemptions for .. trade fairs, exhibitions, demonstrations, etc.. It also requires that a visible sign clearly indicates that such apparatus may not be marketed or put into service until it has been made to comply. Beta testing at a customer site does not fall under the Art. 8.2 exemptions. A sales team demonstrating the product to a customer could be exempt for the period of their demonstration. However, you can't call a large scale Beta test a demonstration - the Beta test is 'putting into service'. IMHO, it's in clear violation of the RTTED. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: am...@westin-emission.no [mailto:am...@westin-emission.no] Sent: Monday, December 17, 2001 5:05 PM To: emc-p...@majordomo.ieee.org Subject: SV: Non-compliant product put into EU marked As far as I know the product shall be produced in a large scale. The reason for putting it on the marked for a time limiting period is (again as far as I know) to run the product ( beta version) in a test installation and thereafter will it go through the entire test program (EMC, LVD, etc). It seems that they did not manage to do the testing before the 1 month test period on the field. Again, I feel they are not doing things in the consecutive order and I also think they are no allowed to put in on the marked, even the short period. Amund -Opprinnelig melding- Fra: Tania Grant [mailto:taniagr...@msn.com] Sendt: 17. desember 2001 19:33 Til: am...@westin-emission.no; emc-p...@majordomo.ieee.org Emne: Re: Non-compliant product put into EU marked Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant product put into EU marked Hi all, You place a radio product into the EU marked with the following status: - Not been EMC, radio or safety tested (the previous model was tested and compliant, major modifications have later been implemented) - The product will only be in the marked for a time limiting period ( 1 month) - During the time limiting period it will be operating as in a normal condition - No CE mark on the product and no DoC I mean that you can't do this. You have to confirm that you fulfil the EMC, radio and safety requirements, DoC in place, even that the product just will be in the marked for 1 month and thereafter withdrawal. Any other comments from the list members ? Best regards Amund Westin, Oslo/Norway --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
RE: Non-compliant product put into EU marked
Article 8.2 of the RTTED (1999/5/EC) allows exemptions for .. trade fairs, exhibitions, demonstrations, etc.. It also requires that a visible sign clearly indicates that such apparatus may not be marketed or put into service until it has been made to comply. Beta testing at a customer site does not fall under the Art. 8.2 exemptions. A sales team demonstrating the product to a customer could be exempt for the period of their demonstration. However, you can't call a large scale Beta test a demonstration - the Beta test is 'putting into service'. IMHO, it's in clear violation of the RTTED. Doug Massey Lead Regulatory Engineer LXE, Inc. -Original Message- From: am...@westin-emission.no [mailto:am...@westin-emission.no] Sent: Monday, December 17, 2001 5:05 PM To: emc-p...@majordomo.ieee.org Subject: SV: Non-compliant product put into EU marked As far as I know the product shall be produced in a large scale. The reason for putting it on the marked for a time limiting period is (again as far as I know) to run the product ( beta version) in a test installation and thereafter will it go through the entire test program (EMC, LVD, etc). It seems that they did not manage to do the testing before the 1 month test period on the field. Again, I feel they are not doing things in the consecutive order and I also think they are no allowed to put in on the marked, even the short period. Amund -Opprinnelig melding- Fra: Tania Grant [mailto:taniagr...@msn.com] Sendt: 17. desember 2001 19:33 Til: am...@westin-emission.no; emc-p...@majordomo.ieee.org Emne: Re: Non-compliant product put into EU marked Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant product put into EU marked Hi all, You place a radio product into the EU marked with the following status: - Not been EMC, radio or safety tested (the previous model was tested and compliant, major modifications have later been implemented) - The product will only be in the marked for a time limiting period ( 1 month) - During the time limiting period it will be operating as in a normal condition - No CE mark on the product and no DoC I mean that you can't do this. You have to confirm that you fulfil the EMC, radio and safety requirements, DoC in place, even that the product just will be in the marked for 1 month and thereafter withdrawal. Any other comments from the list members ? Best regards Amund Westin, Oslo/Norway --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until
SV: Non-compliant product put into EU marked
Lazy... yes maybe or they might have trouble with coordination of the different processes as development, pre-tests, development, final tests, all files completed, ship it to the marked, etc But I assume that they will not put it into the marked, because they are not allowed. So they might be lazy but they won't get trouble with the authorities. Amund -Opprinnelig melding- Fra: John Juhasz [mailto:jjuh...@fiberoptions.com] Sendt: 17. desember 2001 20:55 Til: 'Tania Grant'; am...@westin-emission.no; emc-p...@majordomo.ieee.org Emne: RE: Non-compliant product put into EU marked Hmmm . . . Sounds to me that due to the limited marketing of the product, the manufacturer doesn't want to absorb the expense of compliance testing. Generally speaking, while a compliant test report (especially from a good independent lab)holds weight, as has been noted on several occassions testing is not the only route. Can the manufacturer produce justification that the original compliance has not been affected by the modifications? It doesn't appear to me that the manufacturer is TOTALLY ignorant, just lazy. As they are not applying the mark, they cannot be accused of falsley claiming compliance - but that doesn't absolve them from having to comply with the Directives applicable to their product. IMHO they're playing with fire . . . John Juhasz Fiber Options Bohemia, NY (The opinions expressed here, for what they're worth, are mine alone) -Original Message- From: Tania Grant [mailto:taniagr...@msn.com] Sent: Monday, December 17, 2001 1:33 PM To: am...@westin-emission.no; emc-p...@majordomo.ieee.org Subject: Re: Non-compliant product put into EU marked Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant product put into EU marked Hi all, You place a radio product into the EU marked with the following status: - Not been EMC, radio or safety tested (the previous model was tested and compliant, major modifications have later been implemented) - The product will only be in the marked for a time limiting period ( 1 month) - During the time limiting period it will be operating as in a normal condition - No CE mark on the product and no DoC I mean that you can't do this. You have to confirm that you fulfil the EMC, radio and safety requirements, DoC in place, even that the product just will be in the marked for 1 month and thereafter withdrawal. Any other comments from the list members ? Best regards Amund Westin, Oslo/Norway --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable
SV: Non-compliant product put into EU marked
Special temporary authorization or experimental license sounds good to me, but in this case it is only a regular radio equipment which has been re-designed and installed in a well known radio system. But I agree and ask the same question as you do Don, is there a route for special temporary authorization or experimental license for a specific customer location? Amund -Opprinnelig melding- Fra: djumbdenst...@tycoint.com [mailto:djumbdenst...@tycoint.com] Sendt: 17. desember 2001 22:37 Til: am...@westin-emission.no; emc-p...@majordomo.ieee.org; taniagr...@msn.com Emne: RE: Non-compliant product put into EU marked Is there a route for special temporary authorization or experimental license for a specific customer location? This may be on a spectrum authority (SA) by SA basis. Just do it! may be a fine logo for selling shoes, but does not work in legal arenas. Don Umbdenstock Sensormatic Electronics Tyco International -- From: Tania Grant[SMTP:taniagr...@msn.com] Reply To: Tania Grant Sent: Monday, December 17, 2001 1:33 PM To: am...@westin-emission.no; emc-p...@majordomo.ieee.org Subject: Re: Non-compliant product put into EU marked Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant product put into EU marked Hi all, You place a radio product into the EU marked with the following status: - Not been EMC, radio or safety tested (the previous model was tested and compliant, major modifications have later been implemented) - The product will only be in the marked for a time limiting period ( 1 month) - During the time limiting period it will be operating as in a normal condition - No CE mark on the product and no DoC I mean that you can't do this. You have to confirm that you fulfil the EMC, radio and safety requirements, DoC in place, even that the product just will be in the marked for 1 month and thereafter withdrawal. Any other comments from the list members ? Best regards Amund Westin, Oslo/Norway --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription
SV: Non-compliant product put into EU marked
As far as I know the product shall be produced in a large scale. The reason for putting it on the marked for a time limiting period is (again as far as I know) to run the product ( beta version) in a test installation and thereafter will it go through the entire test program (EMC, LVD, etc). It seems that they did not manage to do the testing before the 1 month test period on the field. Again, I feel they are not doing things in the consecutive order and I also think they are no allowed to put in on the marked, even the short period. Amund -Opprinnelig melding- Fra: Tania Grant [mailto:taniagr...@msn.com] Sendt: 17. desember 2001 19:33 Til: am...@westin-emission.no; emc-p...@majordomo.ieee.org Emne: Re: Non-compliant product put into EU marked Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant product put into EU marked Hi all, You place a radio product into the EU marked with the following status: - Not been EMC, radio or safety tested (the previous model was tested and compliant, major modifications have later been implemented) - The product will only be in the marked for a time limiting period ( 1 month) - During the time limiting period it will be operating as in a normal condition - No CE mark on the product and no DoC I mean that you can't do this. You have to confirm that you fulfil the EMC, radio and safety requirements, DoC in place, even that the product just will be in the marked for 1 month and thereafter withdrawal. Any other comments from the list members ? Best regards Amund Westin, Oslo/Norway --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
RE: Non-compliant product put into EU marked
Is there a route for special temporary authorization or experimental license for a specific customer location? This may be on a spectrum authority (SA) by SA basis. Just do it! may be a fine logo for selling shoes, but does not work in legal arenas. Don Umbdenstock Sensormatic Electronics Tyco International -- From: Tania Grant[SMTP:taniagr...@msn.com] Reply To: Tania Grant Sent: Monday, December 17, 2001 1:33 PM To: am...@westin-emission.no; emc-p...@majordomo.ieee.org Subject: Re: Non-compliant product put into EU marked Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant product put into EU marked Hi all, You place a radio product into the EU marked with the following status: - Not been EMC, radio or safety tested (the previous model was tested and compliant, major modifications have later been implemented) - The product will only be in the marked for a time limiting period ( 1 month) - During the time limiting period it will be operating as in a normal condition - No CE mark on the product and no DoC I mean that you can't do this. You have to confirm that you fulfil the EMC, radio and safety requirements, DoC in place, even that the product just will be in the marked for 1 month and thereafter withdrawal. Any other comments from the list members ? Best regards Amund Westin, Oslo/Norway --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
RE: Non-compliant product put into EU marked
Hmmm . . . Sounds to me that due to the limited marketing of the product, the manufacturer doesn't want to absorb the expense of compliance testing. Generally speaking, while a compliant test report (especially from a good independent lab)holds weight, as has been noted on several occassions testing is not the only route. Can the manufacturer produce justification that the original compliance has not been affected by the modifications? It doesn't appear to me that the manufacturer is TOTALLY ignorant, just lazy. As they are not applying the mark, they cannot be accused of falsley claiming compliance - but that doesn't absolve them from having to comply with the Directives applicable to their product. IMHO they're playing with fire . . . John Juhasz Fiber Options Bohemia, NY (The opinions expressed here, for what they're worth, are mine alone) -Original Message- From: Tania Grant [mailto:taniagr...@msn.com] Sent: Monday, December 17, 2001 1:33 PM To: am...@westin-emission.no; emc-p...@majordomo.ieee.org Subject: Re: Non-compliant product put into EU marked Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant product put into EU marked Hi all, You place a radio product into the EU marked with the following status: - Not been EMC, radio or safety tested (the previous model was tested and compliant, major modifications have later been implemented) - The product will only be in the marked for a time limiting period ( 1 month) - During the time limiting period it will be operating as in a normal condition - No CE mark on the product and no DoC I mean that you can't do this. You have to confirm that you fulfil the EMC, radio and safety requirements, DoC in place, even that the product just will be in the marked for 1 month and thereafter withdrawal. Any other comments from the list members ? Best regards Amund Westin, Oslo/Norway --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
Re: Non-compliant product put into EU marked
Is the manufacturer serious, or completely ignorant? If serious, I would disassociate from them as much as possible. If merely ignorant, and you have some sort of association with them, I would recommend that you educate them fully. Another thought, -- is this product slated for mass distribution, even for only a month, or is it going to another location or a particular customer for some special in-house use or application? What does this customer think? Are they aware, and do they agree to this? The Directives do have special provisions for certain special applications where non-compliant (or is it merely untested !) product can be shipped to Europe, but I believe that under those circumstances, the name of the manufacturer and product model name or designation has to be published broadly in the EU. I don't remember the details. If anyone can shed more light, that would be very nice. taniagr...@msn.com - Original Message - From: am...@westin-emission.no To: emc-p...@majordomo.ieee.org Sent: Sunday, December 16, 2001 2:06 PM Subject: Non-compliant product put into EU marked Hi all, You place a radio product into the EU marked with the following status: - Not been EMC, radio or safety tested (the previous model was tested and compliant, major modifications have later been implemented) - The product will only be in the marked for a time limiting period ( 1 month) - During the time limiting period it will be operating as in a normal condition - No CE mark on the product and no DoC I mean that you can't do this. You have to confirm that you fulfil the EMC, radio and safety requirements, DoC in place, even that the product just will be in the marked for 1 month and thereafter withdrawal. Any other comments from the list members ? Best regards Amund Westin, Oslo/Norway --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server. --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
Non-compliant product put into EU marked
Hi all, You place a radio product into the EU marked with the following status: - Not been EMC, radio or safety tested (the previous model was tested and compliant, major modifications have later been implemented) - The product will only be in the marked for a time limiting period ( 1 month) - During the time limiting period it will be operating as in a normal condition - No CE mark on the product and no DoC I mean that you can't do this. You have to confirm that you fulfil the EMC, radio and safety requirements, DoC in place, even that the product just will be in the marked for 1 month and thereafter withdrawal. Any other comments from the list members ? Best regards Amund Westin, Oslo/Norway --- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/ To cancel your subscription, send mail to: majord...@ieee.org with the single line: unsubscribe emc-pstc For help, send mail to the list administrators: Michael Garretson:pstc_ad...@garretson.org Dave Healddavehe...@mediaone.net For policy questions, send mail to: Richard Nute: ri...@ieee.org Jim Bacher: j.bac...@ieee.org All emc-pstc postings are archived and searchable on the web at: No longer online until our new server is brought online and the old messages are imported into the new server.
