[PSES] Shipping into Europe - Basic question

2012-03-28 Thread Martin E. Cormier
Hello everyone, This will seem to many as a very basic question, but I am having a hard time finding clear information on this: If a non-European manufacturer wants to ship products to Europe, exclusively to another manufacturer/integrator, who will then put the products onto the market,

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Ian White (UK)
Martin, A couple of things come to mind about this they are : If the product is classified as a component / sub-assembly and not to be used by the end user there is no need for a CE mark under the EMC Directive. If a finished appliance is intended exclusively for an industrial assembly

[PSES] AW: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Frank Wermke
Hi Martin, only the integrator puts the complete product onto the market, after integrating them in a complete system that is CE marked. With regard to CE-marked before first entering Europe you have to distinguish between products and components. If the integrator integrates a product (that can

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread John Woodgate
In message 4f73067b.4040...@matrox.com, dated Wed, 28 Mar 2012, Martin E. Cormier mcorm...@matrox.com writes: If a non-European manufacturer wants to ship products to Europe, exclusively to another manufacturer/integrator, who will then put the products onto the market, after integrating them

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Martin E. Cormier
Thanks to everyone for their inputs, and they confirm the feeling I had. It just seems scary to me to try and pass customs with a pallet of PC Add-in boards that don't bear the CE logo. The products are not in a seperate housing, but could be compared to graphics adapters. They will not be

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Brian Oconnell
I am looking at an x-cap that is marked with 'CE'. I am looking at a relay that is marked 'CE'. I am looking at my mu-metal brain shield - no CE mark. Note that my Bugs Bunny tie, that was purchased in Europe, did not bear the CE mark on packaging or the end item. The people in the European part

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread John Woodgate
In message b7adc8fc5285487980d1706d9f805...@tamuracorp.com, dated Wed, 28 Mar 2012, Brian Oconnell oconne...@tamuracorp.com writes: I am looking at an x-cap that is marked with 'CE'. Wrong. I am looking at a relay that is marked 'CE'. If it's a 'simple' relay (how would one know?)

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread ce-test, qualified testing bv - Gert Gremmen
A PC add-in board is just one of the examples that need ce-mark. I hope you were just kiddin Gert Gremmen -Oorspronkelijk bericht- Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens Martin E. Cormier Verzonden: woensdag 28 maart 2012 16:50 Aan: emc-p...@ieee.org Onderwerp: Re:

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Martin E. Cormier
Oh! This is getting interesting... It was the exact pupose of my original question. We know that our regular products, i.e. the ones that may be put directly into market, have to be CE marked. But in this case, we would ship our add-in boards as components, only to a

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Crane, Lauren
Here is relevant guidance from the revised Commission guide to the EMC directive. plug-in boards are an example, but only those that are for incorporation into an apparatus by the end-user 1.2.3.1 Components/sub-assemblies within scope Components or sub-assemblies on the market which are: - for

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Charlie Blackham
Martin Your product as described is excluded from EMC directive. Look at the Guidance, available from http://ec.europa.eu/enterprise/sectors/electrical/documents/emc/guidance/index_en.htm 1.2.3.1 Components/sub-assemblies within scope Components or sub-assemblies on the market which are:

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Ron Pickard
To all, The key rests with the requirements of the EMC Directive and in its guidance document in that if this device could be considered as a finished assembly (apparatus) or not and if it is intended to be put on the market or placed into service (made available to the end user) or not. As

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Crane, Lauren
John, It seems possible the x-cap and relay manufacturer could be CE marking for the RoHS-2 Directive particularly if the items are offered for sale to anyone out of a catalog. The Commission has yet to issue guidance as to whether B2B component sales require CE marking for RoHS-2. Why is a

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Pete Perkins
Martin et al, You ask a very good question here... There has always been confusion on this subject. Unfortunately, the folks who developed the CE marking scheme didn't have enough experience with how equipment is built up from component pieces sources all over the

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread ce-test, qualified testing bv - Gert Gremmen
Right, but you have to be very sure in what to write down on your customs papers, to make sure they won't get blocked. Citing 1.2.3.2 is clearly not enough. Especially not if your device looks and feels like 1.3.2.1 Gert Gremmen -Oorspronkelijk bericht- Van: emc-p...@ieee.org

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread John Woodgate
In message e79b96282e4f9f43baf7c6d3d578acde0801e...@ca1exclv07.adcorp.kla-tencor.co m, dated Wed, 28 Mar 2012, Crane, Lauren lauren.cr...@kla-tencor.com writes: It seems possible the x-cap and relay manufacturer could be CE marking for the RoHS-2 Directive particularly if the items are

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread John Woodgate
In message 4f73476e.20...@matrox.com, dated Wed, 28 Mar 2012, Martin E. Cormier mcorm...@matrox.com writes: My understanding, up to now, was that in that case, the final manufacturer is responsible of declaring its product compliant. He would be putting the CE marking on the complete

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Crane, Lauren
I've experienced this (customs reacting to what an import looks like rather than what it is) a few times over my career. I'm beginning to wonder in this climate where so many details matter that may be beyond the reasonable knowledge of a customs inspector, if something like a declaration of

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread Brian Oconnell
My employer can provide a 'Certificate of Conformity', which can have a reference to a DoC and can state intended use; for some products it is displayed on the box. I have seen other companies do this for whatever customer requirement reasons. I propose an IECEE form for the Proclamation of the

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread John Woodgate
In message e79b96282e4f9f43baf7c6d3d578acde0801e...@ca1exclv07.adcorp.kla-tencor.co m, dated Wed, 28 Mar 2012, Crane, Lauren lauren.cr...@kla-tencor.com writes: if something like a declaration of purpose should be included with every shipment that would not otherwise have a declaration of

Re: [PSES] Shipping into Europe - Basic question

2012-03-28 Thread McInturff, Gary
I propose an IECEE form for the Proclamation of the Declaration of a Certification of Conformity. Why propose new documents when good old circular reasoning can solve the problem. Especially if the real problem is not necessarily complying with the directive but getting it past the customs

[PSES] receiving/approval processes under fire

2012-03-28 Thread Brian Oconnell
The siege is underway. The senior design engineers claim that, after conference with colleagues in other companies, many of my conformity requirements have never been required by their compliance people. Some of the receiving/approval processes that are in dispute: - CoC from plastic component

Re: [PSES] receiving/approval processes under fire

2012-03-28 Thread Richard Nute
Hi Brian: - CoC from plastic component supplier that is not recognized molder. I simply did not accept a non-recognized molder. If we want to use a non-recognized molder, I accept parts provided that the molder can provide documents showing he is in process of becoming a recognized molder.

Re: [PSES] receiving/approval processes under fire

2012-03-28 Thread Marko Radojicic
Hi Brian, Sounds like a fun time. :( Can't comment on any except: - EMC re-test for some changes of PCB layout. That is definitely a possibility but the change has to significantly change some EMC parameter - clock speed, edges, extra high-speed surface tracks, outside interface circuits,