At 01:10 PM 8/15/2008, David Forbes wrote: >Poul-Henning Kamp wrote: > >> > >> In the agreement with the Council, the European Parliament underlines > >> that importers must place only compliant products on the Community > >> market. Before placing a product on the market importers must ensure > >> that [...] > > > > The important thing in this clause is "placing a product on the market". > > > > As long as you import things directly into EU, and never sell them > > again, there is no requirement for CE marking. > > > >Poul, > >This is interesting. It means that I, as an American exporter >selling directly >to end customers in the EU, do NOT need to CE mark my American made products. > >-- David Forbes, Tucson AZ, Estados Unidos Americanos
Indeed... I believe that this is also an area where whether something is a kit or a "component destined for inclusion in other equipment" makes a difference. A significant fraction of the expense of getting regulatory approval (for a US RTL, for FCC, for CE, etc.) is actually doing the necessary research and analysis to determine just which standards are applicable, whether they need testing, etc. You can burn up $10K of labor pretty quickly in just writing up the appropriate declarations that "no, our product is exempt because x, and y, and z, in section a of regulation b, says so" Heck, just getting copies of the relevant standards could put a pretty big dent in $10K. As others have pointed out, this is particularly painful if you're a small quantity vendor of inexpensive widgets, since the paperwork handling cost is pretty much independent of the cost of the item being approved/certified/sanctified/exorcised/whathaveyou.. On the other hand, if you're actually PAYing for the engineering time, it might not be a huge fraction of the design and analysis time, except for trivial modifications to existing products that trigger recertification. Jim Lux _______________________________________________ time-nuts mailing list -- [email protected] To unsubscribe, go to https://www.febo.com/cgi-bin/mailman/listinfo/time-nuts and follow the instructions there.
