Alan, I believe that you are correct about Fujitsu retaining ownership of the equipment while on trial in Belgium, unless your customer wants to be the importer of record.
Enforcement of CE Marking requirements -- at least for the EMC, Low Voltage, and Machinery Directives -- is not a customs issue. The Directives state that CE Marking is required to place the equipment on the market or into service in the EU. Essentially this means that you can send anything electronic to Europe, CE or not, but it's a boat anchor until it's got a properly affixed CE Mark. You have to be careful, though. Some countries use customs as a watchdog. The two countries I know of that are friendly to the import of non-CE equipment are the UK and Germany. I have direct experience with the UK, and have the Germany information directly from the head of the BAPT in Mainz. Contact your customer. Their shipping department can help. You should be able to get the equipment into Belgium directly without CE. If not, you might be able to get it to Belgium through one of the other two countries mentioned. Furthermore, and relative to your NON-CE Compliant Fujitsu product in Australia, certainly send it through testing to the harmonized standards. But depending on what it is, be careful about extensive retrofits or redesigns to meet every clause. It's expensive, and in general not required to show that you meet the essential requirements. I have direct experience with Fujitsu (probably on non-related equipment). Their understanding of compliance with the Directives is based almost entirely on verbatim compliance with the Harmonized standards. While that is certainly a valid approach -- if you're in the design phases of product development -- it tends to fade in practicality when you're considering equipment that was not designed to meet the requirements of the harmonized standards in the first place. Comdisco specializes in leasing and remarketing equipment for the Semiconductor, Test and Measurement, Surface Mount Technology, Telecommunications, Information Technology, Laboratory and Scientific, and Medical Devices Industries. We get all the protection against the risks of non-compliance possible under the Directives and EU law WITHOUT redesign or retrofit to meet the standards by using them as a basis for compliance, but not the final word. It's not difficult, and it's not expensive. It IS, however, situational. For some products, like those intended for a non-descript, general, uncontrolled end-use environment (PCs, for example), the standards are probably the most appropriate route to compliance. For your particular case, there may be a better way. What's the equipment? What is the intended environment? If you're interested in knowing what your options are, contact me directly. I might be able to help you save some time and money. Hope this helps. Rick Towner, Regulatory Compliance Manager, Comdisco, Inc. Phone: 408-383-5043 Fax: 408-321-8314 e-mail: [email protected] ---------- |From: Alan Booth |To: RCTOWNER; treg |Subject: CE marking |Date: Wednesday, June 03, 1998 11:17AM | |Dear Treggers, | |Our Fujitsu colleagues in Australia have a non CE compliant product |which is being aimed at the Belgian market. | |The product is currently undergoing Safety and EMC testing in accordance |with European Directives in order that it can be CE marked and supplied |to the European market. | |Meanwhile field trials and demonstrations of the equipment are planned |in Belgium using non CE marked equipment. | |We have been informed that while the demonstration equipment is in |Belgium Fujitsu would have to retain ownership to ensure that supply of |the equipment has not taken place. | |What we are not sure about is whether Customs will allow non CE marked |equipment into Europe. | |Can anyone clarify this please? | |Regards, | |Alan Booth |Equipment Engineering Group |Fujitsu Telecommunications Europe Limited |Solihull Parkway |Birmingham Business Park |Birmingham |B37 7YU |Telephone +44 121 717 6492 |FAX +44 121 717 6014/6018 |
