>> you might as well have a cardboard box with knobs painted on. <<

If the FCC is "middle of the road" for enforcement, I would hate to think
what other countries might require.  Some time ago a firm here was fined by
the FCC for exhibiting an actual, non-operational equipment (missing parts)
without the proper labelling. Maybe cardboard boxes will need labels next. 


Seriously, we should remember the equipment need not meet the relevant
standards _during_ development, and adjust our expectations accordingly. 
If this means keeping a prototype unit turned off at an exhibition, maybe
that's the price we pay for getting it out the door quickly. And of course
we won't forget the proper labels either, will we?

Regards,

Cortland

====================== Original Message Follows ====================

 >> Date:  27-Sep-97 15:27:18  MsgID: 1055-61959  ToID: 72146,373
From:  Chris Dupres >INTERNET:chris_dup...@compuserve.com
Subj:  Re: CE & Demo Units f.u.
Chrg:  $0.00   Imp: Norm   Sens: Std    Receipt: No    Parts: 1

Martin et al...

Sorry about dragging this out a bit, but the comments :
<The answer for me was - yes, we can demo it even at the customer site. =
That system must be operated by our employees under all conditions. It mus=
t be labeled with a notice that it is not compliant and cannot be sold =
until it is made compliant. There is no time limit on demo / display =
systems as long as they are not operated by anuyone but our own =
employees.>

We need to remember that the EU Directives were born of the Treaty of Rome,
which is a treaty which relates to Trade, and removing barriers to Trade. 
EMC, LVD, Machinery, Low Pressure, Toys etc. etc.all have directives which
seek to level the playing field, and ensure that no one European Economic
Area (EEA) state gets a trading advantage over another EEA state by selling
products which have lower technical standards.  By adopting the same
standards (the Harmonised standards) all EEA states offer the same level of
basic technical performance in terms of intrinsic common impact
non-commercial characteristics like safety, EMC etc.

Demo units are not placed 'On the Market', but are 'Placed into Service',
which is an equally valid reason for compliance.  It follows that if you
knock up a bit of testgear for yourself, or a quick prototype for demo it
should comply, in as much as if it causes interference, or an electric
shock to a person or domestic animal, then an offence has been committed. 
The same with a prototype on an exhibition stand, or at a customers
facility, it should comply or have a bluddy good reason why not.  It need
not be CE marked however, which is the mechanism by which the 'Free Trade'
objectives are met, and clearly not relevant to something which will not be
traded.

I'm reliably informed that enforcement officers prowl exhibitions,
particularly in Germany, with equipment which will identify wild
non-compliers, and invite the equipment to be switched off, often with a
legal prohibition notice.  Prosecutions are unlikely, but if you can't
demonstrate it at an exhibition you might as well have a cardboard box with
knobs painted on.  In reality you are not likely to be 'caught' during a
customer demo, but your conscience may stop you sleeping......  :-)

I suppose the route to take is simple, if you are going to demonstrate
something at a customers site or an exhibition in the EEA, put screening,
filters and screened cables on everything, and point it out as a major
selling point.  "Even the prototype is CE compliant!".

A tuppence worth, maybe.

Chris Dupres
Surrey, UK.


**Primary Recipient:
  "MartinJP" INTERNET:marti...@perkin-elmer.com

====================== End of Original Message =====================

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