Richard, Per section 7.2.1.1 of the latest Guidelines on the Application of the EMC Directive you would only have to comply with the EMC directive if you were bringing the equipment up to "as-new" status. That is, if you made the equipment competitive with new devices used for the same purpose. Otherwise the updated old equipment could have a competitive advantage partly because it would not need to comply. This same section does, however, suggest that you be ready to justify your decision in case you're ever challenged.
Dick Shultz Complinace & Approvals Manager Brooktrout Technology, Inc. On 3/17/98 9:11 AM Richard Cass <richard_c...@iris.scitex.com> said: > Greetings, > We have a situation where we have ITE equipment installed at a commercial > sites in the EU that were delivered before January 1, 1996. They do not > carry the CE mark. We are now working on some field retrofitable design > changes that can be installed in these "old" machines. The upgrade is done > by a service engineer and mostly involves exchanging circuit boards. It > will be economically impossible to make this upgrade of an old > configuration machine meet standards that would apply to new products > shipped to the EU today (e.g. EN50081 class B). My questions boil down to > these: > > 1.) Given that the specific machine was already placed in service in the EU > before 1/1/96, does this mean selling a customer this upgrade kit forces us > to meet the latest standards and then CE mark the product? > > 2.) Does the upgrade kit (a bunch of loose boards that do not function > outside our machine, other parts, and instructions in box) have to be CE > marked? > > I am pretty certain that the answer to 2 is NO and I am fairly certain > (which is less than pretty certain) that the answer to 1 is also NO. Can > anyone help me substantiate these answers or correct me if I am wrong? > > Thanks in advance for the usual insightful responses. > > Regards, > Richard Cass > Iris Graphics > Bedford,MA > USA > >
