A contact was made with DG III concerning the R&TTE Directive. The questions and the reply are listed below. In reference to his last remark, why is there now controversy over the definition of "placing on the market" after the term was clearly defined by the Commission in two explanatory documents on the EMC Directive?
> 1) Is there a transition period during which products which meet existing regulatory requirements can continue to be sold? They can continue to be placed on the market (but not be type approved anymore according such rules after 8/4/2000). > 2) Is it necessary to upgrade products which are already placed on the market before April 2000 but will not be put into use by end users until after that date? No. There is a small legal interpretation issue to be resolved in this context: what is the meaning of placing on the market? Some people argue it relates to product types, others to individual products. we are currently studying this issue. It has consequences for the practical implications of the above. If it relates to products, then all products sold after 8/4/2001 should be compliant with the R&TTE Directive, even those type approved before 8/4/2000.
