Robert said: >With no revenue, it is an exhibition, a test. What if a company decided to give away a thousand radiocommunications devices in London, and set up the required infrastructure to make them work, all for free?
No revenue - but the devices sure did get put into service. Article 7.1 says this should happen only if the product complies with the essential requirements. It's my interpretation that a Beta test is 'putting into service'. Perhaps that's due to my experience - WLAN's - where a Beta test would be a large installation complete with Access Points, and (at least) dozens of clients. Hard to call that anything other than 'putting into service'. A customer agreeing to be a Beta test site probably would also be purchasing the equipment eventually, if not right away. Often equipment installed for beta test is left in service at the site. I'll grant you that Article 8.2 might be interpreted to include beta testing (call it a demonstration?), but I think beta testing will usually violate the spirit if not the text of the article. The article is intended to allow sales/promotional activities in advance of compliance. I think it also depends on how one defines 'beta test'. I'd like to hear how others interpret the RTTED on this point. It's a grey area, for sure. Doug Massey Lead Regulatory Engineer LXE, Inc. -----Original Message----- From: Robert Macy [mailto:m...@california.com] Sent: Thursday, December 27, 2001 9:56 AM To: Massey, Doug C.; IEEE - PSTC FORUM (E-mail) Subject: Re: Non-compliant product put into EU marked Wow! I've been telling clients that even a Beta test is allowed, as long as absolutely no revenue is derived from it. Can't sell it. Can't rent it. With no revenue, it is an exhibition, a test. Is this wrong? - Robert - Robert A. Macy, PE m...@california.com 408 286 3985 fx 408 297 9121 AJM International Electronics Consultants 619 North First St, San Jose, CA 95112 -----Original Message----- From: Massey, Doug C. <masse...@ems-t.com> To: IEEE - PSTC FORUM (E-mail) <emc-p...@majordomo.ieee.org> List-Post: emc-pstc@listserv.ieee.org Date: Thursday, December 27, 2001 6:20 AM Subject: RE: Non-compliant product put into EU marked > >Article 8.2 of the RTTED (1999/5/EC) allows exemptions for ".. trade fairs, >exhibitions, demonstrations, etc.". It also requires that a "visible sign >clearly indicates that such apparatus may not be marketed or put into >service until it has been made to comply." > >Beta testing at a customer site does not fall under the Art. 8.2 exemptions. >A sales team demonstrating the product to a customer could be exempt for the >period of their demonstration. However, you can't call a large scale Beta >test a demonstration - the Beta test is 'putting into service'. > >IMHO, it's in clear violation of the RTTED. > >Doug Massey >Lead Regulatory Engineer >LXE, Inc. > >-----Original Message----- >From: am...@westin-emission.no [mailto:am...@westin-emission.no] >Sent: Monday, December 17, 2001 5:05 PM >To: emc-p...@majordomo.ieee.org >Subject: SV: Non-compliant product put into EU marked > > > >As far as I know the product shall be produced in a large scale. The reason >for putting it on the marked for a time limiting period is (again as far as >I know) to run the product ( beta version) in a test installation and >thereafter will it go through the entire test program (EMC, LVD, etc). It >seems that they did not manage to do the testing before the 1 month test >period on the field. > >Again, I feel they are not doing things in the consecutive order and I also >think they are no allowed to put in on the marked, even the short period. > >Amund > >-----Opprinnelig melding----- >Fra: Tania Grant [mailto:taniagr...@msn.com] >Sendt: 17. desember 2001 19:33 >Til: am...@westin-emission.no; emc-p...@majordomo.ieee.org >Emne: Re: Non-compliant product put into EU marked > > >Is the manufacturer serious, or completely ignorant? > >If serious, I would disassociate from them as much as possible. If merely >ignorant, and you have some sort of association with them, I would recommend >that you educate them fully. > >Another thought, -- is this product slated for mass distribution, even for >only a month, or is it going to another location or a particular customer >for some special in-house use or application? What does this customer >think? Are they aware, and do they agree to this? The Directives do have >special provisions for certain special applications where non-compliant (or >is it merely "untested" !) product can be shipped to Europe, but I believe >that under those circumstances, the name of the manufacturer and product >model name or designation has to be "published" broadly in the EU. I don't >remember the details. If anyone can shed more light, that would be very >nice. > >taniagr...@msn.com > >----- Original Message ----- >From: <am...@westin-emission.no> >To: <emc-p...@majordomo.ieee.org> >Sent: Sunday, December 16, 2001 2:06 PM >Subject: Non-compliant product put into EU marked > > >> >> Hi all, >> >> You place a radio product into the EU marked with the following status: >> >> - Not been EMC, radio or safety tested (the previous model was tested and >> compliant, major modifications have later been implemented) >> - The product will only be in the marked for a time limiting period ( 1 >> month) >> - During the time limiting period it will be operating as in a normal >> condition >> - No CE mark on the product and no DoC >> >> I mean that you can't do this. You have to confirm that you fulfil the >EMC, >> radio and safety requirements, DoC in place, even that the product just >will >> be in the marked for 1 month and thereafter withdrawal. >> >> Any other comments from the list members ? >> >> Best regards >> Amund Westin, Oslo/Norway >> >> ------------------------------------------- This message is from the IEEE EMC Society Product Safety Technical Committee emc-pstc discussion list. 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