Hmmm . . . 

Sounds to me that due to the limited marketing of the
product, the manufacturer doesn't want to absorb
the expense of compliance testing. 
Generally speaking, while a compliant test report
(especially from a good independent lab)holds
weight, as has been noted on several occassions
testing is not the only route. Can the manufacturer 
produce justification that the original compliance 
has not been affected by the modifications? 
It doesn't appear to me that the manufacturer is
TOTALLY ignorant, just lazy. As they are not
applying the mark, they cannot be accused of 
falsley claiming compliance - but that doesn't
absolve them from having to comply with the Directives
applicable to their product.

IMHO they're playing with fire . . .

John Juhasz
Fiber Options
Bohemia, NY 

(The opinions expressed here, for what they're worth, are
mine alone)


-----Original Message-----
From: Tania Grant [mailto:taniagr...@msn.com]
Sent: Monday, December 17, 2001 1:33 PM
To: am...@westin-emission.no; emc-p...@majordomo.ieee.org
Subject: 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
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