Hi Folks
I would take John's message below even further - as I think I stated
previously.
In the UK, the "Provision and Use of Work Equipment Regulations 1998"
("PUWER 1998") requires that employers shall ensure that all equipment used
at work shall comply with the relevant EU directives for safety - thus the
LVD, EMC directive, etc., and actual CE Marking may/ may not be required
according to the wording of the directive in question.
PUWER 1998 is part of the set of supporting regulations for "The Safety at
Work., etc., Act 1974", which in turn is the UK implementation (in fact it
was one of the models for!) of EU Directive 89/391/EEC "The Workplace
Framework Directive". This, in turn, has many implementing detailed
EUdirectives for workplace safety.
Thus, as such, it may not matter if the item gets through local Customs, as
"taking into service" in the work environment is then subject to the latter
directive, in all its national implementations and implications (e.g. safety
standards, language of markings and instructions, etc.), that counts in the
end.
Regards
John Allen
----- Original Message -----
From: "John Woodgate" <j...@jmwa.demon.co.uk>
To: <emc-p...@ieee.org>
Sent: Wednesday, August 31, 2005 7:16 AM
Subject: Re: In-house test equipment
> Doug Beckwith <dougbeckw...@yahoo.ca> wrote (in
> <20050831024102.32663.qm...@web30505.mail.mud.yahoo.com>) about
> 'In-house test equipment', on Tue, 30 Aug 2005:
>
> >My previous employers all had subsidiaries/factories in Europe, and the
> >transfer of custom built test equipment across the pond was
> >commonplace. The key with the EU legislation is the words "offered for
> >sale". If the equipment is not going to be sold then as long as the
> >shipping papaerwork indicates that it is from xyz company to the same
> >xyz company (UK) then there is no issue at customs. We certainly never
> >had any issues.
>
> It's actually not 'offered for sale' that is the critical issue, because
> even if it's not offered for sale, it IS 'taken into service'. The
> weasel phrase here that was probably invoked to allow your equipment
> into the EU is 'This equipment is not for free circulation within the
> EU.' This phrase should appear on the shipping documents but there is
> no guarantee that customs in all EU countries will accept it. In
> particular, **once the equipment has entered the EU, it is not allowed
> to cross an internal national border, because that would be 'free
> circulation'**.
>
> This is a very grey area, which has arisen because there was no proper
> provision for unique special-purpose products, like factory test
> equipment, in the Directive. The new Directive is a bit better in this
> respect.
> >
> >One thing you should be careful of is the fact that the local power
> >utility may require evidence of compliance to the relevant safety
> >standard for the equipment, or may require some kind of inspection
> >before you plug it in.
>
> It's not the power utility (at least in UK) but Health and Safety
> officials.
> --
> Regards, John Woodgate, OOO - Own Opinions Only.
> Deadlines are 90% of deadliness.
> http://www.jmwa.demon.co.uk Also see http://www.isce.org.uk
>
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