In message
<3c6137471f17424280d9b2ceaefd7f853b6...@usmafrexmb01.bose.com>, dated
Fri, 29 Feb 2008, "Tyra, John" <john_t...@bose.com> writes:

>I thought this document had a pretty good definition of "Placing on the
>market" on page 19......
>
>http://ec.europa.eu/enterprise/newapproach/legislation/guide/document/1
>999_1282_en.pdf

This is a very helpful link. I would encourage people to download this
very big Guide; it answers a lot of questions.

>
>After reading this again I think field testing would be considered
>"Placing on the Market" but I am sure our EU colleagues could answer
>this more definitively.

I'm not sure why you draw that conclusion. The text says:
QUOTE
  Placing on the market is the initial action of making a product
available for the first time on the Community market, with
a view to distribution or use in the Community. Making available
can be either for payment or free of charge.
ENDQUOTE

I didn't interpret 'field testing' as involving selling or giving away
the product. If it does, then compliance and CE marking are essential.

Then we have:

QUOTE
 Putting into service takes place at the moment of first use
within the Community by the end user. However, the need to
ensure, in the framework of market surveillance, that products
are in compliance with the provisions of the directives when
being put into service is limited.
ENDQUOTE

This is the definition I gave, without the 'hard cases' extension, which
puts a wide interpretation on 'end user' - that it is anyone who
operates the product after it has been manufactured.

There is also a great deal of uncertainty about the implications of the
second sentence. The Guide applies to all Directives, and we might agree
that it is reasonable not to be too worried about the odd product that
isn't EMC-compliant but causes no problems. But what about safety
standards? Shouldn't it be essential that all products are compliant?
-- 
OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk
For very important information, please turn over.
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK

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