The below may not be complete, and not even represent the full EMC or LOW voltage directive "opinions", (and they are different too). It's how I handle them everyday.
Do you need field testing so soon ? If you want to answer that, you First must decide of field testing is absolutely necessary with a product that may not (or may) comply. Why should you want to expose (future) customers with a product that may include hazards to them or the spectrum. EMC or Safety testing may imply future functional restrictions, making the value of field testing less valuable. " Placed onto the market " is almost every action where a piece of equipment is made available to anyone else but the manufacturer. As John said sell or give away. "put into service" definitely means switching a product "on" the first time (that is from the directive) within the EC territory. Both statements refer to a PRODUCT. It is the manufacturer that defines if a product is a product or not. A product is a defined entity that autonomously provides a function to an end user. This excludes unfinished equipment but does not necessary exclude field samples. Before a new design becomes a product, it may of course temporarily be NO PRODUCT. This is where design happens. This is where compliance testing happens. So John, don't worry, one is allowed to design a new product end switch it on!! Until someone says : "it's a product now" !! We are gonna sell it ! let's go field testing !! I do not believe in asking the authorities. They will simply say no. But for trade shows , but that's another subject. Well John, products do cross EC borders without ce-mark every day. As a test house we do frequently receive PRODUCTS from our USA and WW customers without problems (or do you think that ce-test is that famous that customs understand !! ??!!@) Gert Gremmen ce-test, qualified testing bv Van: emc-p...@ieee.org [mailto:emc-p...@ieee.org] Namens John Woodgate Verzonden: vrijdag 29 februari 2008 16:06 Aan: emc-p...@ieee.org Onderwerp: Re: Field Testing In message <of4c222d7f.6e1294ce-on862573fe.004d10eb-862573fe.004d7...@mmm.com>, dated Fri, 29 Feb 2008, rehel...@mmm.com writes: >What are the European rules governing the use of non-CE marked >equipment and field testing? Not allowed? It isn't specifically prohibited, as such, but ..... > >What are the definitions of "placed on the market" and "put into >service"? I can't seem to find a clear definition. The clearest are in the Directive itself, for sufficiently obscure values of 'clear'. 'Placed on the market' is reasonably obvious - it involves an open offer to sell or give away. That doesn't apply to field test samples, of course. 'Taken into service' is more difficult. Originally, it meant 'the first use for the product's intended purpose', but some 'hard cases' (such as manufacturer's own-built test equipment) seem to have extended the meaning almost to 'the first time the product is powered up', in which case you couldn't even legally power it up to test it for compliance! So it does stop short of 'the first time it's powered up', but exactly where is not clear. In another aspect, the CE mark is what gets the product across national borders and into the EU in the first place. So without one, it can't legally enter. If you want to do field testing in a particular EU country, and want to be strictly legal, you could ask the authorities for permission. Or could you do the testing at an EMC test site? -- 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 - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
