But the requirements for the CE mark are that it meet the EU directives in force at the time it’s placed into market in the EU, not based on date of manufacture? So a 15 year old CE marked product may still not comply with current EU directives at the time it’s imported.
-Dave From: Pete Perkins [mailto:00000061f3f32d0c-dmarc-requ...@ieee.org] Sent: Monday, October 31, 2016 12:49 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] 2nd hand or refurbished products Scott, Some users of large process equipment know that the equipment will be repositioned within its useful lifetime anywhere on the globe. They insist on the original equipment having all of the ‘certification pedigrees’ for such use. This means that the equipment will, of course, be CE marked from the beginning and, when it is imported into the EU as 2nd hand refurbished equipment it will carry the appropriate marking (based upon the date of manufacture) and the Technical File exists to support the claim. Sometimes the manufacturers chafe at this additional, unnecessary certification work but it must be done as a contractual condition of sale. :>) br, Pete Peter E Perkins, PE Principal Product Safety & Regulatory Affairs Consultant PO Box 23427 Tigard, ORe 97281-3427 503/452-1201 p.perk...@ieee.org<mailto:p.perk...@ieee.org> From: Scott Xe [mailto:scott...@gmail.com] Sent: Monday, October 31, 2016 6:12 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] 2nd hand or refurbished products Nick, Both situations are very rare in reality due to EU rule. In the EU market, probably all the second hand products are largely restricted within the EU since any second hand products outside EU may not meet the latest requirements. Regards, Scott From: Nick Williams <nick.willi...@conformance.co.uk<mailto:nick.willi...@conformance.co.uk>> Date: Monday, 31 October 2016 at 6:24 PM To: Scott Xe <scott...@gmail.com<mailto:scott...@gmail.com>> Cc: <EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@LISTSERV.IEEE.ORG>> Subject: Re: [PSES] 2nd hand or refurbished products Scott, Many second-hand products will have difficulty meeting current requirements. This is a problem for products which have been used outside the EU when they are imported into the EU for the first time, but for second hand products which are already within the EU (i.e. those which were originally sold into the EU when they were new), the rules for new products do not apply when they are sold as second hand. Nick. On 28 Oct 2016, at 15:00, Scott Xe <scott...@gmail.com<mailto:scott...@gmail.com>> wrote: Hi Nick, Thanks for your useful advice! The Blue Guide’s one refers to refurbished products adequately. If imported second hand products are treated as newly introduced products into EU and thus meet the latest directives. It seems the second hand products is unfit for this law. How can the second hand products survive in the EU? Regards, Scott From: Nick Williams <nick.willi...@conformance.co.uk<mailto:nick.willi...@conformance.co.uk>> Date: Friday, 28 October 2016 at 1:22 AM To: Scott Xe <scott...@gmail.com<mailto:scott...@gmail.com>> Cc: <EMC-PSTC@LISTSERV.IEEE.ORG<mailto:EMC-PSTC@listserv.ieee.org>> Subject: Re: [PSES] 2nd hand or refurbished products Funnily enough, I’ve recently been looking into this. So far as the product safety directives are concerned, the answer is in the Blue Guide which says: “ Products which have been repaired or exchanged (for example following a defect), without changing the original performance, purpose or type, are not to be considered as new products according to Union harmonisation legislation. Thus, such products do not need to undergo conformity assessment again, whether or not the original product was placed on the market before or after the legislation entered into force. This applies even if the product has been temporarily exported to a third county for the repair operations. Such repair operations are often carried out by replacing a defective or worn item by a spare part, which is either identical, or at least similar, to the original part (for example modifications may have taken place due to technical progress, or discontinued production of the old part), by exchanging cards, components, sub-assemblies or even entire identical units. If the original performance of a product is modified (within the intended use, range of performance and maintenance originally conceived at the design stage) because the spare-parts used for its repair perform better due to technical progress, this product is not to be considered as new according to Union harmonisation legislation. Thus, maintenance operations are basically excluded from the scope of the Union harmonisation legislation. However, at the design stage of the product the intended use and maintenance must be taken into account” Bear in mind, however (since I know you are located in the States) that the directives which apply are those which are in force on the day the prodict first comes into Europe, even if it has been used outside the EU before that. In other words, second hand equipment sourced outside the EU is treated as if it were new on the day it crosses the border. Nick. On 27 Oct 2016, at 18:11, Scott Xe <scott...@gmail.com<mailto:scott...@gmail.com>> wrote: Are EU chemical directives such as packaging directive, RoHS, REACH and safety directives applied to 2nd hand or refurbished products? Thanks and regards, Scott - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org<mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org<mailto:sdoug...@ieee.org>> Mike Cantwell <mcantw...@ieee.org<mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org<mailto:j.bac...@ieee.org>> David Heald <dhe...@gmail.com<mailto:dhe...@gmail.com>> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org<mailto:emc-p...@ieee.org>> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe)<http://www.ieee-pses.org/list.html> List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org<mailto:sdoug...@ieee.org>> Mike Cantwell <mcantw...@ieee.org<mailto:mcantw...@ieee.org>> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org<mailto:j.bac...@ieee.org>> David Heald <dhe...@gmail.com<mailto:dhe...@gmail.com>> - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <sdoug...@ieee.org> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>