Dave, et al,
That is true the product MAY NOT comply (but it MAY) with the
current requirements when it is imported into the EU but that is now easily
checked by reference to the details in the Technical File.
The product owner may then decide as to the best approach to
preparing the product for import.
:>) br, Pete
Peter E Perkins, PE
Principal Product Safety & Regulatory Affairs Consultant
PO Box 23427
Tigard, ORe 97281-3427
503/452-1201
<mailto:p.perk...@ieee.org> p.perk...@ieee.org
From: Nyffenegger, Dave [mailto:dave.nyffeneg...@bhemail.com]
Sent: Monday, October 31, 2016 10:28 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] 2nd hand or refurbished products
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 <mailto: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
<mailto:p.perk...@ieee.org> 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 <mailto: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 < <mailto:nick.willi...@conformance.co.uk>
nick.willi...@conformance.co.uk>
Date: Friday, 28 October 2016 at 1:22 AM
To: Scott Xe < <mailto:scott...@gmail.com> scott...@gmail.com>
Cc: < <mailto:EMC-PSTC@listserv.ieee.org> 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 < <mailto:scott...@gmail.com>
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
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