RE: non CE upgrades in the EU
The European Council has also published a guideline document on the application of the EMC Directive. You can download it at : http://www.emc-journal.co.uk/newguide.html Paragraph 7 discusses, reconditioned, reconfigured and refurbished equipments, both CE marked and not. In the case of non CE marked apparatus, application of the EMC Directive is not mandatory unless, as a result of the modifications, it becomes "as-new apparatus." As-new apparatus is defined as having "identical (or similar) performance as, and adapted to the technical progress to the new apparatus placed on the market at the same time." If the modified equipment is not "as-new", the EMC Directive does not apply. Doug Frazee EMC Compliance Engineer Windermere Information Technology Systems MILCOM Compliance Laboratories (MCL) division 401 Defense Highway Annapolis, MD 21401 USA (410) 266-1793 (410) 266-1751 FAX dfra...@windermeregroup.com -Original Message- From: Richard Cass [SMTP:richard_c...@iris.scitex.com] Sent: Tuesday, March 17, 1998 8:12 AM To: emc-p...@majordomo.ieee.org Subject: non CE upgrades in the EU Greetings, We have a situation where we have ITE equipment installed at a commercial sites in the EU that were delivered before January 1, 1996. They do not carry the CE mark. We are now working on some field retrofitable design changes that can be installed in these "old" machines. The upgrade is done by a service engineer and mostly involves exchanging circuit boards. It will be economically impossible to make this upgrade of an old configuration machine meet standards that would apply to new products shipped to the EU today (e.g. EN50081 class B). My questions boil down to these: 1.) Given that the specific machine was already placed in service in the EU before 1/1/96, does this mean selling a customer this upgrade kit forces us to meet the latest standards and then CE mark the product? 2.) Does the upgrade kit (a bunch of loose boards that do not function outside our machine, other parts, and instructions in box) have to be CE marked? I am pretty certain that the answer to 2 is NO and I am fairly certain (which is less than pretty certain) that the answer to 1 is also NO. Can anyone help me substantiate these answers or correct me if I am wrong? Thanks in advance for the usual insightful responses. Regards, Richard Cass Iris Graphics Bedford,MA USA
Re: non CE upgrades in the EU
Richard, Per section 7.2.1.1 of the latest Guidelines on the Application of the EMC Directive you would only have to comply with the EMC directive if you were bringing the equipment up to "as-new" status. That is, if you made the equipment competitive with new devices used for the same purpose. Otherwise the updated old equipment could have a competitive advantage partly because it would not need to comply. This same section does, however, suggest that you be ready to justify your decision in case you're ever challenged. Dick Shultz Complinace & Approvals Manager Brooktrout Technology, Inc. On 3/17/98 9:11 AM Richard Cass said: > Greetings, > We have a situation where we have ITE equipment installed at a commercial > sites in the EU that were delivered before January 1, 1996. They do not > carry the CE mark. We are now working on some field retrofitable design > changes that can be installed in these "old" machines. The upgrade is done > by a service engineer and mostly involves exchanging circuit boards. It > will be economically impossible to make this upgrade of an old > configuration machine meet standards that would apply to new products > shipped to the EU today (e.g. EN50081 class B). My questions boil down to > these: > > 1.) Given that the specific machine was already placed in service in the EU > before 1/1/96, does this mean selling a customer this upgrade kit forces us > to meet the latest standards and then CE mark the product? > > 2.) Does the upgrade kit (a bunch of loose boards that do not function > outside our machine, other parts, and instructions in box) have to be CE > marked? > > I am pretty certain that the answer to 2 is NO and I am fairly certain > (which is less than pretty certain) that the answer to 1 is also NO. Can > anyone help me substantiate these answers or correct me if I am wrong? > > Thanks in advance for the usual insightful responses. > > Regards, > Richard Cass > Iris Graphics > Bedford,MA > USA > >
non CE upgrades in the EU
Greetings, We have a situation where we have ITE equipment installed at a commercial sites in the EU that were delivered before January 1, 1996. They do not carry the CE mark. We are now working on some field retrofitable design changes that can be installed in these "old" machines. The upgrade is done by a service engineer and mostly involves exchanging circuit boards. It will be economically impossible to make this upgrade of an old configuration machine meet standards that would apply to new products shipped to the EU today (e.g. EN50081 class B). My questions boil down to these: 1.) Given that the specific machine was already placed in service in the EU before 1/1/96, does this mean selling a customer this upgrade kit forces us to meet the latest standards and then CE mark the product? 2.) Does the upgrade kit (a bunch of loose boards that do not function outside our machine, other parts, and instructions in box) have to be CE marked? I am pretty certain that the answer to 2 is NO and I am fairly certain (which is less than pretty certain) that the answer to 1 is also NO. Can anyone help me substantiate these answers or correct me if I am wrong? Thanks in advance for the usual insightful responses. Regards, Richard Cass Iris Graphics Bedford,MA USA
