> -----Original Message----- > From: [EMAIL PROTECTED] > [mailto:[EMAIL PROTECTED] On Behalf Of Jim Lux > Sent: Monday, August 18, 2008 4:54 PM > To: [EMAIL PROTECTED]; Discussion of precise time and > frequency measurement; Discussion of precise time and > frequency measurement > Subject: Re: [time-nuts] CE Mark > > At 01:10 PM 8/15/2008, David Forbes wrote: > > > >Poul, > > > >This is interesting. It means that I, as an American > >exporter selling directly to end customers in the EU, > >do NOT need to CE mark my American made products. > > > >-- David Forbes, Tucson AZ, Estados Unidos Americanos >
It all depends how you intend to sell products in the EU without "placing your product on the market". I am not sure how you can do it "legitimately" and hope to rake in significant sales. You do not need a local distributor to be "placing your product on the market." Advertising is sufficient, catering to the market (by providing sales brochure in local language) is sufficient, a price list in local currency is sufficient. On the other hand, if someone logs on your english-language, US based web site and buys directly in US$ (you sell FOB US) and you don't advertise shipping costs to the foreign country and there is only US-english documentation and the buyer takes care of the importing paperwork, I don't see how you could be accused of "placing your product on the market." If you add the proper disclaimers regarding the fact that your product is not CE compliant and the buyer accepts all liability as a result, I don't see how you could be in trouble. Tokyo Hi-Power (a Japanese ham-radio equipment manufacturer) has done that for a long time. For a while their products were not FCC certified and they did not have a local (US) distributor, yet they would sell to US customers. You had to either call Japan or email to the sales office in Japan and they would give you a price in Yens. They would also ship to you directly if you asked, but none of that was advertised on their web site. This is a little different, since FCC regulations are different from CE regulations, but the spirit is the same. Disclaimer: IANAL, this is just my opinion... Didier KO4BB _______________________________________________ time-nuts mailing list -- time-nuts@febo.com To unsubscribe, go to https://www.febo.com/cgi-bin/mailman/listinfo/time-nuts and follow the instructions there.
