[time-nuts] CE Mark
Jim Lux
James.P.Lux at jpl.nasa.gov
Mon Aug 18 17:54:11 EDT 2008
At 01:10 PM 8/15/2008, David Forbes wrote:
>Poul-Henning Kamp wrote:
> >>
> >> In the agreement with the Council, the European Parliament underlines
> >> that importers must place only compliant products on the Community
> >> market. Before placing a product on the market importers must ensure
> >> that [...]
> >
> > The important thing in this clause is "placing a product on the market".
> >
> > As long as you import things directly into EU, and never sell them
> > again, there is no requirement for CE marking.
> >
>
>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
Indeed... I believe that this is also an area where whether something
is a kit or a "component destined for inclusion in other equipment"
makes a difference.
A significant fraction of the expense of getting regulatory approval
(for a US RTL, for FCC, for CE, etc.) is actually doing the necessary
research and analysis to determine just which standards are
applicable, whether they need testing, etc. You can burn up $10K of
labor pretty quickly in just writing up the appropriate declarations
that "no, our product is exempt because x, and y, and z, in section a
of regulation b, says so"
Heck, just getting copies of the relevant standards could put a
pretty big dent in $10K.
As others have pointed out, this is particularly painful if you're a
small quantity vendor of inexpensive widgets, since the paperwork
handling cost is pretty much independent of the cost of the item
being approved/certified/sanctified/exorcised/whathaveyou..
On the other hand, if you're actually PAYing for the engineering
time, it might not be a huge fraction of the design and analysis
time, except for trivial modifications to existing products that
trigger recertification.
Jim Lux
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