[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.
> >
>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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