[time-nuts] CE Mark
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
>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
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
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