K3 CE

[Stewart Baker]

Hope the K3's coming into the EU have now got CE certification.

Stewart G3RXQ
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[dj7mgq]

> Hope the K3's coming into the EU have now got CE certification.

I still haven't open mine yet (it arrived at work a couple of hours ago), so I
don't know for sure, but Eric wrote that they would not deliver any factory
built K3s until he was finished with the CE certification process. And that the
kit did not need a CE Marking and could not be certified anyway.

Mine is a kit.

vy 73 de toby

PS: You can find Elecraft's statements about CE Markings in the archives of the
reflector.

> Hope the K3's coming into the EU have now got CE certification.
>
> Stewart G3RXQ
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>

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[Julian, G4ILO]

On Nov 14, 2007 12:05 PM, Stewart Baker <[hidden email]> wrote:
> Hope the K3's coming into the EU have now got CE certification.

It matters not a jot to me. As Toby has said, it doesn't affect kits
anyway. But if W&S can import any MFJ product (which definitely are
not CE certified - I think someone on this reflector confirmed it) and
then "certify" it themselves, I don't see why lack of certification
should be an obstacle to anyone in the UK receiving the K3 they
ordered, even a built one.

--
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf
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[David Cutter]

It is acceptable for an importer to certify products as long as he does so within the legal requirments.  He can then quite legally fix the appropriate CE label and provide a Certificate of Compliance.   I could not comment as to whether W & S follow the requirments.  Anyone has the right to view the Certificate of Compliance for any product within the EC.  The importer then becomes the "responsible vendor."

David
G3UNA

>
> From: "Julian G4ILO" <[hidden email]>
> Date: 2007/11/14 Wed PM 01:32:02 GMT
> To: elecraft <[hidden email]>
> Subject: Re: [Elecraft] K3 CE
>
> On Nov 14, 2007 12:05 PM, Stewart Baker <[hidden email]> wrote:
> > Hope the K3's coming into the EU have now got CE certification.
>
> It matters not a jot to me. As Toby has said, it doesn't affect kits
> anyway. But if W&S can import any MFJ product (which definitely are
> not CE certified - I think someone on this reflector confirmed it) and
> then "certify" it themselves, I don't see why lack of certification
> should be an obstacle to anyone in the UK receiving the K3 they
> ordered, even a built one.
>
> --
> Julian, G4ILO K2 s/n: 392  K3 s/n: ???
> G4ILO's Shack: www.g4ilo.com
> Zerobeat Ham Forums: www.zerobeat.net/smf
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[dj7mgq]

Hallo,

> The importer then becomes the "responsible vendor."

Which might be interesting if one ever decided to sell her/his K3, which was
imported as a Kit and built in Europe?

I wonder...

vy 73 de toby
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[Julian, G4ILO]

On Nov 14, 2007 3:42 PM,  <[hidden email]> wrote:
> It is acceptable for an importer to certify products as long as he does so within the legal requirments.  He can then quite legally fix the appropriate CE label and provide a Certificate of Compliance.   I could not comment as to whether W & S follow the requirments.  Anyone has the right to view the Certificate of Compliance for any product within the EC.  The importer then becomes the "responsible vendor."

But if I'm importing it to use, not to sell, does this matter? The
body responsible for CE marking here is Trading Standards. They are
unlikely to even find out about it since I am not a trader. Toby makes
a valid point as concerns resale, but being pragmatic, we don't live
in a bureaucratic police state where officials go through the small
ads checking on what people are selling, so whether it's legal or not,
it's certainly going to be "under the radar".

I think the only issue that may concern Elecraft is if it is likely
that imports are going to be stopped at customs and returned at their
expense. If it's OK for goods to be certified at this end then it
obviously isn't illegal to import uncertified goods therefore customs
isn't going to be bothered.
--
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf
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[David Cutter]

You are not a vendor, merely a kit builder, you are not in business.  However, it's an interesting question.

David
G3UNA

>
> From: [hidden email]
> Date: 2007/11/14 Wed PM 04:08:41 GMT
> To: [hidden email]
> CC: Julian G4ILO <[hidden email]>,  elecraft <[hidden email]>
> Subject: Re: Re: [Elecraft] K3 CE
>
> Hallo,
>
> > The importer then becomes the "responsible vendor."
>
> Which might be interesting if one ever decided to sell her/his K3, which was
> imported as a Kit and built in Europe?
>
> I wonder...
>
> vy 73 de toby
>

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[David Cutter]

Don't forget that, aside from CE marking, you are deemed to be techniclly competent as an Advanced licence holder and can therefore build your own kit and operate it within the terms of your licence. You are right in saying that you can import your own kit for your own use and if you sell it, it is not as a business for general sale of lots of these.

David
G3UNA
 

>
> From: "Julian G4ILO" <[hidden email]>
> Date: 2007/11/14 Wed PM 04:31:17 GMT
> To: elecraft <[hidden email]>
> Subject: Re: Re: [Elecraft] K3 CE
>
> On Nov 14, 2007 3:42 PM,  <[hidden email]> wrote:
> > It is acceptable for an importer to certify products as long as he does so within the legal requirments.  He can then quite legally fix the appropriate CE label and provide a Certificate of Compliance.   I could not comment as to whether W & S follow the requirments.  Anyone has the right to view the Certificate of Compliance for any product within the EC.  The importer then becomes the "responsible vendor."
>
> But if I'm importing it to use, not to sell, does this matter? The
> body responsible for CE marking here is Trading Standards. They are
> unlikely to even find out about it since I am not a trader. Toby makes
> a valid point as concerns resale, but being pragmatic, we don't live
> in a bureaucratic police state where officials go through the small
> ads checking on what people are selling, so whether it's legal or not,
> it's certainly going to be "under the radar".
>
> I think the only issue that may concern Elecraft is if it is likely
> that imports are going to be stopped at customs and returned at their
> expense. If it's OK for goods to be certified at this end then it
> obviously isn't illegal to import uncertified goods therefore customs
> isn't going to be bothered.
> --
> Julian, G4ILO K2 s/n: 392  K3 s/n: ???
> G4ILO's Shack: www.g4ilo.com
> Zerobeat Ham Forums: www.zerobeat.net/smf
> _______________________________________________
> Elecraft mailing list
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>
> Help: http://mailman.qth.net/subscribers.htm
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>

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[Julian, G4ILO]

On Nov 15, 2007 8:24 AM,  <[hidden email]> wrote:
> Don't forget that, aside from CE marking, you are deemed to be techniclly competent as an Advanced licence holder and can therefore build your own kit and operate it within the terms of your licence. You are right in saying that you can import your own kit for your own use and if you sell it, it is not as a business for general sale of lots of these.
>
Coincidentally the December RadCom EMC column, page 43, has a
discussion that is relevant to this.

It explains that the regulations apply to goods that are "placed on
the market" or "taken into service". New goods sold commercially are
"placed on the market" but (the article states) it is clear from
examples like very noisy (and CE marked!) Chinese made switch mode
wall warts sold on eBay that the local Trading Standards are doing
nothing about enforcement (and from personal knowledge they have
neither the manpower nor the technical competence to do so.) Second
hand goods sold on eBay or at a flea market are not "placed on the
market". However, the purchaser is "taking it into service" and
therefore becomes responsible for its EMC compliance.

Although, as you say, we as radio hams should be competent to decide
whether our equipment meets the standards or not, the average person
buying a wall wart battery charger or whatever certainly isn't.

Therefore this whole CE marking busines seems to me to be a total
waste of time, as it is either unenforced or unenforceable.
--
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf
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[dj7mgq]

> Therefore this whole CE marking busines seems to me to be a total
> waste of time, as it is either unenforced or unenforceable.

Without wanting to pass judgement on the sense of CE Markings or lack thereof,
one must not forget, that (at least in DL) if you want to use a "new" rig in a
"new" car, then it *must* have a CE Marking.

This according the DARC (the German version of the RSGB).

vy 73 de toby



PS: For the German speakers out there...

Source: <http://www.darc.de/>
-------------------------------------------------
Funkgeräteeinbau in Kraftfahrzeuge wesentlich erleichtert

Nach einer Mitteilung des Kraftfahrtbundesamtes
in Flensburg wurde durch eine Bekanntmachung im
Verkehrsblatt die Richtlinie 2004/104/EG im
Bundesgebiet in Kraft gesetzt. Diese Richtlinie
ersetzt die 95/54/EG. Das bedeutet, dass alle
neuen Funkgeräte in Kraftfahrzeuge eingebaut
werden dürfen, die ein CE-Zeichen oder ein
E-Zeichen tragen! Eine E-Zulassung der
Transceiver ist damit nicht mehr erforderlich.
 
Die CE-Kennzeichnung reicht aus, wenn eine
Bescheinigung beiliegt, dass das Funkgerät
nicht im Zusammenhang mit der Störfestigkeit
(sicherheitsrelevante Funktionen) steht. Als
"neue" Funkgeräte sind die zu bezeichnen, die
ab dem 11. Januar 2005 in Verkehr gebracht
wurden. Insbesondere betroffen sind hiervon PKW und
LKW mit Erstzulassungsdatum ab dem 1. Oktober 2002
sowie Krafträder und Trikes mit Erstzulassungsdatum
ab dem 17. Juni 2003. So genannte "Altgeräte" (vor
dem 11.1.2005) werden von der Richtlinie 2004/104/EG
nicht mehr erfasst und müssen lediglich die
Vorschriften zum Zeitpunkt ihres erstmaligen
Inverkehrbringens erfüllen. Einer Weiterverwendung
durch wieder Einbau, auch in neuen Kraftfahrzeugen,
steht nichts im Wege.
-------------------------------------------------
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[Stewart Baker]

In the past the "authorities" were concerned with amateurs causing interference
to domestic radio/television reception and all other government services.
Now it is the amateur that has the problem.

We now have to contend with radio interference to our hobby from:-
TV's (LCD & Plasma), Cable TV, PLT, HomePlug, Switch Mode PSU's either
freestanding (wall warts) or in-built(Computer), electronic controls in anything
from a central heating boiler to a sewing machine . et .al.

It's a bit ironic that, as rigs such as the K3 are now being sold with a superb
receive performance that many amateurs are unable to use due to increasing
radio spectrum pollution.

Many items sold into the domestic market would appear to be either non -
compliant, or have a test standard applied that is most advantageous to their
products. A lot of items are able to cause HF interference because, the only
radiated emissions testing required is carried out above 30MHz. Below 30MHz only
the conducted interference on the supply lead is tested.

In the UK the enforcing agency is the Trading Standards. They are lacking in
funding, manpower and technical knowledge to deal with anything other than life
threatening issues (i.e. Lead paint on toys).

As far as the EMC part of CE goes, it promised a lot, but has delivered very
little....

Stewart G3RXQ
Member RSGB EMC Committee

On Thu, 15 Nov 2007 08:51:20 +0000, Julian G4ILO wrote:

> On Nov 15, 2007 8:24 AM, <[hidden email]> wrote:
>> Don't forget that, aside from CE marking, you are deemed to be techniclly
>> competent as an Advanced licence holder and can therefore build your own
>> kit and operate it within the terms of your licence. You are right in
>> saying that you can import your own kit for your own use and if you sell
>> it, it is not as a business for general sale of lots of these.
>>
> Coincidentally the December RadCom EMC column, page 43, has a
> discussion that is relevant to this.
>
> It explains that the regulations apply to goods that are "placed on
> the market" or "taken into service". New goods sold commercially are
> "placed on the market" but (the article states) it is clear from
> examples like very noisy (and CE marked!) Chinese made switch mode
> wall warts sold on eBay that the local Trading Standards are doing
> nothing about enforcement (and from personal knowledge they have
> neither the manpower nor the technical competence to do so.) Second
> hand goods sold on eBay or at a flea market are not "placed on the
> market". However, the purchaser is "taking it into service" and
> therefore becomes responsible for its EMC compliance.
>
> Although, as you say, we as radio hams should be competent to decide
> whether our equipment meets the standards or not, the average person
> buying a wall wart battery charger or whatever certainly isn't.
>
> Therefore this whole CE marking busines seems to me to be a total
> waste of time, as it is either unenforced or unenforceable.

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[Julian, G4ILO]

This is, unfortunately, so true. It is getting to the stage when I
wonder how much longer it is possible for someone in my situation to
operate a "stealth" station in a crowded urban housing estate. It is
not the limited size of my antennas that is the problem but the
interference I have to contend with. I can turn off my electrics and
it makes little difference to the noise level, which is often S3-S5 on
the K3's rather stingy S meter.

As for the situation in Germany, well if that's the law and people
will actually check up on it then you have to go along with it. But
only a politician could bring about a situation where it is an offense
to use equipment that doesn't have a worthless sticker on it. And CE
certification is worthless unless it guarantees that the equipment
meets a worthwhile standard.

I think the only solution that would solve the interference problem
would involve type approval of equipment by independent tester.
Clearly you can't rely on all manufacturers to self-certify with any
degree of honesty. And given the lack of enforcement in the UK there
is no reason for anyone to do more than pay lip service to the
regulations. No doubt you can buy rolls of self adhesive CE stickers
from some Chinese vendor on eBay...

But despite the benefits to us hams of type approval, I'm not sure I'd
like the extra costs and restricted range of products such a measure
would result in. I can remember just how expensive modems were in the
80s when they had to be type approved by the monopoly telecoms
provider.
--
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf

On Nov 15, 2007 10:16 AM, Stewart Baker <[hidden email]> wrote:
> In the past the "authorities" were concerned with amateurs causing interference
> to domestic radio/television reception and all other government services.
> Now it is the amateur that has the problem.
>
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[gm3sek]

Julian G4ILO wrote:

>> Don't forget that, aside from CE marking, you are deemed to be
>>techniclly competent as an Advanced licence holder and can
>>therefore build your own kit and operate it within the terms of
>>your licence. You are right in saying that you can import your
>>own kit for your own use and if you sell it, it is not as a
>>business for general sale of lots of these.
>>
>Coincidentally the December RadCom EMC column, page 43, has a
>discussion that is relevant to this.
>
>It explains that the regulations apply to goods that are "placed on the
>market" or "taken into service". New goods sold commercially are
>"placed on the market" but (the article states) it is clear from
>examples like very noisy (and CE marked!) Chinese made switch mode wall
>warts sold on eBay that the local Trading Standards are doing nothing
>about enforcement (and from personal knowledge they have neither the
>manpower nor the technical competence to do so.) Second hand goods sold
>on eBay or at a flea market are not "placed on the market". However,
>the purchaser is "taking it into service" and therefore becomes
>responsible for its EMC compliance.
>
>Although, as you say, we as radio hams should be competent to decide
>whether our equipment meets the standards or not, the average person
>buying a wall wart battery charger or whatever certainly isn't.
>
>Therefore this whole CE marking busines seems to me to be a total waste
>of time, as it is either unenforced or unenforceable.

Sorry, I don't agree. Overall, I think the European EMC regulations have
been a success - so much so that we take them for granted. It's always
the leakage around the system that gets the publicity, and it only takes
one small thing like an unfiltered wall wart to cause problems for us.

The vast majority of electronic and electrical appliances coming into
European homes are 'mainstream' products from European companies, or
from international companies with substantial business operations in
Europe. Regardless of where they were actually manufactured, these
products do comply with all the relevant product standards. European
radio amateurs have definitely benefited from this. The RFI mailing list
has frequent horror stories from the USA that just don't happen over
here any more.

As licensed amateurs we are personally responsible for EMC compliance,
the only difference being that we don't have to provide formal
demonstrations or documentation.

For kits and ready-made amateur radio equipment imported from outside
Europe, practical experience is that personal importers are never asked
to demonstrate compliance. I can certainly confirm that as an exporter
of kits and boards to the rest of Europe, the USA and around the world -
in over a thousand transactions, never a single challenge.

According to Wayne's posting a couple of weeks ago, Elecraft has already
done the testing to demonstrate compliance with the relevant European
standards - which the K3 passed easily, of course. As soon as all the
necessary documentation has been assembled, they will immediately become
legally entitled to attach a CE sticker (they don't have to file it with
anyone else). But, quite rightly, that isn't Elecraft's main priority
just now.

For K3s being imported into Europe at present, that leaves only the most
trivial technicality: a product that does in fact meet all the relevant
European standards, but doesn't have a CE marking to say so.

Worrying about such little things is a symptom of severe K3 deprivation!
Fortunately, there is also a complete cure for this condition   :-)

As soon as the documentation does comes into existence, the owners of
unmarked K3s will become legally entitled to attach a CE sticker
themselves. They don't need any documentation to do this; it is
sufficient to know that valid documents exist. They'll be in the bottom
of a locked filing cabinet, in a cellar on a planet called Aptos.



--

73 from Ian GM3SEK
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[dj7mgq]

> As for the situation in Germany, well if that's the law and people
> will actually check up on it then you have to go along with it.

Actually what I sent to the reflector was about the German implementation of a
European Union regulation, i.e. it is also "the law" in the France, Italy,
Spain, Poland, Sweden, Malta, Greece, the U.K. etc.

To see more about 2004/104/EG you could take a look at:
<http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32004L0104:EN:NOT>

"Commission Directive 2004/104/EC of 14 October 2004 adapting to technical
progress Council Directive 72/245/EEC relating to the radio interference
(electromagnetic compatibility) of vehicles and amending Directive 70/156/EEC on
the approximation of the laws of the Member States relating to the type-approval
of motor vehicles and their trailersText with EEA relevance"

If the above makes sense or not: This is one reason why it is important that at
least the factory built K3s have a CE Marking.

vy 73 de toby
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[Julian, G4ILO]

On Nov 15, 2007 11:45 AM, Ian White GM3SEK <[hidden email]> wrote:

> As soon as the documentation does comes into existence, the owners of
> unmarked K3s will become legally entitled to attach a CE sticker
> themselves. They don't need any documentation to do this; it is
> sufficient to know that valid documents exist. They'll be in the bottom
> of a locked filing cabinet, in a cellar on a planet called Aptos.

Couldn't we just self-certify it?

On Nov 15, 2007 12:02 PM,  <[hidden email]> wrote:

> If the above makes sense or not: This is one reason why it is important that at
> least the factory built K3s have a CE Marking.

OK, Toby, I think we'll never agree on the importance of abiding by
laws that are not enforced. Here, the police can't even be bothered to
do anything about drunken and rowdy behaviour or crazy driving by
young people in the town centre at weekends. The thought of them
bothering to check if a radio has a CE sticker is simply unimaginable.

--
Julian, G4ILO K2 s/n: 392  K3 s/n: ???
G4ILO's Shack: www.g4ilo.com
Zerobeat Ham Forums: www.zerobeat.net/smf
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[David Cutter]

In the case of vehicles it will be e marking (lower case).

David
G3UNA

>
> From: [hidden email]
> Date: 2007/11/15 Thu AM 09:24:45 GMT
> To: elecraft <[hidden email]>
> Subject: Re: [Elecraft] K3 CE
>
> > Therefore this whole CE marking busines seems to me to be a total
> > waste of time, as it is either unenforced or unenforceable.
>
> Without wanting to pass judgement on the sense of CE Markings or lack thereof,
> one must not forget, that (at least in DL) if you want to use a "new" rig in a
> "new" car, then it *must* have a CE Marking.
>
> This according the DARC (the German version of the RSGB).
>
> vy 73 de toby
>
>
>
> PS: For the German speakers out there...
>
> Source: <http://www.darc.de/>
> -------------------------------------------------
> Funkgeräteeinbau in Kraftfahrzeuge wesentlich erleichtert
>
> Nach einer Mitteilung des Kraftfahrtbundesamtes
> in Flensburg wurde durch eine Bekanntmachung im
> Verkehrsblatt die Richtlinie 2004/104/EG im
> Bundesgebiet in Kraft gesetzt. Diese Richtlinie
> ersetzt die 95/54/EG. Das bedeutet, dass alle
> neuen Funkgeräte in Kraftfahrzeuge eingebaut
> werden dürfen, die ein CE-Zeichen oder ein
> E-Zeichen tragen! Eine E-Zulassung der
> Transceiver ist damit nicht mehr erforderlich.
>  
> Die CE-Kennzeichnung reicht aus, wenn eine
> Bescheinigung beiliegt, dass das Funkgerät
> nicht im Zusammenhang mit der Störfestigkeit
> (sicherheitsrelevante Funktionen) steht. Als
> "neue" Funkgeräte sind die zu bezeichnen, die
> ab dem 11. Januar 2005 in Verkehr gebracht
> wurden. Insbesondere betroffen sind hiervon PKW und
> LKW mit Erstzulassungsdatum ab dem 1. Oktober 2002
> sowie Krafträder und Trikes mit Erstzulassungsdatum
> ab dem 17. Juni 2003. So genannte "Altgeräte" (vor
> dem 11.1.2005) werden von der Richtlinie 2004/104/EG
> nicht mehr erfasst und müssen lediglich die
> Vorschriften zum Zeitpunkt ihres erstmaligen
> Inverkehrbringens erfüllen. Einer Weiterverwendung
> durch wieder Einbau, auch in neuen Kraftfahrzeugen,
> steht nichts im Wege.
> -------------------------------------------------
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[gm3sek]

Julian G4ILO wrote:
>
>> As soon as the documentation does comes into existence, the owners of
>> unmarked K3s will become legally entitled to attach a CE sticker
>> themselves. They don't need any documentation to do this; it is
>> sufficient to know that valid documents exist. They'll be in the bottom
>> of a locked filing cabinet, in a cellar on a planet called Aptos.
>
>Couldn't we just self-certify it?
>

Not just out of thin air. Somebody, somewhere has to do the work.


--

73 from Ian GM3SEK
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[David Cutter]

You only self-certify if you intend to place new goods onto the EEC market,
ie you are a manufacturer or importer.

David
G3UNA

----- Original Message -----
From: "Julian G4ILO" <[hidden email]>

> Couldn't we just self-certify it?
>
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