Importing a laser - form: FDA-2877

[CC]

Hi:

I have an interest to obtain a Chinese made laser for personal laser
show hobby use. I've been trying to understand what I must do, or if it
is even within my means, to ensure that if I obtain such a laser, it
will be legal.

According to the "Frequently Asked Questions for Manufacturers of
Electronic Products that Emit Radiation" located here:

http://www.fda.gov/cdrh/radhealth/rademitfaq.html

1. An importer of a laser would be considered a manufacturer, thus must
comply with the regs.

2. Must fill out form FDA 2877 to import a product.

The form has a section allowing one to declare that the product(s):

__ A. ARE NOT SUBJECT TO RADIATION PERFORMANCE STANDARDS BECAUSE THEY:

__ 5. Are components or subassemblies to be used in manufacturing or as
replacement parts (NOT APPLICABLE to diagnostic x-ray parts).

__ 6. Are prototypes intended for on going product development by the
importing firm, are labeled "FOR TEST/EVALUATION ONLY," and will be
exported, destroyed, or held for future testing (i.e., not distributed).
(Quantities Limited - see reverse.)

On the back it says:

DECLARATION A: Importers should be prepared to demonstrate compliance to
or non-applicability of FDA standards, regulations, or guidance.
Components or sub-assemblies must be non-functioning.[snip]


If one declares section A subsection 5, that the item is a component,
then one might have to demonstrate that the item is non-functioning.
What does this mean? It would seem unlikely that a Chinese laser which
requires only that one insert the power cord and turn it on could be
considered "non-functioning". Thus, this presents a stumbling-block to
the option of declaring the laser to be a component.

If one cannot declare the product to be a component and thus not subject
to FDA standards, then one is subject to the much more complex
requirements of declaring certification, filing reports, etc.

Every time I attempt to understand how to comply with government
regulations, the result is the same. It is simply overwhelming for a
single person. It requires the resources of a company which can afford
to dedicate specific personnel to the task of regulatory compliance, or
to hire a consultant firm to perform this task.

Hence the motivation to skirt the law is intense. No wonder there is a
thriving black market in non-compliant laser products sold by one-man
"sites".

Ugh.

[Richard Budd]

Post by CC
I have an interest to obtain a Chinese made laser for personal laser
show hobby use. I've been trying to understand what I must do, or if it
is even within my means, to ensure that if I obtain such a laser, it
will be legal.
According to the "Frequently Asked Questions for Manufacturers of
http://www.fda.gov/cdrh/radhealth/rademitfaq.html
1. An importer of a laser would be considered a manufacturer, thus must
comply with the regs.
2. Must fill out form FDA 2877 to import a product.
__ 5. Are components or subassemblies to be used in manufacturing or as
replacement parts (NOT APPLICABLE to diagnostic x-ray parts).
__ 6. Are prototypes intended for on going product development by the
importing firm, are labeled "FOR TEST/EVALUATION ONLY," and will be
exported, destroyed, or held for future testing (i.e., not distributed).
(Quantities Limited - see reverse.)
DECLARATION A: Importers should be prepared to demonstrate compliance to
or non-applicability of FDA standards, regulations, or guidance.
Components or sub-assemblies must be non-functioning.[snip]
If one declares section A subsection 5, that the item is a component,
then one might have to demonstrate that the item is non-functioning.
What does this mean? It would seem unlikely that a Chinese laser which
requires only that one insert the power cord and turn it on could be
considered "non-functioning". Thus, this presents a stumbling-block to
the option of declaring the laser to be a component.
If one cannot declare the product to be a component and thus not subject
to FDA standards, then one is subject to the much more complex
requirements of declaring certification, filing reports, etc.
Every time I attempt to understand how to comply with government
regulations, the result is the same. It is simply overwhelming for a
single person. It requires the resources of a company which can afford
to dedicate specific personnel to the task of regulatory compliance, or
to hire a consultant firm to perform this task.
Hence the motivation to skirt the law is intense. No wonder there is a
thriving black market in non-compliant laser products sold by one-man
"sites".
Ugh.

Actually your best move is to do what we do - import lasers that already
meet CDRH regs and are registered by the manufacturer. We get our
Yb-fiber lasers from SPI in the UK and integrate them into our systems
for resale. You will still have to go through the registration,
documentation, labeling process again with your final product before you
can sell it or use it in a public venue, but at least you are off to a
legal start. The only way you *should* be able to get bare laser modules
is if you are a fairly large manufacturer...

The requirements are NOT that difficult for a laser manufacturer to meet
so I don't understand why any reputable one wouldn't. Mainly meeting
records & documentation, labeling, and safety interlocking that will
prevent emission under most probable fault conditions is all that is needed.

The preventing unwanted emission is the the biggest technical bit the
FDA wants. A simple mechanical shutter that can indefinitely take max
power will do it. Where not practical - like in the several hundred watt
fiber laser modules we use (physical design, not thermal, issue) -
safety-rated electronic interlocking is permitted instead. That boils
down to guaranteed shutting down of the power supply in a manner that
cannot also produce a random output spike and having a mandatory 5-sec
delay before emission is possible after the interlock is satisfied
again. A safety relay that interrupts the drive signals in a switching
power supply along with its output does the trick.

BTW: What is 'Safety-rated' one might ask? A device such as an interlock
relay that is designed - and UL/CSA/IEC/etc registered - to be unable to
fail to operate in an safe manner, eg dual-coils, status monitoring,
mechanical construction ('force-guided') operation meaning if a contact
welds shut the other contacts cannot operate (all safety relays are
multi-pole). They must open to break a dual safety circuit but cannot
fully operate and close the acknowledgment side of the loop. In the US
safety relays probably cost more ($40-$230) than the laser module does
but you are going to want one in you system along with matching
interlock switches on any removable housings. Can you say 'Due
diligance'?. The relay would tie to the interlock circuit in the laser
module. On the supplier end I'm sure China can supply suitable tech in
their laser modules for much less than anyone else ;-)

Cheers!

[CC]

Post by Richard Budd

Post by CC
I have an interest to obtain a Chinese made laser for personal laser
show hobby use. I've been trying to understand what I must do, or if
it is even within my means, to ensure that if I obtain such a laser,
it will be legal.

Actually your best move is to do what we do - import lasers that already
meet CDRH regs and are registered by the manufacturer. We get our
Yb-fiber lasers from SPI in the UK and integrate them into our systems
for resale. You will still have to go through the registration,
documentation, labeling process again with your final product before you
can sell it or use it in a public venue, but at least you are off to a
legal start. The only way you *should* be able to get bare laser modules
is if you are a fairly large manufacturer...

Most hobbyists are buying OEM modules.

Post by Richard Budd
The requirements are NOT that difficult for a laser manufacturer to meet
so I don't understand why any reputable one wouldn't. Mainly meeting
records & documentation, labeling, and safety interlocking that will
prevent emission under most probable fault conditions is all that is needed.

Plus maintaining those records and recalling all previously sold product
if in the future it is determined that there was something amis in the
compliance. Seems like strong motivation to be on the OEM side of things.

Post by Richard Budd
The preventing unwanted emission is the the biggest technical bit the
FDA wants. A simple mechanical shutter that can indefinitely take max
power will do it. Where not practical - like in the several hundred watt
fiber laser modules we use (physical design, not thermal, issue) -
safety-rated electronic interlocking is permitted instead. That boils
down to guaranteed shutting down of the power supply in a manner that
cannot also produce a random output spike and having a mandatory 5-sec
delay before emission is possible after the interlock is satisfied
again. A safety relay that interrupts the drive signals in a switching
power supply along with its output does the trick.
BTW: What is 'Safety-rated' one might ask? A device such as an interlock
relay that is designed - and UL/CSA/IEC/etc registered - to be unable to
fail to operate in an safe manner, eg dual-coils, status monitoring,
mechanical construction ('force-guided') operation meaning if a contact
welds shut the other contacts cannot operate (all safety relays are
multi-pole). They must open to break a dual safety circuit but cannot
fully operate and close the acknowledgment side of the loop. In the US
safety relays probably cost more ($40-$230) than the laser module does
but you are going to want one in you system along with matching
interlock switches on any removable housings. Can you say 'Due
diligance'?. The relay would tie to the interlock circuit in the laser
module. On the supplier end I'm sure China can supply suitable tech in
their laser modules for much less than anyone else ;-)

But why would a manufacturer put any such thing in a "module" which
generally implies a component to be integrated into a system that will
later have to comply to enter commerce?

Thanks for the input!

[Richard Budd]

<Big snip>

Post by CC

least you are off to a legal start. The only way you *should* be able
to get bare laser modules is if you are a fairly large manufacturer...

Most hobbyists are buying OEM modules.

<another snip>

Post by CC
But why would a manufacturer put any such thing in a "module" which
generally implies a component to be integrated into a system that will
later have to comply to enter commerce?
Thanks for the input!

Hmm, because it gets it in the country legally? Most governments - not
just the US - are very concerned about all components that emit
potentially hazardous radiation. Super bright LED's and their kin are
starting to gather their attention as well because of the high energy
density close to the emitter(s). The 'hobbyist' aspect of compact
energy-emitting devices worries them. Sales to registered businesses (as
in the business pays taxes) are much easier.

If the 'module' is a stand alone device you just have to plug in or
hookup to a battery then it is a fully-functioning laser and MUST be
treated as such. That is what the stuff on the back of the form is
talking about. The lasers we get from SPI are components in the sense
that they will always be integrated into a larger system but - just take
it out of the box and put power to it and you have a dangerous laser
source! End of story.

To be a non-functioning component it must be just that. A laser
chip/housing with NO drive electronics in it. By their very nature a
DPSS laser almost always have self-contained drive electronics and
therefore while they may be a component in a system it is also a
stand-alone laser device. Selling 'kits' as a laser module and a power
supply you just wire together to a non-business entity is also generally
considered verboten but is also a very gray area. Having the items on
different pages in a catalog without direct references to each other
would probably get mfgr's around the laws.

Multi-watt/100's of watts high-power IR laser diodes for pumping,
telecom, or direct-diode use are prime examples of components because
you also have to provide a separate power supply.

Again, with the ease what is needed to be legal, I just don't see why
any manufacturer of these relatively low power systems (I deal with
industrial systems) just doesn't put a mechanical shutter on the housing
and do the paperwork. In China it'd cost what, 10 cents? Frankly, to me
having the modules CDRH-compliant is a selling point giving the final
OEM another layer of C.Y.A. diligence.
Cheers!

[CC]

Richard Budd wrote:
[edit]

Post by Richard Budd
Again, with the ease what is needed to be legal, I just don't see why
any manufacturer of these relatively low power systems (I deal with
industrial systems) just doesn't put a mechanical shutter on the housing
and do the paperwork. In China it'd cost what, 10 cents? Frankly, to me
having the modules CDRH-compliant is a selling point giving the final
OEM another layer of C.Y.A. diligence.
Cheers!

Thanks for the input.

Well, the CNI company that I'm planning to deal with has a little "FDA"
icon on their product datasheet. But I think that needs to be verified,
as lots of Chinese products are coming in with for instance, fake UL
stickers.

So to verify they would have to provide me a valid FDA accession #, right?

But as I understand the regs., an accession # doesn't necessarily mean
the device is compliant, only that a report has been filed. But I
suppose at that point if it is not compliant, it is the manufacturer who
has the legal/regulatory burden to fix the non-compliance, not the
purchaser.


Good day!

[Richard Budd]

Post by CC
[edit]

Post by Richard Budd
Again, with the ease what is needed to be legal, I just don't see why
any manufacturer of these relatively low power systems (I deal with
industrial systems) just doesn't put a mechanical shutter on the
housing and do the paperwork. In China it'd cost what, 10 cents?
Frankly, to me having the modules CDRH-compliant is a selling point
giving the final OEM another layer of C.Y.A. diligence.
Cheers!

Thanks for the input.
Well, the CNI company that I'm planning to deal with has a little "FDA"
icon on their product datasheet. But I think that needs to be verified,
as lots of Chinese products are coming in with for instance, fake UL
stickers.
So to verify they would have to provide me a valid FDA accession #, right?
But as I understand the regs., an accession # doesn't necessarily mean
the device is compliant, only that a report has been filed. But I
suppose at that point if it is not compliant, it is the manufacturer who
has the legal/regulatory burden to fix the non-compliance, not the
purchaser.
Good day!

On the spec sheet look for something like (from SPI's):
21 CFR 1040.10 Compliance:
These products are Class 4 lasers as
designated by the Center for Device and
Radiological Health (CDRH). They are
specifically designed to be an OEM laser
device for incorporation or integration into
other equipment. As such, they DO NOT
MEET the full requirements for a stand-alone
laser system as defined by 21 CFR 1040.10
under the Radiation Control for Health and
Safety Act of 1968. It is the responsibility of
the equipment manufacturer to meet all of
the regulatory requirements for the full
system.


Beyond that, can you dl the user manual? If it looks good with warnings,
label locations, etc. you should be good. As part of the CDRH regs it
has to be available to the user - technically come with each laser
module sold unless you have an OEM agreement with the maker to provide a
replacement one tailored to the final system.

The manual from SPI has section titled 'Compliance' that reads:
"This product is a Class 4 laser. The product is specifically designed
to be an OEM laser product for incorporation or integration into other
equipment. As such it DOES NOT MEET the full requirements for a
stand-alone laser system as defined by CFR 1040.10 and IEC/EN 60825-1"
<snip about how it meets EU regs> "Within the USA, the equipment is
shipped with an appropriately completed FDA 2877 form. It is the
responsibility of the equipment manufacturer to meet all of the
regulatory requirements for the full system."

It goes on about the safety features, labeling, & documentation
incorporated in their laser for easier final full compliance. As far as
I can see, the only thing that stops these fiber lasers from full
compliance is that the beam exits a collimator pen at the end of a
5-meter long armored fiber cable which by itself can be pointed any way
ya want with no interlocking of where it's pointed.

I can see the flames coming now but... As a rabid experimenter in me
youth it kills me to say it but, lasers with class-3 or 4 ratings should
not be sold to private individuals without some assurance they know what
they are doing. Reputable manufacturers try to enforce that idea
themselves before gov steps in harder and will show clear hesitation
when you send your first RFQ. In our case the makers do a sales call
first to check us out (and get an idea of our needs). If anything it
minimizes their liability.

On a side note, the PRC and India current have very different ideas
about laser safety than the rest of the industrial world- as in almost
none. That's part of why their equipment costs less - and is scrutinized
more by customs when imported. One of our suppliers was at the latest
Laser equipment show in Beijing a couple months ago and mentioned one
Chinese vendor with a 100J pulsed Nd:YAG firing it across the display
area to blast paint off a Coke can and make it dance from the little
explosions. No beam protection whatsoever. Asian reporters 2 FEET AWAY
TAKING PHOTOS AS THE CAN IS BEING HIT. Scary.

Cheers!

[Lostgallifreyan]

Post by Richard Budd
I can see the flames coming now but... As a rabid experimenter in me
youth it kills me to say it but, lasers with class-3 or 4 ratings should
not be sold to private individuals without some assurance they know what
they are doing. Reputable manufacturers try to enforce that idea
themselves before gov steps in harder and will show clear hesitation
when you send your first RFQ. In our case the makers do a sales call
first to check us out (and get an idea of our needs). If anything it
minimizes their liability.

No flame, but I do disagree, strongly.

First, I take it you mean class 3B? Otherwise we'd have to assume the
logical derivative is that you'd advocate a ban on all laser pointers
except <1mW CW visible.

Then, there are guns, radio transmitters over 4W, radar modules,
ultrabright LED's, strobe lights, HV power supplies, car hi-fi bass-
boosting capacitors, boxes of matches and cigarette lighters, knives,
acids, solvents... All of these things can cause sudden escalation of
danger to human life at a distance from their immediate locale, even if you
just pick them up and throw them. Lasers are rarer by far than any of
these. They have some unique dangers, but excepting very well collimated
systems with mounts that allow fine control of far-field aim (on still,
let alone moving targets), these dangers are less severe than is often
claimed.

While some better effort is required to regulate the state of class 4
lasers being distributed around the world, you can't police everyone, and
you probably don't have to. Setting a standard that others find desirable
is usually enough, and they'll do it willingly, without being forced.
People will only bend the rules if they can't get what they want just as
easily by following them. Too many firms CHARGE MONEY for these extra
legalities, and I mean SERIOUS money, way beyond what was actually spent
beyond the main system cost. They use it as a means to justify profit
and exclusively righteous self-positioning in their field of trade instead
of just charging what it costs. THAT is why people try to circumvent the
rules, it's cheaper.

All this talk of regulation and restriction seems to spread to the point
where we should question whose agenda is being served. It begins to sound
like the current debate in the UK, that the rich-poor divide is formed by
the middle classes aquiring new power and pulling the ladder up after them
so that the masses cannot follow.

Instead of making it harder for more people to get more lasers, make it
easier for them to get them the right way. Otherwise they will get them
anyway, and many of your worst fears might come true. If those who work
with lasers for a living don't want govt to make their lives miserable,
they need to get this right, you can't assist govt to divide and rule, it
needs no encouraging, beleive me. While some scientists have assisted such
moves, they rarely get remembered with much respect.

What needs to be done is to supply the parts for such systems in ways that
require some technical effort from the end user. That should weed out the
dangerous morons. >:) Scientists and engineers know FAR better than govt
how to do this. Why do you think that there is that 'grey area' that allows
catalogs to list seperate parts of systems differently from complete units,
so long as they don't overtly try to link those products in a deliberate
circumvention of rules? The govt has extended some trust there, so use it,
or they'll take it away.

If there is enough technical demand made on the end user to assemble,
enable, install and connect parts to make a system, such that the user
cannot operate the system without first doing this and gaining some
understanding, and this being made a legally binding part of sale, such
that if the user fails, they cannot claim against the seller or anyone
else, you'll solve most of the problem. There will always be ways for end
users to circumvent this, but most of those will have the desired effect of
making the end user proficient, or at least aware of the danger of what
they come to own.

[Lostgallifreyan]

Post by Lostgallifreyan
If there is enough technical demand made on the end user to assemble,
enable, install and connect parts to make a system, such that the user
cannot operate the system without first doing this and gaining some
understanding, and this being made a legally binding part of sale,
such that if the user fails, they cannot claim against the seller or
anyone else, you'll solve most of the problem. There will always be
ways for end users to circumvent this, but most of those will have the
desired effect of making the end user proficient, or at least aware of
the danger of what they come to own.

I should elaborate further here, I want to be VERY clear what I mean.

If Joe Bloggs in Brick Lane wants a 1 watt show laser and hasn't had any
college classes, he'll have to either learn, or find some geeky mate to
assemble it for him and enable whatever switches and settings are there to
allow it to work. Either way, he'll pick up plenty of good information, as
he'll have a personal interest in getting it.

This is the distinction of company policy that should be made:
Instead of assuming a right to question every buyer and assuming some kind
of righteous ability to judge (time consuming and expensive, unless you
reduce that process to a sickening prejudicial 'right-tick-in-the-box'
mentality), what they should do is focus on the technical merit alone, at
their end of the business.

By setting good technical hurdles, an engineer can be sure that sales of
products will limit the dangers from end users' misuse. They do this
without having to spend time with every sale, without having to be judge
and jury, and they probably only have to design it once, replicating it for
each laser sold. That's cheaper for the company, and they can pass the
reduced costs to the customer, making it easier for them to follow good
practise and compliance with regulations.

[Richard Budd]

Post by Lostgallifreyan

Post by Lostgallifreyan
If there is enough technical demand made on the end user to assemble,
enable, install and connect parts to make a system, such that the user
cannot operate the system without first doing this and gaining some
understanding, and this being made a legally binding part of sale,
such that if the user fails, they cannot claim against the seller or
anyone else, you'll solve most of the problem. There will always be
ways for end users to circumvent this, but most of those will have the
desired effect of making the end user proficient, or at least aware of
the danger of what they come to own.

I should elaborate further here, I want to be VERY clear what I mean.
If Joe Bloggs in Brick Lane wants a 1 watt show laser and hasn't had any
college classes, he'll have to either learn, or find some geeky mate to
assemble it for him and enable whatever switches and settings are there to
allow it to work. Either way, he'll pick up plenty of good information, as
he'll have a personal interest in getting it.
Instead of assuming a right to question every buyer and assuming some kind
of righteous ability to judge (time consuming and expensive, unless you
reduce that process to a sickening prejudicial 'right-tick-in-the-box'
mentality), what they should do is focus on the technical merit alone, at
their end of the business.
By setting good technical hurdles, an engineer can be sure that sales of
products will limit the dangers from end users' misuse. They do this
without having to spend time with every sale, without having to be judge
and jury, and they probably only have to design it once, replicating it for
each laser sold. That's cheaper for the company, and they can pass the
reduced costs to the customer, making it easier for them to follow good
practise and compliance with regulations.

Per yer 1st one, yer right, class 3B or whatever they call over 5mw this
year. I recently came across a site that sells 90mw green DPSS lasers
the size of a small flashlight. Great to use as a guidestar with your
telescope but still dangerous as hell! No questions to buy it, just send
your money. THAT is a problem!

Post by Lostgallifreyan
Then, there are guns, radio transmitters over 4W, radar modules,
ultrabright LED's, strobe lights, HV power supplies, car hi-fi bass-
boosting capacitors, boxes of matches and cigarette lighters, knives,
acids, solvents... All of these things can cause sudden escalation of
danger to human life at a distance from their immediate locale,

Er?
Guns are restricted. Timmy ten-year old can't buy one. You get above 5
watts RF or so (depends on the band)and you need a license though not
for safety reasons plus Rf power circuits don't like un-knowledgeable
people playing with them - they tend to go 'poof' rather easily. Strobes
can't sustain their output. Ultra-bright LED's & their kin have
international/FDA safety standards in the works meaning soon they WILL
be restricted above a certain intensity. The rest is - just off the
wall... ;-)

BUT - We're actually pretty much in agreement in that something needs to
be done to ensure that whoever buy this stuff knows what they are doing.
'Major assembly-required' works for me. At one time price prevented this
from being a problem but now these things are so damn cheap... As for
fully functioning 3B & 4 lasers, so far the only viable way is to
require the purchaser to be a business because they have definite legal
responsibilities & liabilities when they buy the laser device. The
company may still be a bunch of morons but it is also eminently sue-able
and ripe for prosecution if they screwup badly enough.

Post by Lostgallifreyan
Too many firms CHARGE MONEY for these extra legalities, and I mean
SERIOUS money, way beyond what was actually spent beyond the main
system cost. They use it as a means to justify profit and exclusively
righteous self-positioning in their field of trade instead of just
charging what it costs.

I've never came across 'charges for meet regs' or whatever you are
referring to. If you mean the difference in price for a fully compliant
laser vs an OEM one, you're damn right there is a difference in price -
the cost of the safety devices and liability insurance which is NOT
cheap. Our insurance company charges us a 1%-fee per-system based on
selling price of each system. The latest system we just sold for $480k
means that we pay $4,800 to insure ourselves if some loon decides to
bypass all the safeties and let the beam loose and then sue us for the
damage they cause. The interlocks for the workstation and lasers came to
exactly $2,175.20 - our cost. Plug in my time to design the circuits and
install the safeties into the equipment ($50/hr in-house charges) and
you see how it adds up very fast.

This latest system I've designed has over 1,200 hours spent by me behind
it plus the cost of the lasers I used for the research which are $68k
each. Our company didn't lay out that kind of cash to give the tech away
once it works and neither does any other one.

Cheers and don't stare at the pretty lights!

[Lostgallifreyan]

Post by Richard Budd

Post by Lostgallifreyan
Then, there are guns, radio transmitters over 4W, radar modules,
ultrabright LED's, strobe lights, HV power supplies, car hi-fi bass-
boosting capacitors, boxes of matches and cigarette lighters, knives,
acids, solvents... All of these things can cause sudden escalation of
danger to human life at a distance from their immediate locale,

Er?
Guns are restricted. Timmy ten-year old can't buy one. You get above 5
watts RF or so (depends on the band)and you need a license though not
for safety reasons plus Rf power circuits don't like un-knowledgeable
people playing with them - they tend to go 'poof' rather easily. Strobes
can't sustain their output. Ultra-bright LED's & their kin have
international/FDA safety standards in the works meaning soon they WILL
be restricted above a certain intensity. The rest is - just off the
wall... ;-)

They were meant to be, sort of. :) My point was that each has degrees of
restriction appropriate to their use or misuse, largely, even guns, despite
their danger and folkloric status. Lasers are different, there is a kind of
public fear/awe that is so unrelated to a real sense of each type that
things can and DO go agly.

I appreciate your points about costs of making them safe. If it was 1% I'd
not be at all concerned. Thing is, it's not, often, when small DPSS's are
concerned. I can't vouch for most of the things I've seen because I'm not
in a position to, but there are several on Photon-Lexicon who are fairly
adept at recognising various makes of laser despite the ever changing web
of resellers. Prices vary, often a lot. Some EU firms are suspected of
buying cheap Chinese imports and selling them at much higher prices, as if
they had something made with better parts, or special EU-compliant safety
features, and if those lasers have no change, or the addition of a small
manual shutter to slide across the aperture perhaps, it hardly justifies
the doubling or trebling of cost per laser, especially whan that laser is
still being sold as an OEM component. Price increases of that nature aren't
proportional, and probably harm the industry, as these are the practises
that make it so tempting to try to deal with Chinese firms directly.

Some EU firms doing this may state that their lasers were built in the EU,
and therefore different, but I read some time ago that Chinese firms were
buying crystals and even complete lasers made in Poland or other east
European countries. If they could do this and sell them at a low cost, it's
hard to see what can justify the high cost when border controls and postage
within the EU is a lesser obstacle that trade from China.

In short, I suspect that with most class 3B lasers meant for show gear,
there is a lot of strange pricing practise that has little to do with
safety or any other technical aspect, and more to do with manipulation of
public perception.

[Richard Budd]

Post by Lostgallifreyan
snip>

The rest is - just off the

Post by Lostgallifreyan

Post by Richard Budd
wall... ;-)

They were meant to be, sort of. :) My point was that each has degrees of
restriction appropriate to their use or misuse, largely, even guns, despite
their danger and folkloric status. Lasers are different, there is a kind of
public fear/awe that is so unrelated to a real sense of each type that
things can and DO go agly.
I appreciate your points about costs of making them safe. If it was 1% I'd
not be at all concerned. Thing is, it's not, often, when small DPSS's are
concerned. I can't vouch for most of the things I've seen because I'm not
in a position to, but there are several on Photon-Lexicon who are fairly
adept at recognising various makes of laser despite the ever changing web
of resellers. Prices vary, often a lot. Some EU firms are suspected of
buying cheap Chinese imports and selling them at much higher prices, as if
they had something made with better parts, or special EU-compliant safety
features, and if those lasers have no change, or the addition of a small
manual shutter to slide across the aperture perhaps, it hardly justifies
the doubling or trebling of cost per laser, especially whan that laser is
still being sold as an OEM component. Price increases of that nature aren't
proportional, and probably harm the industry, as these are the practises
that make it so tempting to try to deal with Chinese firms directly.
Some EU firms doing this may state that their lasers were built in the EU,
and therefore different, but I read some time ago that Chinese firms were
buying crystals and even complete lasers made in Poland or other east
European countries. If they could do this and sell them at a low cost, it's
hard to see what can justify the high cost when border controls and postage
within the EU is a lesser obstacle that trade from China.
In short, I suspect that with most class 3B lasers meant for show gear,
there is a lot of strange pricing practise that has little to do with
safety or any other technical aspect, and more to do with manipulation of
public perception.

Ah, that's a whole other story. That's more of a case of a business
actually being able to make the fabled >100% markup taught about in
business schools. Parts of the laser industry I deal with DO often make
those margins - and more. Given that, I say shop carefully and do what
you need to do to get a reliable Chinese - or South American, Brazil has
a few new suppliers - vendor and set yourself up to be a US distributor!
If there is no competition, it's a sellers market.

We sell a lot of our systems to electronics component makers in
Taiwan/PRC and you will find them eager to ferret out new business
alliances - but - be careful. They will also endlessly 'negotiate' for
months before all of a sudden wanting things done last week.

Our primary optical mechanics supplier (Laser Mechanisms) is one hell of
a money maker for the Fredricks family with typical out-the door profit
margins >300% - net! for their very specialized products. I worked
closely with its founder Bill Fredricks when he ran Photon Sources in
the 70's and he has a strict pricing rule: Raw stock or parts come in
the door - they are internally marked up 100%. The raw parts come out of
the machine shop and put into parts-stock - 100& markup. The parts get
assembled into full components and put into assembly/final stock, you
guessed it. Another 100% markup. Every operation dept. parts go through
they are marked up. As a reseller/integrator for Laser Mech we get a 20%
discount but still, they make a bundle because they are THE best out
there in a very limited supplier market.

Must be nice... We're lucky to make 25% over the parts/time costs for
our systems and we have to fight for that little. Sure a system might
sell for ~$500k but if we played hard-ball to make better margins we'd
almost never sell any equipment.
Cheers!