Some Trouble with LaserGlow.com Blue CNI Laser

[OPO226]

I thought for OEM lasers you do not need any numbers to import legally... I thought that was for finished projectors or something.

From FDA-2877: If you declare that a laser(s) for import "ARE NOT SUBJECT TO RADIATION PERFORMANCE STANDARDS," because they "Are components or subassemblies to be used in manufacturing or as replacement parts" then "Components or sub-assemblies must be non-functioning."

The only other option to not have the item held under bond is to provide an FDA accession number.

[buffo]

Have them ship the head separately. Declare it an OEM laser product that is not subject to radiation performance standards under declaration A5.

Since it's only a head, it's non-functioning. There's no fraud; you can clearly demonstrate that it is non-functioning to any customs inspector that decides to be an asshole and wants to open your package. It is exactly an OEM part. Nothing more.

Ship the power supply separately, and because it's not a radiation-emitting device it is not subject to the FDA import restrictions at all.

Now, put the two pieces together. Bingo - you just became a laser manufacturer. Technically, in the US you now need to register with the FDA (actually the CDRH) before you sell it. In practice, however, no one ever does. They just include the entire projector in a variance application, and they're golden...

Seriously, how do you think people import lasers? I can't remember the last time I saw an accession number on a laser. Hell, even the Spectra-Physics 163 argons that I have don't have them, and they were pulls from working copiers here in the US! The difference is that they were ordered from SP as either a head or a PSU. Never as a matched set.

Adam

[allthatwhichis]

That's what I was getting at. You said you work at a US Government Lab... Do things like the US Government. Actually for $2400, did you check SP or MG? That much money you probably could have bought American.

[Dr Laser]

I imported full laser units (PS and head) with full description what it is. And only what I got was a duty and tax bill. What kind of illegal pirate am I?

[buffo]

You are in Canada. Different rules, Doc. Different rules.

Adam

[Dr Laser]

Can't believe it's that bad across Niagara falls.

[OPO226]

Have them ship the head separately. Declare it an OEM laser product that is not subject to radiation performance standards under declaration A5.

Since it's only a head, it's non-functioning. There's no fraud; you can clearly demonstrate that it is non-functioning to any customs inspector that decides to be an asshole and wants to open your package. It is exactly an OEM part. Nothing more.

Hmm, interesting. Do you agree that to import even an OEM laser module that is non-functioning, that FDA-2877 needs to be filed?

Ship the power supply separately, and because it's not a radiation-emitting device it is not subject to the FDA import restrictions at all.

Now, put the two pieces together. Bingo - you just became a laser manufacturer. Technically, in the US you now need to register with the FDA (actually the CDRH) before you sell it. In practice, however, no one ever does. They just include the entire projector in a variance application, and they're golden...

Yeah, since I never intend to sell it, I think my worries would end once the item was delivered and duties paid, if necessary.

Seriously, how do you think people import lasers? I can't remember the last time I saw an accession number on a laser. Hell, even the Spectra-Physics 163 argons that I have don't have them, and they were pulls from working copiers here in the US! The difference is that they were ordered from SP as either a head or a PSU. Never as a matched set.

I purchase a lot of scientific lasers. I recently purchased a 100W 532nm system from LeeLaser for $150k that had detailed info about the FDA registration #s in the first few pages of the manual. I would have been rather concerned if it hadn't. I also flew to the factory before buying the laser for detailed training.

There are now onerous requirements for training, procedures, users needing to be registered at various operating classifications (user, maintainer, etc.), in US DOE labs after a string of serious accidents with YAGs over the past few years, in order to use them at all.

[buffo]

Do you agree that to import even an OEM laser module that is non-functioning, that FDA-2877 needs to be filed?

TECHNICALLY? Yes. In practice? No. If you want to play by the rules, by all means file the 2877. But I'd be very surprised if you had any trouble with your order even if you didn't fill out the form.

Granted, I haven't imported all that many lasers, but I didn't bother to fill out any customs declaration for the ones I did. Never had any problem either... The box simply showed up at my door (courtesy of DHL) with no issues whatsoever.

Furthermore, you are the first person I've spoken with that actually went to the trouble to file the proper customs document for a laser. (I'm speaking solely of hobbyists here, mind you. I'm exempting the people I know that have imported large lasers for industrial use.)

I think my worries would end once the item was delivered and duties paid, if necessary.

Yeah, we're on the same page here.

I purchase a lot of scientific lasers. I recently purchased a 100W 532nm system from LeeLaser for $150k that had detailed info about the FDA registration #s in the first few pages of the manual. I would have been rather concerned if it hadn't. I also flew to the factory before buying the laser for detailed training.

Well, there's an enormous difference between the purchase of a 100 watt YAG (did you say $150,000? ) that will be used in a production or laboratory environment and the average hobbyist purchase of a 100 milliwatt DPSS green laser that will be tinkered with in the garage...

Scientific lasers are expensive. For the kind of money you pay, you have every right to expect a detailed manual, FDA accession number, factory training, and outstanding specs. But filling out a 2877 for a $400 laser that someone is going to use for a hobbyist projector is overkill. Yes, it's still the letter of the law, but the combined experience of the many members here on the forum suggests that it's not necessary.

There are now onerous requirements for training, procedures, users needing to be registered at various operating classifications (user, maintainer, etc.), in US DOE labs after a string of serious accidents with YAGs over the past few years, in order to use them at all.

And that makes sense, if they're working with a 100 watt laser. But those same requirements are silly when applied to the average hobbyist and his class3b laser. To use an analogy - there are OSHA requirements for working above 6 ft off the ground (lifeline and body harness) that apply to industry but are never applied (or even considered) in the home.

Don't get me wrong... I think you actually have a unique advantage over most hobbyists; you're already used to treating *all* lasers with the utmost respect. (Most hobbyists start out with low power pointers and gradually move up. Sometimes this leads to a cavalier attitude when it comes to lasers in general, which can really be a liability when you start messing around with medium frame ion lasers...) But there comes a time when you have to accept that there are some differences between how a hobbyist operates and how a large government laser research lab operates.

This would be an interesting question to pose to the CDRH though. I've called them before, and each time they've been quite helpful. I'm curious as to what they'd say about it...

Adam

[rosskim1980]

I bought it Aug 20. It is a LRS-473-AM-80-5 as I said, which is CNI MBL series, 80mW, with 10kHz analog modulation and 3% power stability.

Last night I seemed to get a fairly stable 80-85mW over a long period. I have to set up a photodiode some time this weekend to check the modulation. It's hard to get anything done with a 2.5 year old running around.

As far as I know, for CNI blue laser with analog modulation,the power stability can not be 3%, last time I purchased one blue laser from CNI directly, MBL-473nm-100mW with 10kHz analog modulation, the guy in CNI told me if it is blue laser with analgo modulation, the power stability can only be 10%.so I think if you have question,it is better to contact CNI guys directly,maybe you will get some good advices from them.