Just a stupid question … why would an non-EU manufacturer have to create a declaration for an item such as this. I could see something for machinery or appliances etc. but for an ROV thruster.
No matter what, Blue Robotics is going to have to deal with it. I have attached something that covers some of the requirements or waivers for low voltage devices which this falls under. They are going to need to develop the certificate and mark accordingly if they are going to sell outside of the United States. I have to deal with our ITAR issues all the time and it is just something you have to live with.
The guideline that the document calls out should provide the wiggle room for this issue. On your part, you might ping on customs and tell them that the device is covered under exceptions granted to “Low Voltage”. I don’t know how far that will get you but you can copy some of the technical data off the site and see if that helps.
lvdgen_en (625 KB)