We do almost all of our repairs by having the customer return the unit to the factory and the unit soon returned to the general licensee. Do we need to report this activity as a receipt from and retransfer to the general licensee?
Generally, no. The reporting of transfers (and receipts) of generally licensed devices is for tracking what specific devices general licensees possess. Taking temporary physical custody for the purpose of repairing a device is not considered a transfer (or receipt) for this purpose. However, if the repair involves a change to the source such that the label information changes, it must be reported under 10 CFR 32.52(a)(4) or (b)(4). Care should be taken to ensure that any device sent in for repair, but not ultimately returned to the same general licensee, is reported. It may be reported for the quarter in which it was determined that the device would not be returned to the same general licensee, if not previously reported for the quarter in which the device was received. If a device is received from a general licensee (e.g., for repair) and then returned to the same company, but is installed in a use location that is different from the original use location, must this be reported as a r
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