Barry Hi!

I still think "it is best" is the most appropriate answer. If 
manufacturer has a European office, there is no problem in holding 
the technical file at both the manufacturer and European office. 
However, many of the foreign manufacturers do not have a 
European office and use distributors or market under co-licensing 
Agreements with other manufacturers. Under this circumstance, I 
do not think it is a good idea to keep one's file in Europe, since the 
file consists of proprietary information (schematics, drawings, etc.).

I believe the Directives specify the delivery of the files to the 
responsible Authorities within 10 days. With today's courier 
services, there should be no problem meeting the deadline. With 
the Year 2000 Bug problem, there could be havoc!

I summarize to state that there is no problem in keeping the Doc at 
both the manufacturer's site and in Europe. However, be aware that 
if manufacturer has no office of its own in Europe, keeping the 
technical file there can cause "leakage" of information. 

 

Date sent:              Thu, 22 Oct 98 15:26:37 PDT
To:                     <emc-p...@ieee.org>
From:                   <b...@namg.us.anritsu.com> "Bailin Ma"
Subject:                Re: DoC
Send reply to:          <b...@namg.us.anritsu.com> "Bailin Ma"

> My understanding is that "it is best..." in Peter's Email should be changed 
> to "it is MUST ...". In other words, "it is MUST for the manufacturer and 
> European office to hold a copy of the DoC and technical file." If your 
> product will be made or sold in CE countries.
> Please correct me. Regards, Barry Ma
> -------------
> Original Text
> From: "Peter Merguerian" <pe...@itl.co.il>, on 10/22/98 1:04 PM:
> Dear Roger,
> 
> It is the manufacturer's responsibility. A European rep need not 
> sign the DoC. However, it is best for the manufacturer and 
> European office to hold a copy of the DoC and technical file.
> 
> Regards,
> 
> 
> From:                 roger...@astec-asia.com
> Date sent:            Thu, 22 Oct 98 09:42:49 EST
> To:                   emc-p...@ieee.org
> Subject:              DoC
> Send reply to:        roger...@astec-asia.com
> 
> > 
> >      Who has the authorisation to sign the DoC for CE Making?  Is it 
> >      necessary to be signed by European office?
> >      
> >      Regards,
> >      
> >      Roger Hsu
> > 
> > ---------
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> 
> 
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PETER S. MERGUERIAN
MANAGING DIRECTOR
PRODUCT TESTING DIVISION
I.T.L. (PRODUCT TESTING) LTD.
HACHAROSHET 26, P.O.B. 211
OR YEHUDA 60251, ISRAEL

TEL: 972-3-5339022
FAX: 972-3-5339019
E-MAIL: pe...@itl.co.il
Visit our Website: http://www.itl.co.il

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