Oh boy!   I do think you have a potential can of worms here.   I'll try and
take this one by one, my responses preceded by TG:


*       "...then re-label it with our own label, make only minor physical
changes, document the product and sell it in the EU."   TG:  I don't think
that you can legally re-brand someone else's product without their
permission.   Are you also attaching "their" existing regulatory approval
labels that are now associated with your name?????   That is
misrepresentation, or worse.   Regarding "...minor physical changes...", you
may be sabotaging the power supply's existing safety approvals.  
*       "In the event that the unit's conformance to the Electromagnetic
Compatibility Directive (89/336/EEC) or to the Low Voltage Directive
(73/23/EEC) is challenged, who is liable to
represent the product?"  TG:   You are, since you are placing it on the
market.


Tania Grant,  tgr...@lucent.com
Lucent Technologies, Switching Solutions Group
Intelligent Network and Messaging Solutions


-----Original Message-----
From: wmf...@aol.com [ mailto:wmf...@aol.com <mailto:wmf...@aol.com> ]
Sent: Wednesday, December 13, 2000 7:03 AM
To: emc-p...@ieee.org
Subject: OEM Issues (EU context)



Similar to the 'SAFETY LISTING' thread this week:

As a manufacturer of electrical equipment, we purchase another manuf's power
supply, CE-marked by them with a copy of their Declaration of Conformance.
We
then re-label it with our own label, make only minor physical changes,
document the product and sell it in the EU. In the event that the unit's
conformance to the Electromagnetic Compatibility Directive (89/336/EEC) or
to
the Low Voltage Directive (73/23/EEC) is challenged, who is liable to
represent the product? My guess is that we are ast least as responsible as
the 'manufacturer', above, but mine is not a legal opinion.

Anyone out there (especially on the continent)in a position to offer advice
on how I should proceed?

Many thanks.

WmFlanigan

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