Thanks for your response Michael. I would like to clarify a few points.
>Ship product manuals (installation, service and administration) with
>every product sample.
As with the rest of your questions, the answer depends partly on
what type of products you have. The reason is that the Product
Specific Standards frequently have their own requirements, that
go above and beyond the general requirements you find in the
basic Directives and generic standards.
The product is a Small Office eXchange. RTTE directive, EN55022 & EN55024
and EN60950.
The RTTE directive Article 6 para 3 states briefly about providing info to
the user.
As I understand : should provide info to the user on the intended use of
apparatus together with DOC.
and for TTE sufficient information to identify the interfaces of public
telecommunications networks to which the equipment is intended to be
connected.
Generally speaking, you must ship with every unit only those
documents that are required to ensure safe and compliant
use and installation. So what you must ship depends on
your product and how it is used.
If you are shipping bulk packs of product to the distributors,
and if the distributors will be repackaging the products, then
there is of course no need to ship one set of docs with each
unit. BUT (important!) you must be prepared to demonstrate
that you have a written, enforced procedure that requires the
distributor to put the necessary documentation in every box.
No, the distributor won't be re-packing the boxes.
As for languages, you can generally get away with English,
French, German, and Spanish. Again, this depends partly
on the type of product you make, and on the product
specific standards that apply to your equipment. You may
also find that some countries add their own local requirement
for a particular language. You might be able to side-step
issues like this, but you would spend so much time
arguing and negotiating that it would be easier just to
do the additional translation and get on with business.
>We have a regulatory document which explains the different approvals
>(stating compliances with the directive and standards tested to, etc)
I assume you mean that you have a Declaration of Conformity
or a Declaration of Incorporation. There are mixed feelings
about this. Computer people (Dell, for example) will not
give you a Declaration of Conformity without a huge hassle,
because even though the machine itself is fully compliant,
you might put some non-compliant software on it (if you don't
know about the Wassenaar Act, you should check this
out immediately!!!).
But for the majority of manufacturers, the only sane and
intelligent thing to do is to put a Declaration of Conformity
in with each unit, or print it in your manual.
Remember that Customs inspectors are basically ignorant
about technology. They don't know - or care - what your
products do. They need to see certain pieces of paper, and
that's all there is to it. If you got the paper, then your products
pass. If you don't have the paper packed with each unit, then
be prepared to have your shipment impounded and rotting
on the dock for a few months while you run around in circles.
It's your choice.
As for soft-copy, some manufacturers put their documents
on their products in soft copy. Which I personally think is
a damn stupid idea. Can you imagine a Customs officer
booting up a PC and sorting through the hard drive? Not
bloody likely!
You are spot on here.
So, the bottom line is :
Service & Instruction manuals requirement is not part of the directives and
is not legally required.
But warnings and declarations are essential parts of the directive. In order
to ensure smooth flow of products it is advisable to have these translated
to EU languages and include a hard copy in every box.
Good luck.
Mike
Dear Members,
We are in the process of organising our shipments to various countries in
the EU. We have tested and complied with the RTTE directive and understand
the CE marking requirements. We had the following doubts wrt to the shipment
of the products.
Is it legally required to :
* Ship product manuals (installation, service and administration) with
every product sample. We intend to send manuals only to the distributor in
the respective countries and not with every box. If yes, does this legally
have to be in the respective national language. We understand that there are
11 official languages in EU. This may be required from 'marketing point of
view', but is it a legal requirement as per any directives ?
* We have a regulatory document which explains the different approvals
(stating compliances with the directive and standards tested to, etc) and
warnings we have for Europe, USA, etc. Is there a legal requirement to have
such a document stating Compliance with each sample shipped. If yes, does
this have to be in a hard copy format in the respective national language.
Alternatively, can this document be posted on the website and indicate the
access details with the product. Is this legal ?
My specific questions are as below.
1. What information (in any format) must we supply (eg. Regulatory
document). If any, what are the requirements with respect to format and
language?
2 Is there a requirement for us to provide any other information in the
native language of the country we sell into?
3 Is there a requirement for any information we supply to be in hardcopy, or
is softcopy sufficient?
4 Are there any restrictions or perhaps concessions made for putting
information on our website for people to download? Could we for example,
put all information on there and have them download all requirements?
Your comments please
Praveen Rao
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