Hi Richard:
> We may soon be privately labeling our products for a particular customer,
> and I have a question concerning the EU Declaration of Conformity. We will
> be shipping products to our customer's distribution center, and they will be
> responsible for sales to their customers. By shipping the product to our
> customer's distribution center, have we placed the product on the market and
> must therefore issue a Declaration of Conformity?
When we buy products from an OEM (whether or not
they go to our distribution center), we ask the
OEM for their DoC (and copies of reports supporting
the DoC).
Using the OEM DoC (and reports), we issue our own
DoC as if we designed and manufactured the product.
(If we have all the applicable reports, then we can
issue our own DoC regardless of whether the OEM has
issued a DoC.)
This doen't answer your question as to whether
shipping the product to your customer's distribution
center constitutes placing the product on the market.
However, in using this process, the question does not
arise as a DoC has been issued by both organizations.
I guess the answer is: If you issue a DoC, then you
have met your obligation. If you do not issue a DoC,
then you may or may not have met your obligation.
I doubt your customer would want to ship your DoC
with "his" product.
Best regards,
Rich
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