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
-------------------------------------------
This message is from the IEEE EMC Society Product Safety
Technical Committee emc-pstc discussion list.
Visit our web site at: http://www.ewh.ieee.org/soc/emcs/pstc/
To cancel your subscription, send mail to:
majord...@ieee.org
with the single line:
unsubscribe emc-pstc
For help, send mail to the list administrators:
Ron Pickard: emc-p...@hypercom.com
Dave Heald: davehe...@mediaone.net
For policy questions, send mail to:
Richard Nute: ri...@ieee.org
Jim Bacher: j.bac...@ieee.org
All emc-pstc postings are archived and searchable on the web at:
http://ieeepstc.mindcruiser.com/
Click on "browse" and then "emc-pstc mailing list"