I believe you are incorrect in your assumption that the authorized representative must write the DoC. I believe if you look at the directives for the most part they say Manufacturer or authorized rep, not only authorized rep.
Dennis Ward Director of Engineering American TCB Certification Resource for the Wireless Industry www.atcb.com 703-847-4700 fax 703-847-6888 direct - 703-880-4841 209-769-8316 NOTICE: This E-Mail message and any attachment may contain privileged or company proprietary information. If you received this message in error, please return to the sender. _____ From: emc-p...@ieee.org [mailto:emc-p...@ieee.org] On Behalf Of Piotr Galka Sent: 09/15/2007 2:45 AM To: EMC-PSTC Subject: Another DofC and CE basic question. Hi All, Seeing the discussion titled "Declaration of Conformance" I allowed myself to ask another basic question. I suppose the answer is obvious for lot of you, by I don't know it. The out of EU manufacturer must have the authorised representative established in the Community and it is that representative who has the right to write DoC and to affix the CE mark (that manufacturer is not allowed to do it). As I understand the customs needs CE on products coming to EU, but nobody outside the EU can affix CE I see no possible solution to import anything. Where is the point I miss ? In new Guidelines on the application of LVD I see (note 22 at page 12): "The obligations do not extend to an importer who will, in general, not have a detailed knowledge of which directives have been considered or technical specifications applied". I suppose that importer can import something directly from manufacturer (not buy it from his authorised representative). Do the importer has to get the DoC (and keep it long after finishing that import) from authorised representative or it is enough for him to know that the manufacturer has the representative and it is the representative responsibility to have all papers for all products send by this manufacturer to EU ? And from another side: Who (in that case) should write the disassembly instruction (for WEEE) (if the importer is in another EU country that the representative) ? The importer is responsible to have that instruction, but >from the note I have mentioned above somebody out there noticed that "importer, in general, not have a detailed knowledge" ? If there are several importers in one EU country of some product, I understand all of them put that product on that country market. If the product becomes WEEE how it is decided for which importer to account that product to count the recycling results. Do each product must be permanently marked not only by producer (product name), his authorised representative (the CE mark), but also by each importer and that WEEE products are sorted not by producer name but by importer name ? Sorry to All for such basic, and partially not EMC-PSTC, questions, but I believe here are peoples who knows that the best. Best Regards, Piotr Galka MicroMade Poland ______________________________________________________________________ This email has been scanned by the MessageLabs Email Security System. For more information please visit http://www.messagelabs.com/email ______________________________________________________________________ - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. Website: http://www.ieee-pses.org/ To post a message to the list, send your e-mail to emc-p...@ieee.org Instructions: http://listserv.ieee.org/request/user-guide.html List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas emcp...@ptcnh.net Mike Cantwell mcantw...@ieee.org For policy questions, send mail to: Jim Bacher: j.bac...@ieee.org David Heald: emc-p...@daveheald.com All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc
