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
 
 

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