Jumping in not having researched the full thread... be sure to see also the new framework directive/regulation on CE Marking that strives to provide legal certainly regarding these various economic actors (manufacturer's, distributors, importers, etc...)
Ref Regulation 765/2008, regulation 764/2008 and Council Decision 768/2008/EC Regards, Lauren Crane Applied Materials america - europe - asia Corporate Product EHS www.amat.com lauren crane (mr.) product regulatory analyst (t) +1.512.272.6540 lauren_cr...@amat.com - external use - Save paper and trees! Please consider the environment before printing this e-mail. John Woodgate <j...@jmwa.demon.co.uk> Sent by: emc-p...@ieee.org 08/03/2010 01:04 PM To EMC-PSTC@LISTSERV.IEEE.ORG cc Subject Re: EU Declaration of Conformity In message <AANLkTimvdGX9cMCRa3-4bkQVNzJGC6+n=gbls7fzc...@mail.gmail.com>, dated Tue, 3 Aug 2010, Carl Newton <emcl...@gmail.com> writes: >I believe that this last statement, above, may apply to company B that >is private-labeling a product manufactured by company A and placing it >on the EU market. In this case, Company B assumes the role of the >manufacturer and is responsible for it's own DoC. Although it did not >do the design, and does not actually manufacture the product, Company B >must accept the responsibilities of the manufacturer as defined in the >Blue Guide. That is correct, and in that case Company B would be well-advised to carry out sample testing on the incoming product and set up a cast-iron contract with the supplier so as to extract reparations if non-conforming product is shipped. But it does not apply to the case cited by the enquirer, which was about a product manufactured outside the EU and distributed partly by a company within the EU and partly through other channels. -- OOO - Own Opinions Only. Try www.jmwa.demon.co.uk and www.isce.org.uk John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK If at first you don't succeed, delegate. But I support unbloated email http://www.asciiribbon.org/ - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at: http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.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...@socal.rr.com> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com> - This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. To post a message to the list, send your e-mail to <emc-p...@ieee.org> All emc-pstc postings are archived and searchable on the web at http://www.ieeecommunities.org/emc-pstc Graphics (in well-used formats), large files, etc. can be posted to that URL. Website: http://www.ieee-pses.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...@socal.rr.com> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher <j.bac...@ieee.org> David Heald <dhe...@gmail.com>