I believe that we need to consider the definition of 'manufacturer' . Consider the following from Section 3 of the Blue Guide:
"The manufacturer may design and manufacture the product himself. As an alternative, he may have it designed, manufactured, assembled, packed, processed or labelled with a view to placing it on the Community market under his own name, and thus presenting himself as a manufacturer." http://ec.europa.eu/enterprise/policies single-market-goods/documents/blue-guide/index_en.htm 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. Carl On Tue, Aug 3, 2010 at 1:00 PM, John Woodgate <j...@jmwa.demon.co.uk> wrote: In message <001801cb3329$482681f0$d600a...@tamuracorp.com>, dated Tue, 3 Aug 2010, Brian O'Connell <oconne...@tamuracorp.com> writes: While the term 'agency' my not apply to that side of the cod pond, these institutions all have specific requirements for this when a product bears their mark. But these are nothing to do with CE marking. Use of their marks for re-label depends on the general services agreement that has been signed with the NCB. Have noted that my employer's agreement with BSI, TUVR, CSA, Nemko, and UL are all similar. And the "undelegatable responsibility" is a given for the manufacturer. But there are still vehicles where the D of C that gets into the end-users' hands, or where the D of C that is publicly published for the product does not originate from the manufacturer. That would be illegal. The DoC must be signed by a responsible officer of the manufacturer. On the subject of cod and agencies - did ya know that there is a Food Standards Agency in the UK that regulates the use of the term "fish and chips" ? And many other common phrases, such as 'low fat'. -- 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>
