In message
<64D32EE8B9CBDD44963ACB076A5F6ABB0265E1CC@Mailbox-Tech.lecotech.local>,
dated Thu, 25 Jul 2013, "Kunde, Brian" <brian_ku...@lecotc.com> writes:
1. The LVD, MD, and EMCD refer to the DoC in the annex as "EC
Declaration of Conformity". But in the RoHS Directive, it is referred
to as "EU Declaration of Conformity". Is one more correct than the
other or is EC and EU both acceptable as the title of your DoC?
The designation changed from EC to EU a few years ago. The Directives
haven't caught up yet.
2. The Machinery Directive states in several locations that the DoC
must "accompany the machinery". Now I get burned by definitions all
the time so your input to the meaning of "accompany" is appreciated.
One might say this means that the DoC has to be in the box when you
ship the product; another's would say the DoC has to be created or
exist or occur at the same time as the product is placed on the market,
but the DoC does not have to physically ship with the hardware.
My advice is to interpret it literally and send a copy with the product.
That way Herr Zoll or Monsieur Douane can't impound the shipment for a
month while he gets round to demanding a copy of the DoC.
Does the DoC even have to be provided to the customer or can it just be
made available upon request, or make it available for download online?
Can we provide the DoC separately such as via an email to the customer
or as part of the Sales Agreement Documentation?
There appears to be no legal requirement for the customer to see the
DoC, because it's information intended for Customs and Market
Surveillance. But many customers demand to see it anyway.
We currently provide the DoC in the User's Manual but it has become a
nightmare. Any time a standard or directive number or date changes, we
have to create all new DoCs. This means hundreds of new or revised
prints, part numbers, and ECNs to update thousands of Bill of
Materials. Manual Packs already built have to be reworked. So we really
need to get the DoC out of our BOM system because of how often it changes.
Print it on a separate piece of paper, not in the manual, and include it
with the shipping documents. That's where Zoll and Douane will look for
it.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Why is the stapler always empty just when you want it?
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
-
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