You are referring to the document as a "Manufacturer Declaration" where I would refer to it as an "EU Declaration of Conformity". I've seen declaration documents that say "Manufacturers Declaration", usually for components, but they are not official EU DoCs. Are you sure your rejection was because of the Letter Head or because of the Header on your document?
I am very interested in such stories as these because I'm not clear on the current required documentation or the Authority a Customs agent has regarding CE compliance, and the EU-DoC. In your case specific, where did the Customs Agent get your DoC? Though I'm not familiar with all EU Declarations, I believe that shipping the DoC with the product, though becoming more common, is not a requirement. The MD, for instance, says the DoC OR a document calling out the contents of the DoC should be in the manual. But what Customs agent is going to rip open 12 layers of cardboard, vacuum seal, and plastic wrap to search through a 300 page manual? What if it is an E-Manual? Do most people include the DoC with the shipping documentation, provide the DoC only when requested, or just include a copy in the box with each item? What is legally required? Though the CE Marking on the product is required I believe the EU-DoC just has to exist and be made available upon request. Since compliance is assumed, if an Authority requires to see your DoC isn't that a sign that the compliance of your product is in question for some reason? Do the authorities have to provide such a reason? I know the EU is trying to stop counterfeit and non-compliant devices from entering which may be the reason for requiring the DoC in Customs among taking other such steps. So far, our company's products have not been burdened by these additional measures but I would like to be prepared for the future. Thanks for listening to me. The Other Brian -----Original Message----- From: Brian Oconnell [mailto:oconne...@tamuracorp.com] Sent: Thursday, November 14, 2013 5:00 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Rejected Manufacturer Declarations Concur with Mr. Schmidt. While ISO17050-1,-2 does not require letterhead or company logo, am not aware of anything that would disallow. Would think that anything on the declaration that serves to further identify the manufacturer would be encouraged. But more than once, have received conflicting directions from various import 'authorities' across the EU; so am not surprised, and has not "strained credibility" for me. Brian From: Mark Schmidt [mailto:mark.schm...@dornerworks.com] Sent: Thursday, November 14, 2013 1:44 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] Rejected Manufacturer Declarations Hi Doug, My thoughts are that typically company letterhead would display the corporate logo/brand, their address and phone. Since your client used the UK based office letterhead this would be very relevant in meeting the requirements of DoC. As you indicated as long as critical information wasn't missing you would think that this approach would be acceptable. Regards, Mark Schmidt From: Douglas Nix [mailto:d...@mac.com] Sent: Thursday, November 14, 2013 4:31 PM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: [PSES] Rejected Manufacturer Declarations Colleagues, I had a client relate a story to me today that strained credibility, but may be true. I hope to hear your thoughts and experiences on this topic. We were discussing manufacturer's Declarations of Conformity. I made the statement that the EC Declaration should be on the manufacturer's letterhead. My client indicated that they had originally done that, issuing their declarations on the letterhead of their UK-based office. They then claimed that customs inspectors in Poland and Turkey had rejected their declarations because they were on their letterhead. I have never heard of this, and certainly know of no legislation that would support rejecting a manufacturer's declaration on this basis. I can believe that the declarations were rejected because they were missing critical information, or were incomplete in some other way. What are your experiences? Have you had declarations rejected by customs or by customs brokers in any EU member state for the same, or a similar reason? What was the resolution for you? Doug NIX, C.E.T. Compliance InSight Consulting Inc. - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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Thank you. - ---------------------------------------------------------------- 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.ieee-pses.org/emc-pstc.html Attachments are not permitted but the IEEE PSES Online Communities site at http://product-compliance.oc.ieee.org/ can be used for graphics (in well-used formats), large files, etc. Website: http://www.ieee-pses.org/ Instructions: http://www.ieee-pses.org/list.html (including how to unsubscribe) List rules: http://www.ieee-pses.org/listrules.html For help, send mail to the list administrators: Scott Douglas <emcp...@radiusnorth.net> Mike Cantwell <mcantw...@ieee.org> For policy questions, send mail to: Jim Bacher: <j.bac...@ieee.org> David Heald: <dhe...@gmail.com>
