In message
<64D32EE8B9CBDD44963ACB076A5F6ABB0266DBB8@Mailbox-Tech.lecotech.local>,
dated Fri, 15 Nov 2013, "Kunde, Brian" <brian_ku...@lecotc.com> writes:
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.
If there is a suspicion of non-conformity, even 'technical' rather than
substantive, i.e. only documentation or marking is incorrect, the
product cannot cross the border and is impounded.
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.
No, but it's sensible. If the regulator wants to see the DoC but it
isn't there, the product is likely to be impounded until it is there.
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?
I advise putting a copy with the shipping documents, which M le Douane
has in his hot little hand.
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?
Largely irrelevant: what is required for a quiet life is relevant.
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?
Yes.
Do the authorities have to provide such a reason?
Not immediately, and if challenged, they will definitely find 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.
Be prepared. Go the extra kilometre. Co-operate with Herr Zoll. Don't
try to stand on your rights on principle; it is not in your interest.
--
OOO - Own Opinions Only. With best wishes. See www.jmwa.demon.co.uk
Nondum ex silvis sumus
John Woodgate, J M Woodgate and Associates, Rayleigh, Essex UK
-
----------------------------------------------------------------
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>
