In the context of the EMC Directive, "Distributor" is defined within the 
directive’s (2014/30/EU) Article 3, Definitions. Item (14) states 
"‘distributor’ means any natural or legal person in the supply chain, other 
than the manufacturer or the importer, who makes apparatus available on the 
market;".
It is also interesting to note that the directive's Definitions specifically 
differentiate between "placing on the market" and "making available on the 
market". 
Article 3, Definitions, item (9) states "‘making available on the market’ means 
any supply of apparatus for distribution, consumption or use on the Union 
market in the course of a commercial activity, whether in return for payment or 
free of charge;".
Note the circular reference. Distributors can ‘make available’ to other 
distributors (or for consumption/use). It is therefore possible to have 
multiple distributors in the supply chain, which includes the final distributor 
supplying the apparatus to the end user, or in directive speak 'making 
available on the market for consumption or use', i.e. whoever sells or supplies 
it last.
So according to the directive we could have: Manufacturer ==> Shipper ==> [EU] 
Importer ==> Distributor 1 =//=> Distributor n ==> Consumer/End User.
Now it gets interesting. Article 10 of the directive sets out the "Obligations 
of distributors" which essentially states that the 'distributor' shall ensure 
that:
* Apparatus bears the CE mark
* Required documents are present
* Article 18 is met (information regarding precautions, restrictions, intended 
use)
* Annex I, Essential Requirements are met (the technical stuff)
* Stored & transported such that Annex I requirements are not compromised
* Any non-compliant goods already sold are fixed or recalled
* Have documentation available demonstrating compliance (TCF ?)
So all you wholesalers, trade distributors, chain-store buyers, mail order 
companies, internet retailers, market traders, stall holders, eBay sellers, 
small shop owners and fencers of stolen goods... you'd better make sure you 
understand and fulfil your obligations under Directive 2014/30/EU of the 
European Parliament.
What could possibly go wrong?
T
----- Original Message -----
From: John Woodgate
Sent: 04/25/14 07:14 AM
To: EMC-PSTC@LISTSERV.IEEE.ORG
Subject: Re: [PSES] SV: [PSES] New EMC Directive

In message <20140425.073410.415869030.vef00...@nifty.ne.jp>, dated Fri, 25 Apr 
2014, T. Sato <vef00...@nifty.ne.jp> writes: >I thought all retailers are also 
distributors under the new EMC >directive, as they are in the supply chain. > 
>Am I missing something? The two words have different meanings. As I said, some 
companies do both. Just as an example, a distributor might or might not have a 
'trade counter' where professionals can go to buy stuff, but they normally take 
orders by phone or on-line and send stuff from their warehouses, whereas 
retailers have shops/stores where the general public go. -- 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 - 
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