In the eyes of the new legislative framework (and other legislation groups), retailers are the same as distributors (or at least a retailer is a type of distributor). A specific natural or legal person might be a couple economic operators. It is possible to be both a manufacture and a distributor, for example.
Many Commission discussions of the NLF use a phrase like "....distributors (including retailers)...." Sometimes "retailer" is an exact substitute for "distributor" (rather than a subset). For example, regarding battery legislation, this explanation from UK guidance THE WASTE BATTERIES AND ACCUMULATORS REGULATIONS 2009 Government Guidance Notes May 2011 "Examples of distributors are: -- A retailer that buys packs of batteries from a UK supplier and then sells them to end users -- A wholesaler that buys batteries from a UK supplier and sells both to end users and retail outlets -- A company that supplies batteries free-of-charge as part of a promotion, even if they do not normally sell batteries. Examples of companies that are both distributors and producers [LC equiv. to manufacturer in battery reg. speak] are: -- A business that imports and places batteries on the UK market and also sell them through their own retail outlet or network of outlets. -- A business that has purchased batteries wholesale from a UK supplier and then sells the batteries on to end-users would be a distributor; if that same business also imports calculators that include batteries into the UK and also sells these on to end-users, then the business would also be a producer of the batteries in the calculator." The Irish batteries regulation is written in terms of "retailer" even though the directive is written in terms of "distributor", but actions attributed to this economic actor (the retailer) in the Irish legislation are acts of "distribution" Just a guess - but I imagine a difference between a distributor and a retailer may appear, and be significant, in regulations related to taxes, advertising, etc... Regards, Lauren Crane KLA-Tencor -----Original Message----- From: Jim Hulbert [mailto:jim.hulb...@pb.com] Sent: Friday, April 25, 2014 7:00 AM To: EMC-PSTC@LISTSERV.IEEE.ORG Subject: Re: [PSES] SV: [PSES] New EMC Directive But there are also retailers who do NOT have shops/stores but only sell on-line. So I think the definition of "retailer" is becoming murkier. Jim -----Original Message----- From: John Woodgate [mailto:j...@jmwa.demon.co.uk] Sent: Friday, April 25, 2014 2:15 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 - ---------------------------------------------------------------- This message is from the IEEE Product Safety Engineering Society emc-pstc discussion list. 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