Hi All,
I'm surprised to see all these questions.... These exact same requirements
have been in the Recast ROHS Directive and mandatory since Jan 13. So if
for example you are an EU manufacturer placing goods on the EU market you
MUST place your address on the product as per Art 7h(unless size does not
permit etc etc).. There is nothing new in the EMC and LVD Recasts, they are
just coming into line with all the other Directives that have previously
had the NLF requirements applied to them.
Cheers
Ed
On Sat, Apr 26, 2014 at 12:56 PM, ce-test, qualified testing bv - Gert
Gremmen <g.grem...@cetest.nl> wrote:
> As far as i understand the idea behind
> the new directives is to put liability
> for compliance at the whole supply chain.
> In the past, too often an importer (liable in the old directive)
> could not be held responsible/liable because
> he did not exist, had disappeared
> or simply could not be found, leaving the EU with
> a non-compliant product and no-one to blame.
> (while not EMC, see RAPEX-listings for
> 100s of anonymous non complaint products)
> By including the whole chain the commission
> decided it would be more easy to enforce.
>
> So I doubt that the subtle differences between
> importer, distributor of retailer as
> laid out in this discussion will mean something
> for liability in this respect.
>
> Neither do I believe that to ensure or to verify
> will lead to a different position of the enforcement
> authorities in respect to these parties. The words
> only reflect the action the different parties
> they need to take to ensure
> -i repeat- ensure that only compliant products
> are "made available to the market" or "put into service on the market"
>
> The verification action is no different from the ensuring
> action, in that both require any person in the supply chain
> to be able to provide "prove" a safe product is will be sold.
> ("prove" in the classical sense of ec directives)
>
> This can mean that he requests proof of compliance from
> the manufacturer, or any person in the supply chain above.
>
> It will also lead to a substantial changes
> in sales contracts between partners in the supply chain.
>
> While the authorities can and will use public right
> to charge any available agent in the chain, the consequences
> for liability between chain partners will need to be covered with civil
> right. And that is quite another beast.
>
>
>
> Regards,
>
> Ing. Gert Gremmen, BSc
>
>
>
> g.grem...@cetest.nl
> www.cetest.nl
>
> Kiotoweg 363
> 3047 BG Rotterdam
> T 31(0)104152426
> F 31(0)104154953
>
> Before printing, think about the environment.
>
>
> -----Oorspronkelijk bericht-----
> Van: Charlie Blackham [mailto:char...@sulisconsultants.com]
> Verzonden: Friday, April 25, 2014 5:02 PM
> Aan: EMC-PSTC@LISTSERV.IEEE.ORG
> Onderwerp: Re: [PSES] Retailer vs. Distributor RE: [PSES] SV: [PSES] New
> EMC Directive
>
> All
>
> These new NLF aligned Directives are just Directive at present.
> None have yet been implemented in national legislation and there is also
> no "official" "guidance".
>
> I think we may need to wait (quite) a few months before there is more
> clarification in this area.
>
> The new sections on obligations of importers and of distributors are
> designed to allow better market enforcement. Since this is actually done at
> national level, under national legislation:
> - it will be interesting to see what gets implemented in that legislation
> - what (subtle) differences there are between different countries in their
> implementation.
>
> Regards
> Charlie
>
> -----Original Message-----
> From: Crane, Lauren [mailto:lauren.cr...@kla-tencor.com]
> Sent: 25 April 2014 15:49
> To: EMC-PSTC@LISTSERV.IEEE.ORG
> Subject: [PSES] Retailer vs. Distributor RE: [PSES] SV: [PSES] New EMC
> Directive
>
> 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.ukNondum ex
> silvis sumus John Woodgate, J M Woodgate and Associates,
> Rayleigh, Essex UK
>
> -
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