On Fri, 06 Jun 2014 23:20:06 +0800,
  Scott Xe <scott...@gmail.com> wrote:

> Thanks!  What is the major impact on own brand labelers?

NLF directives such as 2014/30/EU defines "manufacturer" as
"any natural or legal person who manufactures apparatus or
**has apparatus designed or manufactured, and markets that apparatus
under his name or trade mark** ;"

The new Blue Guide has some additional explanation on this:
"The manufacturer may design and manufacture the product himself.
As an alternative, he may have it designed, manufactured, assembled,
packed, processed or labelled with a view to placing it on the market
under his own name or trademark, and thus presenting himself as a
manufacturer (footnote 78).
...
(footnote 78) Those manufacturers are often referred to as 'own brand
labellers' or 'private labellers'."


So, I think they will be required to take all the responsibility as
the manufacturer.

Regards,
Tom

-- 
Tomonori Sato  <vef00...@nifty.ne.jp>
URL: http://homepage3.nifty.com/tsato/

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